For a French founder, fund principal or family-office client with €500K+ of stable foreign income, moving tax residency from France to Greece is now one of the cleanest ways to cap a worldwide tax bill inside the European Union. France charges an effective top rate of around 49% (45% barème + 4% CEHR + the 30% PFU on capital income). Greece, under the non-domiciled flat-tax regime introduced by Law 4646/2019 (article 5A), charges a flat €100,000 per year on all foreign-source income for up to 15 years, plus €20,000 per added family member — and Greek-source income is the only thing that escapes the cap. The catch sits squarely on the French side: the article 167 bis exit tax on substantial shareholdings, the four alternative tests under article 4 B CGI, and the foyer fiscal doctrine that can keep you French-resident even after physically moving to Athens or Mykonos.
The Tax Delta at a Glance
| France (current) | Greece (after move) | |
|---|---|---|
| Personal income tax | 0–45% progressive (barème) | 9–44% progressive on Greek-source income; €100,000 flat on all foreign income as Article 5A non-dom |
| Contribution exceptionnelle sur les hauts revenus (CEHR) | 3–4% above €250K / €500K | None |
| Capital gains | 30% PFU (12.8% IR + 17.2% CSG/CRDS) on shares; up to 36.2% on real estate | Foreign gains absorbed in €100K flat; 15% on Greek non-listed shares only |
| Dividends, interest, royalties (foreign) | 30% PFU + CEHR | Inside the €100K flat — no extra tax |
| Wealth / inheritance | IFI 0.5–1.5% on real estate >€1.3M; up to 60% inheritance tax | No wealth tax; inheritance 1–10% direct line (€150K threshold per child) |
| Worldwide vs territorial | Worldwide for residents | Worldwide, but Article 5A caps the foreign portion |
| Effective rate (entrepreneur, €1M foreign passive income) | ~47–49% | ~10% (the €100K flat as a share of €1M) |
The arithmetic shifts decisively above roughly €450,000 of foreign income — that is the break-even where Greece’s €100K flat tax becomes cheaper than the standard Greek progressive rates. Below that, the regime is overpriced; above it, every additional euro of foreign income is taxed at 0% in Greece. A French resident earning €1M of foreign dividends and capital gains pays close to €450,000 in combined IR + CSG/CRDS + CEHR. The same €1M routed through Greece under Article 5A pays a hard €100,000. At €5M of foreign income, Greece saves roughly €2.2M+ per year and slips below Italy’s €200K forfait (raised from €100K in August 2024) as the cheapest “single-cheque” non-dom regime in the EU.
Step-by-Step Move
Step 1: Confirm you can legally cease French tax residency
France’s residency rules sit in article 4 B of the Code général des impôts. You are French tax-resident if any one of four alternative tests is met: (a) your foyer (the household, typically where the spouse and minor children live) is in France; (b) your lieu de séjour principal — broadly the 183-day rule — is in France; (c) you carry on professional activity in France that is not ancillary; or (d) the centre of your economic interests is in France. These are alternative, not cumulative. Spending fewer than 183 days does not on its own sever residency.
For a France→Greece move this is the most-litigated frontier. The classic mistake is the founder who relocates to Athens alone while the spouse and school-age children stay in Paris “until the school year ends.” Under criterion (a) the founder remains French tax-resident at zero personal days in France, the article 167 bis exit tax has not even been triggered, and the Article 5A application is technically valid but defeated by the treaty tie-breaker. Move the family. Terminate or genuinely arm’s-length-let the French résidence principale. Wind down or transfer professional activity. Shift the economic centre. Document each fact contemporaneously: lease termination, EDF/water cut-off, school deregistration, Greek lease or property deed, AFM (Greek tax number) issuance, and Greek bank statements.
Step 2: Plan around France’s exit tax (article 167 bis)
France’s exit tax under article 167 bis CGI applies to individuals who have been French tax resident for at least six of the last ten years and who hold either (i) qualifying portfolio interests with a fair market value above €800,000, or (ii) at least 50% of the rights in any single company. The mechanism is a deemed disposal on the day before departure: latent gains on qualifying shares are crystallised at fair market value and taxed under the standard PFU regime (12.8% IR + 17.2% CSG/CRDS = 30% combined), plus CEHR where relevant.
