Italy's €300,000 Flat Tax vs Greece's €100,000: Which Non-Dom Regime Fits in 2026?

What is the Italian non-dom flat tax?

The Italian non-dom flat tax is Article 24-bis of the Income Tax Code, under which a new Italian tax resident pays one fixed annual amount on all foreign-source income instead of ordinary progressive tax on it. From 1 January 2026 that amount is €300,000 a year, set by Law 199/2025 and published in the Official Gazette on 30 December 2025.

The regime was introduced in 2017 at €100,000. It is elective, it runs for a maximum of fifteen years, and it can be revoked. The size of the income is irrelevant to the price: the same €300,000 discharges foreign income of €2 million or €200 million.

What is the Greek non-dom flat tax?

The Greek non-dom flat tax is Article 5A of Law 4172/2013, under which an individual transferring tax residence to Greece pays €100,000 a year on all foreign-source income, conditional on investing at least €500,000 in Greece within three years of applying. It has applied since tax year 2020 and the figures have never changed.

The investment may go into Greek real estate, businesses, transferable securities or shares in Greek entities. It is waived entirely for holders of a residence permit for investment activity, which is the Greek golden visa. That waiver is the single point at which the tax regime and the residence programme touch.

Is Greece's €100,000 flat tax new in 2026?

No. The €100,000 figure has been in force since tax year 2020, introduced by Law 4646/2019. The amount, the €20,000 family charge, the €500,000 investment requirement and the fifteen-year cap are all unchanged. Any description of it as a 2026 innovation is mistaken.

What did change is procedural. Law 5222/2025 removed the old 31 March application deadline, along with the rule requiring payment within thirty days in the first year. A decision of the Greek tax authority in July 2026 then set a fresh timetable with digital filing through the myAADE portal. The filing dates under that decision should be confirmed directly with the Greek tax authority before you rely on them, because the timetable was reset recently and published guidance is still catching up.

Who is eligible for each regime?

Italy requires that you were not an Italian tax resident for at least nine of the previous ten tax periods, and Greece requires non-residence for seven of the previous eight years. Both tests look backwards at tax residence rather than nationality, and neither regime imposes any nationality restriction.

The decisive difference is the condition attached rather than the lookback. Greece conditions the regime on the €500,000 investment unless the golden-visa waiver applies. Italy attaches no investment condition of any kind: you pay the substitute tax, and that is the whole arrangement.

Both regimes also require that tax residence genuinely moves. Electing a flat tax while continuing to live, work and keep a family home elsewhere invites a challenge from the country you left, and that challenge is decided on facts rather than on the election you filed.

How much does each regime cost over fifteen years?

Across a full fifteen-year term a single applicant pays €4.5 million in Italy and €1.5 million in Greece, and the Greek applicant additionally commits €500,000 to Greek assets. Ignoring inflation and professional fees, that is a difference of €3 million in tax across the term.

The Greek investment is not a fee. It buys an asset you continue to own, which may appreciate or produce income, and which you may eventually sell. Readers weighing that commitment may find our guide to buying property in Europe useful, and our analysis of Athens real estate covers the market most Greek applicants examine first.

A flat tax is worth paying only when ordinary tax on the same income would exceed it. Italian top-rate tax reaches 43% before regional and municipal surtaxes, and Greek rates reach 44%. On that arithmetic the Italian price needs foreign income in the millions each year before it makes sense, while the Greek price clears the same hurdle at a substantially smaller figure.

What does each flat tax leave out?

Both flat taxes discharge foreign-source income only. Domestic income is taxed under ordinary rules in both countries, so Italian rental income is taxed in Italy and Greek dividends are taxed in Greece, at the full progressive rates.

Italy additionally excludes capital gains on qualified shareholdings disposed of within the first five years, which remain taxable in the ordinary way. Greece gives no credit for foreign tax already paid abroad against the flat €100,000.

On estates, both offer something valuable. Italy limits inheritance and gift tax to Italian assets while the regime applies. Greece exempts foreign movable property from Greek inheritance and gift tax for the duration of the regime.

