Buying Greek Property Through a Company: Legal Structure and Tax Benefits

Buying Greek property through a company is a common investment structure for international investors deploying a large portfolio, multi-generational inheritance planning, or long-term tax optimisation. Unlike buying an asset under a personal name, buying through a legal entity separates legal risk and opens up certain tax advantages, but it also brings its own obligations and risks — particularly the 15% Special Real Estate Tax (SRET) applied to non-transparent corporate schemes.

For the Greece Golden Visaprogramme, investors can fully meet the €800,000 Zone A threshold through a legal entity — but must comply with strict rules: hold 100% of the shares, and the entity must be registered in Greece or an EU member state. This article analyses the three main legal structures (AE/SA, IKE, EPE), compares cost and tax between personal and corporate ownership, the benefits of the €100,000/year Non-Dom Regime, and the risks Vietnamese investors need to note.

Legal framework for buying Greek property through a company

Greek law allows both individuals and legal entities (Greek and foreign) to own property in Greece. According to the Greek Ministry of Migration and Asylum and market data from the Bank of Greece, buying Greek property through a company is a fully recognised option for personal investment, commercial business, and Golden Visa purposes — as long as the legal conditions are met.

For the Golden Visa, the rules for buying through a legal entity are stricter than buying personally. First, the Golden Visa applicant must hold 100% of the entity’s shares — co-ownership with a third party, even a spouse, is not permitted. Where a married couple co-own 50/50, this structure does not qualify, and the investor must switch to buying personally (in one person’s name or as personal co-owners).

Second, the entity must have its registered office in Greece or an EU/EEA member state. Entities in third countries (such as the BVI, Cayman, Panama) do not qualify — this is an anti-money-laundering and anti-avoidance rule. Third, the value of the property, or the combined value of multiple properties (within the same Zone threshold), must reach the Golden Visa mark (€800,000 for Zone A, €400,000 for Zone B, €250,000 for Zone C conversion).

This rule creates two main options. The first is to set up a new Greek entity (AE, IKE, or EPE) held 100% by the individual investor. The second is to use the investor’s existing EU entity (for example, a holding company in the Netherlands, Luxembourg, Cyprus, Malta, or Ireland) to buy the Greek property. Both options are valid; the choice depends on the investor’s overall tax structure and objectives.

Common types of Greek legal entities: AE, IKE, EPE

Greek law recognises three main limited-liability entity types commonly used to buy property: AE (Anonymi Eteria), IKE (Idiotiki Kefaleouchiki Eteria), and EPE (Eteria Periorismenis Efthinis). All three have their own legal personality, with shareholders liable only up to their capital contribution.

AE (Société Anonyme — Anonymi Eteria) is equivalent to a joint-stock company, suited to large investments and complex multi-shareholder structures. The minimum share capital is €25,000, at least one director is required, and audit is mandatory above a certain financial threshold. AE is the only structure eligible for the EU Interest and Royalties Directive — suitable when an investor expects income from an EU subsidiary. AE can also issue bond loans exempt from stamp duty — convenient for complex financing structures.

IKE (Private Company — Idiotiki Kefaleouchiki Eteria) is the most flexible structure, introduced in 2012 and quickly becoming the most popular choice for small and medium businesses and property investment. IKE requires no minimum share capital (even €1 is acceptable), has a simple governance structure, and does not require an audit below the threshold. IKE suits individual or family investors buying one or a few properties who have no need to issue bonds or set up a complex EU subsidiary.

EPE (Limited Liability Company — Eteria Periorismenis Efthinis) is a traditional form sitting between AE and IKE, with a minimum share capital of €4,500. However, EPE is gradually being replaced by IKE due to more cumbersome procedures and less flexibility. It is rarely chosen for new property investment.

Comparing setup costs: IKE has the lowest setup cost at €600-€1,500, taking 1-2 weeks. EPE falls in the €1,000-€2,000 range, taking 2-3 weeks. AE is the most expensive at €2,500-€5,000, taking 3-4 weeks due to more complex procedures. Annual accounting and audit fees also differ: IKE €1,500-€3,000/year, EPE €2,000-€4,000, AE €5,000-€15,000/year depending on scale.

For most individual Vietnamese investors buying a single €800,000 Golden Visa property, IKE is the most balanced choice between low cost, governance flexibility, and full compliance with legal requirements. AE suits investors building a portfolio of multiple properties, or combining property investment with other business activity in Greece.

Buying Greek property through a company: personal vs corporate tax comparison

The tax structure for investing through a legal entity differs significantly from buying personally — and the final choice depends heavily on the intended economic use of the asset and the size of the portfolio.

Transfer tax applies equally: 3.09% for both individuals and legal entities when buying an existing property. Newly built property is exempt from 24% VAT under the Greek government’s extension through 31 December 2026 — applying to both. This is a point where there is no difference in transaction tax.

