Security Alert
On 24 June 2025, the Ministry of Finance introduced a new Draft Bill proposing significant amendments to Article 71H of the Greek Income Tax Code (ITC). These amendments aim to build on Greece’s existing family office framework by increasing legal clarity, flexibility, and overall attractiveness for both Greek and international high-net-worth individuals. Although still subject to public consultation until 8 July 2025, the revised Article 71H ITC aspires to open doors for broader participation and boost Greece’s profile as a centre for global wealth management.
By way of introduction, the Greek family office regime entered into force in 2021 and became effective as from 1.1.2021. The regime stipulates the incorporation under Greek law of special purpose legal entities (“family offices”), the statutory objective of which will be exclusively the management and administration of the assets and investments of individuals and their family members. Those special purpose legal entities should comply with certain legal requirements with regard to personnel and required annual expenditure, while their gross profits shall be computed on the basis of a 7% profit margin imposed on their annual expenses.
Key Highlights of the Proposed Bill
Extension to foreign tax resident individuals
Under the former regime, Greek Family Offices were limited to serving only Greek tax resident individuals and family members. The updated rules remove this limitation, allowing non-Greek tax residents to benefit from establishing Greek Family Offices. This represents a proactive step forward, acknowledging the increased mobility of many wealthy families’ members.
Expansion of qualifying services to cover advisory services to trustees
Beyond mere management and administration of family wealth, Greek Family Offices will now be authorised to provide advisory services to trustees of trusts settled by, or for the benefit of, those individuals (and their families) whose wealth is managed under this regime. This expansion recognises the global nature of modern family wealth structures.
Reduction of annual expenditure requirement
One of the most notable changes is the drop in the minimum annual expenditure from EUR 1 million to EUR 250,000. High start-up and operating costs had previously raised concerns about the regime’s accessibility. Lowering the threshold encourages a broader range of families to consider setting up a Greek Family Office.
Widening the definition of “family members”
Where the former framework only recognised two straight line generations, the new Bill expands coverage to include married children, grandchildren, siblings, and spouses. Such an amendment should ensure continuity of wealth management across multiple branches of a family, in line with international practice.
Shielding from place of effective management rules
A key development is the explicit confirmation that Greek Family Offices providing services to foreign legal entities owned by covered individuals or their family members will fall outside the scope of the Greek place of effective management (PoEM) rules. This addresses longstanding concerns of inadvertently triggering Greek tax residency for foreign asset-holding entities.
Looking Ahead
If passed, the current proposals for amending Article 71H ITC will likely make Greek Family Offices more adaptable and appealing to a global audience. With the PoEM issue addressed, a workable annual expenditure threshold, and an extended generational coverage, added to the special VAT exemptions for services rendered to individuals (and the entities owned by them), these revisions significantly enhance Greece’s competitiveness in the international single family office market.
Interested stakeholders should keep a close watch on the public consultation phase, set to conclude on 8 July 2025. We anticipate that if the measures become law, the Greek Family Office will offer a more agile and globally relevant vehicle for family wealth governance in a post-2025 landscape.