Weighing the two regimes against your own income profile? Book a complimentary consultation and we will model both against your actual figures and family size.

How do you apply, and how long does it take?

In Italy the election is made in the tax return for the year in which residence is transferred, and an advance ruling from the Revenue Agency is available but optional. That optional ruling is frequently misreported as a requirement, which it is not.

In Greece the application is filed with the tax authority for the year in which inclusion is sought, supporting documents follow, and the tax is paid before the year closes. The Governor of the authority decides. The €500,000 investment must then be completed within three years and evidenced.

In practice neither timetable is the real constraint. The work that determines success happens beforehand: establishing where your tax residence currently sits, unwinding it cleanly, documenting the source of the funds that will move, and confirming how your current country treats departure. Our guide to establishing tax residency sets out that groundwork in detail.

Are there lower-cost Greek alternatives to the €100,000 regime?

Yes, for two specific profiles. Greece runs two further regimes that are often confused with the €100,000 one, and neither requires a €500,000 investment. They are narrower in scope, and for the people who qualify they are far less costly.

Article 5B taxes the foreign income of relocating pensioners at a flat 7%, for up to fifteen years, provided the applicant was not Greek tax resident for five of the six preceding years and comes from a country with a tax-cooperation agreement with Greece. For a retiree with a €200,000 pension that is €14,000 a year rather than €100,000.

Article 5C exempts 50% of Greek employment or self-employment income from tax for seven years, for individuals relocating to take up a new post in Greece. It applies to Greek-source earnings, which is precisely what the €100,000 regime does not cover, so the two solve different problems.

Neither should be presented as a substitute for Article 5A. A pensioner with large foreign investment income, rather than pension income, is outside 5B and back to the €100,000 question.

What happens when the regime ends?

Both regimes stop after fifteen years and cannot be renewed. From that point the individual is taxed as an ordinary resident of the country, on worldwide income, at full progressive rates, unless they have moved tax residence again in the meantime.

That end date deserves planning from the start rather than in year fourteen. Fifteen years is long enough for children to be schooled and settled, for property to be acquired, and for the ordinary-residence tax position to become materially more expensive than the flat tax ever was. Both regimes can also be revoked earlier, and Italian optants who leave lose the benefit for the remaining years.

Not sure which side of this comparison you fall on? Speak to Mirabello Consultancy before you move tax residence, because the exit position is usually harder than the arrival.

Which regime is stronger, and where is each weak?

Italy is stronger where foreign income is very large, where no investment commitment is wanted, and where the household is small. Its professional infrastructure is deep and its ruling practice well established after nine years of operation.

Italy is weaker on price stability. Two increases inside two years, both arriving in budget legislation with little notice, is the material risk: what the state set, the state may reset. Existing optants were protected on both occasions, which is reassuring once you are inside the regime and no comfort at all to someone deciding today.

Greece is stronger on headline cost, on the family charge, and for anyone who wanted Greek property or business exposure regardless, since in that case the €500,000 is not a cost of the regime at all. Holders of the Greek investment permit avoid the condition entirely.

Greece is weaker where there is no appetite for Greek assets, because the €500,000 must genuinely be deployed and held for the term. Its administrative framework has also just been rewritten, so current practice is newer and less tested than Italy's.

Which regime should you choose?

Choose Greece if you are willing to invest €500,000 in the country, and Italy if you are not and your foreign income is large enough that €300,000 remains the lower-cost outcome. For families the arithmetic tilts further towards Greece, because four dependants cost €80,000 a year there against €200,000 in Italy.

Neither decision should rest on price alone. The interaction with your current country's exit rules and treaty network usually matters more than the headline figure, and a regime that saves tax while creating a residence dispute is a poor outcome. Investors comparing the residence side as well may want to weigh Portugal, Malta and Cyprus, and our golden visa comparison sets those out with verified figures.

Both regimes are documented by the authorities that administer them. Italy's is described by the Agenzia delle Entrate, and Greece's incentives by the Independent Authority for Public Revenue. Read them, or have them read for you, before committing to either.