Greece is in the EU and the EEA, so the deferral is automatic and interest-free with no security required, under the post-2014 De Lasteyrie / N v. Inspecteur CJEU jurisprudence built into article 167 bis. The latent tax stays on the books but is not collected unless and until you actually dispose of the shares. The exit-tax liability extinguishes after 15 years if the qualifying shares are still held — meaning a French founder who departs in 2026 holding her start-up shares through 2041 owes nothing on the original deemed disposal. Real disposals before that point trigger the deferred tax pro rata.
Two procedural traps deserve attention. First, Form 2074-ETD must be filed with the departure return. Skipping it converts the automatic EEA deferral into an immediately payable liability, with late-payment interest and penalties. The form is mandatory even when no tax is currently due, and the annual 2074-ETD-SUIVI follow-up return is required for as long as the deferral remains outstanding — up to 15 years. Second, Article 5A in Greece does not waive Greek capital gains tax on the disposal of qualifying foreign shares for a non-dom — it absorbs them inside the €100K flat. So a founder who sells the start-up the year after relocating to Athens pays €100K in Greece (not 30%+ on the gain) and benefits from the deferred-then-extinguishing French exit tax provided she stays past year 15. This makes the 15-year horizon the dominant planning axis for any France→Greece move involving a substantial shareholding.
Step 3: Establish Greek tax residency
Greek tax residency is governed by article 4 of the Greek Income Tax Code (Law 4172/2013) and tracks the standard OECD test: you are Greek tax resident if (a) you spend more than 183 days in Greece in any 12-month period, or (b) Greece is your centre of vital interests (personal, economic, social ties). Most successful Article 5A applicants spend the full 183+ days on the ground in the first two years to anchor residency unambiguously and to break French residency cleanly.
Article 5A then layers on the flat-tax regime. The eligibility gate is that you must not have been a Greek tax resident for at least 7 of the previous 8 years — almost always automatic for an incoming French citizen — plus a binding commitment to invest at least €500,000 in Greek real estate, Greek companies or Greek securities within three years of acceptance. Pre-existing Greek investments count, including a Golden Visa property purchase. The application is filed with the Greek tax administration (AADE) by 31 March of the year you wish to be taxed under the regime, with a 60-day statutory response window. EU citizens (which French nationals are) register under freedom-of-movement rules — the residence-permit pathway is light-touch and parallel to the tax filing. The full Greek-side breakdown — Article 5A mechanics, Golden Visa thresholds, family add-on, AFM issuance, banking — sits on the Greece country page.
Step 4: Document the break and the new tie
Collect: Greek lease or property deed, AFM (Greek tax number), Greek bank statements, utility bills in your name, Greek health insurance (private or EOPYY enrolment), school enrolment for children, any Article 5A acceptance letter from AADE, and a Greek tax-residence certificate issued under the France-Greece treaty. Renew the Greek certificate annually for the first five years; it becomes the spine of any future contestation file.
The France-Greece Double Tax Convention of 21 August 1963 (in force, modernised by subsequent protocols and by the 2017 Multilateral Instrument) follows an OECD-style structure. Article 4 provides the residency tie-breaker cascade: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement. If France contests your departure, the analysis is run sequentially. A Greek permanent home plus relocated family plus the Greek tax-residence certificate usually settles the matter at the centre-of-vital-interests step. The MLI inserted the principal-purpose test (PPT) into the convention, meaning the move must be a real relocation, not a synthetic structure — Article 5A is widely accepted as a legitimate domestic regime, but a paper-only move is exposed.
Step 5: First-year compliance in both jurisdictions
Your French departure year is filed as a split-year: form 2042 with the résidence au 31 décembre indicated as Greece, dates of fiscal residence split out, and form 2074-ETD attached for the article 167 bis deemed disposition. The Service des Impôts des Particuliers Non-Résidents (SIPNR) at Noisy-le-Grand becomes your administrative point of contact. Continued French-source income (rental from retained French property, French dividends, French employment days) remains taxable under non-resident rules and the treaty’s source-state caps.
