Financial Planning for Americans in Greece

Americans living in Greece should normally review their finances across both the US and Greek systems.

That can include:

• US tax filing
• Greek tax residence
• worldwide income
• foreign tax credits
• 401(k)
• IRA
• Roth IRA
• US Social Security
• Greek pension rights
• US brokerage accounts
• local investments
• PFIC exposure
• FBAR
• FATCA
• property
• estate planning
• beneficiaries
• EUR/USD currency exposure
• future residence

The central issue is that Greece may tax you on worldwide income once you become resident, while the United States generally continues taxing US citizens on worldwide income as well.

That makes coordination essential.

1. US tax generally continues after moving to Greece

Moving to Greece does not normally remove a US citizen from the US federal tax system.

US citizens and resident aliens abroad generally remain subject to US taxation and reporting on worldwide income.

That can include:

• Greek salary
• self-employment income
• dividends
• interest
• investment gains
• pension income
• Greek financial accounts
• property income
• business interests

Greece can also tax some or all of the same income.

The financial plan therefore needs to work across both systems.

2. Greece generally uses a 183-day residence test

An individual can become Greek tax resident based on:

• permanent or principal residence
• habitual abode
• centre of vital interests

A person who is present in Greece for more than 183 days cumulatively during a twelve-month period is generally treated as Greek tax resident from the first day of presence, subject to the detailed exceptions.

Residence should therefore be reviewed before substantial financial transactions are made.

3. Greek tax residents are generally taxed on worldwide income

Greek tax residents are generally subject to Greek tax on taxable income arising both:

• in Greece
• outside Greece

That means US-source:

• dividends
• interest
• pensions
• investment gains
• rental income

can all become relevant to the Greek tax return.

Where a double-tax treaty applies, treaty provisions can affect which country taxes the income and how double taxation is relieved.

4. Foreign tax credits can help reduce double taxation

Where foreign-source income is also taxed abroad, Greece can generally provide a foreign tax credit subject to the applicable rules.

The credit cannot generally exceed the Greek tax attributable to that same income.

For Americans, this is particularly important because US worldwide taxation continues after the move.

5. Greece and the US have an income-tax treaty

The United States and Greece have a bilateral income-tax convention dating from 1950.

Although it is significantly older than many modern US treaties, it remains part of the framework for determining how certain categories of income are taxed between the two countries.

6. The age of the treaty makes specialist advice particularly important

Older treaties can differ materially from newer US treaty models.

Do not assume the US-Greece treaty handles:

• pensions
• Social Security
• investment income
• gains
• government pensions

in exactly the same way as treaties with countries such as the UK, Ireland or Germany.

The detailed treaty wording should be checked for significant transactions.

7. Greece offers a special regime for qualifying foreign pensioners

Greece has a specific alternative taxation regime under Article 5B for qualifying people receiving pension income from abroad who transfer their tax residence to Greece.

Qualifying individuals can pay tax at a flat rate of 7% on their foreign-source income under that regime.

8. The 7% regime is broader than pension income alone once elected

A particularly important feature is that the 7% rate applies to the qualifying individual's foreign-source income generally, not simply the foreign pension itself.

Domestic Greek-source income remains subject to the normal rules.

This can make the regime highly relevant for retirees with:

• US pensions
• US investment income
• US rental income
• US brokerage assets

subject to eligibility and detailed classification.

9. You must meet eligibility conditions

The pensioner regime is not available to everyone.

Among the main conditions, the individual must generally:

• receive qualifying pension income arising abroad
• not have been Greek tax resident for five of the six years preceding the move
• transfer residence from a jurisdiction with the required tax-administration cooperation framework

Applications are subject to the official procedure and deadlines.

10. The application deadline matters

The official guidance provides for application generally by 31 March of the relevant tax year.

Someone considering retirement in Greece should therefore investigate eligibility before simply moving and assuming they can elect the regime later.

11. The regime should still be tested against US tax

A 7% Greek tax rate does not mean a US citizen pays only 7% tax overall.

The United States generally continues taxing citizens on worldwide income.

That means you may still need to consider:

• US federal tax
• Greek tax
• foreign tax credits
• treaty relief

A Greek tax advantage should be tested across both countries.

12. 401(k) accounts can usually remain in the US

Moving to Greece does not itself generally require you to close a 401(k).

The bigger issues are:

• provider restrictions
• investment choice
• fees
• retirement withdrawals
• Greek taxation
• RMDs
• beneficiaries

Before rolling over or withdrawing the account, review both systems.

13. IRA and Roth IRA also need cross-border analysis

A traditional IRA may remain in the United States after the move.

A Roth IRA can also generally remain open, subject to provider rules.

But the Greek tax treatment needs to be considered separately.

Do not simply assume that the US label determines the Greek tax outcome.

14. Roth treatment should be checked before relying on tax-free withdrawals

A qualifying Roth IRA distribution may be tax-free under US domestic law.

That does not automatically establish its Greek treatment.

Before retirement, review:

• growth
• distributions
• Roth conversions
• account classification
• treaty interaction

This becomes particularly important for someone modelling a retirement plan around tax-free Roth income.

15. Roth conversions need careful timing

A Roth conversion can create immediate US taxable income.

If you are already Greek resident, the Greek implications should also be checked.

Potential planning factors include:

• whether you qualify for Article 5B
• US marginal tax
• Greek tax
• future pension withdrawals
• RMDs
• future residence

16. Greece and the US have a Social Security totalization agreement

The US-Greece Social Security Agreement entered into force on 1 September 1994.