Rental income tax shows the clearest difference. Individuals pay progressive tax from 15% (€0-€12,000), 35% (€12,001-€35,000), up to 45% (>€35,000). Legal entities pay a flat 22% corporate income tax under the new rules of the Greek Tax Authority (AADE) — regardless of income level. For a Golden Visa apartment let for €24,000/year, an individual pays around €5,700 in tax, while a legal entity pays €5,280 — roughly equivalent. However, for a rental portfolio of €60,000/year, an individual pays €19,500 while a legal entity pays only €13,200 — a difference of €6,300/year.

Annual ENFIA also differs. Individuals pay only the main tax (€2-€16.25/m² depending on zone value and building age) plus an additional tax of 0.15-1.15% if the total property value exceeds €250,000. Legal entities pay the same main tax plus a 0.55% supplementary tax on total property value (reduced to 0.1% if the asset is used for the entity’s own business activity). For an €800,000 property, the corporate supplementary tax adds €4,400/year — a significant cost if there is no rental cash flow to offset it.

Capital gains tax carries a key difference. Capital gains from an individual’s property sale are exempt through 31 December 2026. Legal entities do not get this exemption — capital gains are counted as income subject to 22% corporate tax. This is a significant disadvantage if the investor intends to exit within the next 5 years.

However, for long-term exits (after 2026), a legal entity has an advantage: a foreign investor selling shares in a Greek company holding property is not subject to capital gains tax in Greece if they have no permanent establishment there. The share-deal versus asset-deal structure opens up a tax-optimal exit option for long-term investors.

The 15% Special Real Estate Tax (SRET) — the biggest risk to know

The Special Real Estate Tax (SRET) is Greece’s distinctive anti-avoidance rule, imposing a 15% annual tax on the statutory value of a property if the owning entity is not sufficiently transparent about its beneficial owner. This is the most important risk of investing through a legal entity.

SRET was introduced to counter non-transparent structures — for example, a BVI entity holding Greek property without disclosing its real owner. At 15%/year on the asset value, SRET can completely wipe out investment returns — a €1 million property would incur €150,000 of SRET per year.

Fortunately, several SRET exemptions are available. The most common are: the business income exemption (the entity has genuine business activity, not just passive asset-holding); the disclosure exemption (the entity fully discloses the ownership chain down to the natural-person beneficial owner); the listed entity exemption (the entity is listed on an EU stock exchange); and the regulated entity exemption (REIC, mutual fund, pension fund under regulatory supervision).

For individual Vietnamese investors setting up a corporate structure, the disclosure exemption is the most common route. A Greek entity (IKE, AE, EPE) held 100% by an identifiable natural person fully meets this exemption. An EU entity registered in a country with genuine economic substance (Netherlands, Luxembourg) also usually qualifies if structured correctly.

A special note: both shareholders and the buyer are jointly liable with the seller for any prior SRET obligations. An investor buying shares in a Greek company holding property must thoroughly due-diligence the entity’s SRET history — otherwise they may be retroactively liable for SRET unpaid in prior years. This is why a share deal requires much deeper legal due diligence than an asset deal.

The €100,000 Non-Dom Regime — the greatest long-term tax benefit

Greece’s Non-Domiciled Tax Regime is one of the most attractive preferential tax programmes in the EU for HNWIs — and a strong incentive for investors to consider a corporate structure combined with moving tax residence to Greece.

The Non-Dom mechanism is simple. An eligible individual becomes a Greek tax resident but chooses to pay a flat €100,000/year instead of declaring progressive tax on worldwide income (up to 45%). All foreign-sourced income — dividends, interest, capital gains from foreign securities, foreign business income — is treated as fully taxed through this €100,000 payment. Greek-sourced income remains subject to normal Greek tax.

Non-Dom eligibility requires: not having been a Greek tax resident in 7 of the last 8 years; and investing at least €500,000 in Greek real estate, business, or securities within 3 years of registering for the regime. An €800,000 Zone A Golden Visa property more than covers the required investment threshold — a natural synergy between Golden Visa and Non-Dom.

Family extension: an additional €20,000/person/year for a spouse, children under 18, dependent children under 25, and financially dependent parents. A family of four (investor + spouse + 2 children) pays total Non-Dom tax of €100,000 + €20,000×3 = €160,000/year for the entire family’s worldwide income. The regime applies for a maximum of 15 years.

For Vietnamese HNWIs with worldwide income of €1-€5 million/year, Non-Dom delivers significant tax savings. For example, with worldwide income of €2 million/year: the maximum progressive tax at 45% would be €900,000. The flat Non-Dom rate of €100,000 saves €800,000/year. Over 15 years, cumulative savings reach €12 million — far exceeding the value of the original property investment.