In Greece, file the personal income tax return (form E1) electronically through the AADE portal, declaring worldwide income with the Article 5A flat-tax line settling the foreign portion. The €100,000 flat is paid in a single annual instalment by 31 July; missing the deadline ejects you from the regime with no recovery. Family members under the €20K add-on are filed separately under their own E1 returns referencing the principal applicant’s Article 5A acceptance.
Cost & Timeline
| Phase | Cost | Time |
|---|---|---|
| Tax planning + bilingual legal review (pre-move) | €10,000–€25,000 | 1–2 months |
| Article 167 bis valuation + form 2074-ETD | €5,000–€15,000 | 1–3 months |
| Greek residency setup (AFM, banking, Article 5A filing) | €8,000–€20,000 | 1–3 months |
| Qualifying €500K Greek investment (RE, fund, securities) | €500,000+ | 0–3 years |
| Move + setup (lease, utilities, schools, insurance) | €5,000–€15,000 | 1–2 months |
| First-year dual filing (FR departure + GR E1 + Article 5A €100K) | €5,000–€12,000 | Annual |
| Total year-1 advisory cost (excl. €500K investment) | €33,000–€87,000 | 4–8 months |
The €500K investment is a hard requirement of Article 5A but does not have to be liquid spend — Golden Visa property, a Greek-incorporated holding-company capitalisation, or a Greek-listed-securities portfolio all qualify. For a €1M-foreign-income entrepreneur the €100K flat plus advisory cost typically pays back the entire setup within 12 months of Greek tax residency.
Treaty Considerations
The France-Greece convention of 21 August 1963 remains the controlling instrument in 2026, modernised by the MLI which inserted the principal-purpose test and updated the preamble to anti-treaty-shopping language. Article 4 governs the residency tie-breaker and follows the standard OECD cascade. Article 7 allocates business profits to the state of permanent establishment. Article 13 generally assigns capital gains on shares (other than real-estate-rich entities) to the residence state — the textual basis for tax-free disposal of French start-up shares once Greek residency is established and article 167 bis has been satisfied. Article 18 assigns private pensions to the residence state, useful for retirees opting to combine Article 5A on capital income with a separate planning track for pension income.
The interaction with Article 5A is administratively clean: Greece treats the €100K flat as discharging Greek tax on all foreign income, and the treaty’s foreign-tax-credit mechanism (article 21) means the French side cannot re-tax the same income unless the French residency tie-breaker pulls the taxpayer back. This is why executing step 1 (cleanly severing French residency) is more important than any single Greek filing — the treaty is a backstop, not a planning instrument.
Common Mistakes
- Leaving the family in France while you move alone. The article 4 B foyer test keeps you French tax-resident regardless of your physical days, voiding both the exit-tax trigger and the Article 5A benefit through the treaty tie-breaker.
- Skipping form 2074-ETD. Even when the EEA deferral covers the entire liability, the form is mandatory. Skipping it accelerates collection and triggers penalties.
- Missing the 31 March Article 5A filing deadline. The window is calendar-year-bound and unforgiving — miss it and you wait a full year, taxed under standard Greek progressive rates in the interim.
- Failing to fund the €500K Greek investment within three years. Article 5A is revoked retrospectively if the investment commitment is not honoured, with full back-tax under standard Greek rates and penalties.
- Onward move to a non-EEA destination within 15 years. Moving from Greece to the UAE, Monaco, Switzerland or Singapore before article 167 bis extinguishes collapses the French deferral and crystallises the latent tax. Plan a 15-year Greek horizon, or accept the article 167 bis acceleration.
- Missing the 31 July €100K payment. The flat tax must be paid in a single instalment — late payment ejects you from the regime with no statutory recovery, dropping you back onto Greek progressive rates for that year and forward.
FAQ
Will I still have to file in France after moving?