It helps coordinate the two countries' social insurance systems and can:

• prevent duplicate social-security coverage in certain employment situations
• allow contribution periods to be combined where needed to establish benefit entitlement

This is an important advantage for people whose careers are split between the two countries.

17. Greek coverage can help establish US entitlement

Under totalization rules, someone who does not independently have enough US Social Security credits may potentially use Greek coverage to help establish US benefit entitlement.

For US totalization, the worker generally needs at least six US credits before foreign coverage can be used.

18. US coverage can potentially help with Greek entitlement

The agreement also works in the opposite direction.

US periods can potentially be taken into account for qualifying Greek benefits where the Greek conditions and totalization provisions apply.

The countries still calculate and pay their benefits separately.

19. Social Security should not be viewed in isolation

US Social Security may ultimately sit alongside:

• Greek pension income
• 401(k)
• IRA
• Roth IRA
• investments
• property
• cash

A retirement-income strategy should consider all of these together.

20. Greek capital income has category-specific tax rates

Greek domestic tax rules distinguish between categories of capital income.

Current AADE guidance lists:

• dividends at 5%
• interest at 15%
• royalties at 20%

subject to treaty rules and individual circumstances.

21. Capital gains can also be taxed under Greek rules

Current official guidance states that gains from certain securities can be taxed at 15% under the Greek domestic framework, subject to the detailed conditions and treaty provisions.

For Americans, the same investment may also remain relevant to US capital-gains taxation.

22. Local investment products can create PFIC problems

A Greek or European adviser may recommend:

• UCITS ETFs
• European mutual funds
• Greek funds
• Luxembourg funds
• insurance-based investment products

For an American, many non-US pooled investment companies can potentially be PFICs.

That can create:

• Form 8621
• complex calculations
• potentially punitive tax outcomes
• additional accounting costs

Local suitability does not automatically mean US suitability.

23. US brokerage accounts can remain useful

Many Americans abroad retain US brokerage accounts.

Potential benefits can include:

• access to US-listed investments
• avoiding certain PFIC issues
• retaining established custody
• maintaining dollar assets

But the account still needs to be considered under Greek tax rules once you become resident.

24. Provider restrictions should be checked before moving

A US brokerage or retirement custodian may alter the service it provides after your address changes to Greece.

Restrictions can affect:

• mutual-fund purchases
• managed accounts
• new accounts
• advice
• trading

Confirm provider policy before closing or moving an existing account.

25. FBAR remains relevant

Greek financial accounts can potentially create US FBAR reporting.

These may include:

• bank accounts
• investment accounts
• joint accounts
• certain pension arrangements
• business accounts over which you have authority

FBAR is separate from your US income-tax return.

26. FATCA can create further reporting

Americans abroad may also need to report specified foreign financial assets under Form 8938.

Local Greek institutions can also have FATCA reporting obligations in respect of US account holders.

US reporting should therefore be considered before opening new financial products.

27. Property can become a major part of the plan

Americans living in Greece may:

• buy a primary home
• retain US property
• own holiday property
• receive rental income

Property planning can involve:

• Greek tax
• US tax
• rental income
• capital gains
• currency
• inheritance
• liquidity

The home should not be viewed separately from the wider plan.

28. Estate planning needs local and US coordination

Americans remain potentially exposed to US estate-planning rules while living overseas.

Greek succession and inheritance rules can also be relevant.

The plan may need to coordinate:

• US wills
• Greek wills
• property
• retirement beneficiaries
• trusts
• non-US spouses
• children in different countries

29. Beneficiary nominations still matter

401(k), IRA and Roth IRA accounts generally pass according to their beneficiary designations.

Those nominations should be reviewed after moving.

Check:

• spouse
• children
• citizenship
• residence
• inherited-account rules
• estate planning

30. EUR/USD planning matters

An American in Greece may have:

• retirement accounts in USD
• brokerage assets in USD
• Social Security in USD
• Greek expenditure in EUR
• Greek property in EUR

That creates currency exposure.

A good plan should hold enough euro liquidity for near-term liabilities without automatically converting every long-term dollar asset.

31. Greece may be a retirement destination or a temporary base

Your long-term plan matters.

You may:

• work in Greece for several years
• retire permanently
• later return to the US
• move elsewhere in Europe

Investment, tax and pension planning should preserve flexibility where possible.

32. The best plan coordinates lifetime outcomes

The objective is not simply:

minimise Greek tax this year.

It is to coordinate:

• US tax
• Greek tax
• pensions
• retirement income
• investments
• reporting
• estate planning
• currency
• future residence

That produces a more robust cross-border financial plan.

This page is for general information only and does not constitute personalised financial, tax, legal, pension, retirement, investment, estate-planning or currency advice.

Financial planning for Americans in Greece can involve:

• US federal tax
• Greek tax
• tax residence
• worldwide income
• Article 5B
• foreign pensions
• 401(k)
• IRA
• Roth IRA
• Social Security
• Greek pension rights
• investment taxation
• PFICs
• FBAR
• FATCA
• property
• estate planning
• currency
• future residence

US tax advice should be obtained from a suitably qualified US tax adviser or CPA.

Greek tax and legal advice should be obtained from appropriately qualified Greek professionals.

The 7% Article 5B regime has specific eligibility and application requirements and should not be assumed to apply automatically.

Financial planning should be coordinated with specialist tax advice before implementing substantial pension withdrawals, Roth conversions or investment changes.

Investments can fall as well as rise, and you may get back less than you invest.

Tax rules, treaties, Social Security agreements and provider policies can change.