Combining a Greek property purchase through a company with the Non-Dom Regime creates an overall tax-optimal structure. A Greek IKE holds the property and pays 22% corporate tax on rental income. The individual, as sole shareholder, applies the flat €100,000/year Non-Dom rate to worldwide income. This structure is particularly suited to investors with high worldwide income who intend to actually reside in Greece for 183+ days/year to maintain tax residence.

Process for setting up an entity and buying property through it

Setting up a corporate investment structure takes around 4-8 weeks longer than buying personally, and involves four main stages.

Stage 1 is entity formation (3-4 weeks for an IKE). First, the representing lawyer registers the new IKE/AE/EPE with the General Commercial Registry Greece (GEMI). The entity must obtain an AFM (Greek Tax ID), open a business bank account at a Greek bank, and register with the AADE tax authority. Share capital must be fully paid into the company account before buying the property.

Stage 2 is preparing the purchase transaction (2-3 weeks). The entity signs a Memorandum of Understanding with the seller and pays a 10% deposit of the transaction value. The representing lawyer carries out legal due diligence: checking the title deed, encumbrances, planning permit, the property’s SRET status, and the seller’s tax history. For newly built property, completion certification and planning-compliance certificates must also be checked.

Stage 3 is signing the official sale and purchase agreement before a notary (1-2 weeks). The contract is signed by the entity’s legal representative (the IKE/AE director) or via a Power of Attorney if the representative is not present. The remaining 90% is paid by bank transfer. The notary certifies the deed and charges a fee of 0.8-1.2%. After notarisation, the contract must be registered with the Land Registry/Cadastre within 30 days — a fee of 0.475-0.575%.

Stage 4 is tax compliance and the Golden Visa (4-6 weeks). The entity files an E9 form registering the property with the AADE to calculate annual ENFIA. If applying for the Golden Visa, the application must include: the original entity shareholding structure proving 100% investor ownership, the entity’s articles of association, a business activity certificate, and the sale contract already registered with the Land Registry. The whole process from entity formation to receiving the Golden Visa card usually takes 8-12 months.

A note on legalising Vietnamese documents: before 11 September 2026, legal documents from Vietnam had to go through a three-step consular legalisation process (notarisation → Vietnamese Ministry of Foreign Affairs → Greek Embassy). After this date, the Apostille Convention officially takes effect in Vietnam, significantly simplifying procedures for both entity formation and property registration.

When to buy through a company and when not to

The decision to buy through a legal entity or personally depends on three main factors: portfolio size, residency goals, and global tax planning.

Buying through a company should be considered when: the investor has a portfolio of multiple properties (3+ assets) in Greece, making use of the flat 22% corporate tax versus the 45% progressive rate; the investor plans to actually reside there and apply the Non-Dom Regime, combining a Greek IKE holding the asset with the flat €100,000 personal tax; the investor has complex multi-generational inheritance plans and prefers transferring shares rather than assets (reducing legal complexity); or the investor intends to combine property investment with business activity in Greece.

Buying personally is better when: the investor is buying a single Golden Visa property, has no significant rental cash flow, and wants to make use of the capital gains exemption through 2026; a simple structure with no need to conceal the beneficial owner; a limited budget that does not want the added cost of setting up and running an entity (€5,000-€20,000/year depending on type); or wants the flexibility of co-ownership between spouses (buying through an entity requires 100% ownership by one person).

For most individual Vietnamese investors buying a single €800,000 Zone A Golden Visa apartment, buying personally is the simpler and more cost-effective option — unless they plan to apply the Non-Dom Regime or build a portfolio of multiple properties. In those cases, IKE is the optimal structure between cost, flexibility, and legal compliance.

Before deciding, investors should consult a tax lawyer specialising in cross-border structuring to assess the overall tax impact in both Vietnam and Greece. Comparing this with specific segments such as the central Plaka, Kolonaki, and Syntagma segments, Athens Riviera Glyfada, Voula, Vouliagmeni or Thessaloniki will help identify the type of asset that suits a corporate structure.

Summary

Buying Greek property through a company is a powerful investment structure for investors with a multi-asset portfolio or combining it with the €100,000/year Non-Dom Regime. The three main Greek entity options are IKE (flexible, low cost, most popular), AE (larger structure, multi-shareholder, complex investment), and EPE (traditional, rarely used today). For most individual investors, IKE is the optimally balanced structure.

The main tax benefits include the flat 22% corporate income tax (versus the 45% progressive rate for individuals with a large portfolio) and the ability to use a share deal on exit — allowing a foreign investor to sell shares without incurring capital gains tax in Greece. However, the biggest risk is the 15%/year Special Real Estate Tax (SRET) applied to non-transparent structures — it is essential to secure the disclosure exemption through an ownership chain traceable directly to the natural-person beneficial owner.

The decision to buy through a company or personally depends on portfolio size, Non-Dom plans, and global tax planning. Consulting a tax lawyer specialising in cross-border structuring is essential before deciding. Detailed information on taxes in Greece and the Greek economy will add a macro perspective to the corporate investment structure.