Yes. The departure-year split-year return is filed in the spring of year+1. Continuing French-source income (rental from retained French real estate, French dividends, French employment days) requires non-resident filings via SIPNR Noisy-le-Grand. The article 167 bis deferral is monitored on form 2074-ETD-SUIVI annually for as long as the deferred liability remains outstanding (up to 15 years). Skipping the follow-up return collapses the deferral and accelerates the full liability.
Can I keep my French bank account, company or property?
Yes to all three, with caveats. Banks reclassify the account as non-resident, which changes interest treatment and product eligibility. A retained French SARL or SAS is fine but exposes you to centre of effective management risk if board meetings stay in France — restructure governance and move directorships to Greece or a third country before the personal move. Retained French real estate keeps you within the IFI (Impôt sur la Fortune Immobilière) scope on French real estate above €1.3M, even as a non-resident, and within French CGT on a future sale.
Does the €100,000 flat tax really cover all foreign income?
Yes — including foreign dividends, foreign interest, foreign capital gains, foreign rental income, foreign royalties, partnership profits, trust distributions and foreign employment days. The €100K is a hard cap regardless of amount. Greek-source income (Greek rental, Greek-source employment, Greek dividends from non-treaty-protected Greek companies, Greek non-listed share disposals) sits outside the flat tax and is taxed at standard Greek progressive rates.
What if France disputes my exit?
The dispute typically begins as a contrôle fiscal, escalates to the tribunal administratif, and can ultimately reach the Conseil d’État. Your Greek tax-residence certificate, AFM, lease, utility evidence, school enrolment and family-relocation evidence are the centre of the file. The France-Greece treaty tie-breaker (article 4) gives a structured legal route, and the procédure amiable (mutual agreement procedure) under the treaty is available if domestic remedies fail. Contemporaneous evidence of relocation is decisive — keep travel logs, lease, utility bills, school records and bank statements from day one.
What happens after the 15 years are up?
Article 5A is non-renewable. From year 16 onward you are taxed under standard Greek progressive rates on worldwide income — up to 44% — unless you leave Greek tax residency. Many families plan an exit before year 15 (Cyprus 60-day non-dom is the typical onward move for asset-light profiles, the UAE for those who can move outside the EU). If you have completed seven years of legal Greek residence by then you may also qualify for Greek citizenship by naturalisation and onward-plan with an EU passport in hand.
Greece or Italy — which is better for a French founder?
For most profiles between €500K and €2M of stable foreign income, Greece is now the better deal: €100K versus Italy’s €200K (raised in August 2024), comparable EU residency, lower property prices and a comparable 15-year horizon. Italy retains the edge on banking depth, DTA network and the absence of a mandatory €500K investment. Above €5M of foreign income with very large annual realisations, Italy’s flat €200K still pulls ahead of Greece’s €100K plus the locked €500K investment carrying cost. See France to Italy for the side-by-side.
Next Step
For the full destination-side breakdown — Article 5A mechanics, €500K investment routes, Golden Visa thresholds, family add-on, FIP and digital-nomad alternatives — see Tax-Free Residency in Greece. For the French-side machinery — article 4 B, article 167 bis, EEA deferral and 2074-ETD — see How to Legally Exit a High-Tax Country. To compare against alternatives, see France to Italy, France to Cyprus (0% on foreign dividends for 17 years, 60-day rule) and France to Portugal (IFICI route, EU passport in 5 years).
Book a free consultation — we specialise in France-to-Greece relocations and run article 167 bis modelling, the qualifying €500K investment plan and the Article 5A 31 March filing in parallel.
Last updated: 2026-04-27
Sources:
– Direction générale des Finances publiques (DGFiP) — Article 167 bis CGI and Form 2074-ETD instructions — https://www.impots.gouv.fr
– Greek Independent Authority for Public Revenue (AADE) — Article 5A non-dom regime guidance — https://www.aade.gr/en
– France-Greece Double Tax Convention of 21 August 1963 (consolidated with MLI) — published via BOFiP and the Greek Treaty Series
– PwC Worldwide Tax Summaries — France and Greece individual taxation — https://taxsummaries.pwc.com