Greece's non-dom regime charges a flat annual fee on worldwide income regardless of amount — making Greece the winning option for HNW individuals with over EUR 700K annual income, while Spain Beckham remains unbeatable for mid-to-high salary executives

The Greek bet: when a flat fee crushes a percentage rate

The Greek non-dom regime represents a radically different taxation philosophy from Spain’s Beckham Law or Malta’s GRP: rather than exempting income or applying a low percentage rate to a base, Greece charges a flat annual fee on all foreign-source income, regardless of the amount. A taxpayer with EUR 300,000 in foreign income pays the same as one with EUR 30,000,000 in foreign income: EUR 100,000.

This structure creates a very clear mathematical crossover point: below a certain income level, other regimes are more efficient; above it, the Greek non-dom can offer single-digit effective rates on large fortunes. Understanding exactly where that crossover sits, and whether the taxpayer’s profile exceeds it, is the key to this analysis.

Spain: Beckham Law in 2026

The 6-year, 24% mechanism

The Beckham Law — Article 93 LIRPF — offers a flat 24% rate on Spanish-source employment income for 6 years. Foreign-source income (dividends, interest, capital gains, rental income from outside Spain) does not tax in Spain during the period.

For an executive or entrepreneur with Spanish-source activity, this translates to single or low-double-digit effective rates on total income, depending on the composition between Spanish and foreign income:

The total effective rate decreases as exempt foreign income increases. Above EUR 3M in annual foreign income, Beckham becomes one of the most efficient regimes available.

The Mbappé + Madrid effect

The combination of Beckham + 0% wealth tax in Madrid + 0% inheritance tax in Madrid creates the most favourable aggregate fiscal environment of any major European city for the 6-year regime window. No other first-tier European capital — Amsterdam, Dublin, Paris, Berlin — offers a comparable combination.

Greece: the HNW non-dom regime (Article 5A CITA)

Background and legal basis

Greece introduced its high-net-worth non-domicile regime in 2019 (Law 4646/2019, Article 5A of the Income Tax Code, CITA), effective from fiscal year 2020. The declared objective was to attract HNW individuals and international investors who had previously preferred Malta, Cyprus, or Portugal.

How the flat fee works

The Article 5A CITA regime works as follows:

1. The taxpayer must have been a tax resident outside Greece for at least 7 of the last 8 years before the transfer.
2. A flat fee of EUR 100,000 per year applies to all foreign-source income (dividends, interest, capital gains, international rents, foreign-source employment income, foreign pensions — everything).
3. Greek-source income (employment in Greece, Greek real estate income, dividends from Greek companies) taxes at the ordinary progressive Greek rate.
4. Each family member who also wishes to join the regime pays EUR 20,000 additional per person (confirm current amounts with AADE before advising).
5. Regime duration: up to 15 years according to the original Art. 5A CITA drafting (confirm current maximum duration and extension/termination conditions with AADE before advising).

Additionally, the taxpayer must invest in Greece a minimum amount within the first 3 years (in real estate, businesses, Greek securities, or other productive assets) — confirm the minimum investment amount with AADE before advising.

Greek Investor Visa: 2024 update

Greece’s Golden Visa — a residency permit for non-EU individuals investing in Greece — was reformed in 2024, establishing differentiated thresholds by zone:

The amounts above are indicative based on the announced 2024 reform; confirm exact thresholds and territorial classification with Enterprise Greece / Greek Ministry of Migration and Asylum before advising.

The Golden Visa provides a residence permit but does not automatically trigger the non-dom regime: they are two distinct instruments with separate conditions. An EU citizen can access the non-dom regime without needing a Golden Visa.

Comparison table: Spain Beckham vs Greece non-dom + Investor Visa

Worked example: founder with EUR 3M exit + EUR 500K salary

Profile: startup founder with planned exit in year 3 + high salary

Data:

• Business exit (sale of shares in foreign company): EUR 3,000,000 in capital gains (foreign-source)
• Annual salary from Spanish company: EUR 500,000
• Total assets: EUR 5,000,000 (EUR 2M in Spain, EUR 3M abroad)

Under Beckham Law (Spain, Madrid):

Total effective rate (exit year): 3.4% on EUR 3,500,000 total income

Under Greek non-dom (Article 5A CITA):

Total effective rate (exit year): 2.9% on EUR 3,500,000 total income

In this example, Greece’s advantage is EUR 20,000 (EUR 100K vs EUR 120K). Modest at this level. The difference amplifies dramatically as the exit grows:

Note: under Beckham, foreign-source capital gains are exempt during the regime regardless of size, so the exit scale does not affect the Beckham tax. Greece remains slightly more efficient when the Spanish salary exceeds EUR 420,000 (the breakeven point), but not dramatically so.

Where Greece non-dom clearly outperforms Spain Beckham

1. For total income above approximately EUR 700K–1M with foreign mix

For an HNW individual with EUR 2M total income (mix of dividends, foreign salary, interest), the Greek non-dom pays EUR 100,000 flat. Under Spain Beckham, if EUR 600,000 of that income is Spanish-source, the tax would be EUR 144,000. Above EUR 600K in Spanish income, the Greek advantage grows rapidly because Beckham applies 47% to the excess while Greece maintains the flat fee.

2. Very large foreign-source exit years

A founder selling a company for EUR 20M with EUR 100K in Greek salary: total Greek tax = EUR 100K (non-dom on foreign) + ordinary rate on EUR 100K Greek income ≈ EUR 100K + EUR 40K = EUR 140K. For very large foreign-source exits, both regimes are highly efficient, but the Greek flat fee can be slightly lower in some scenarios.

3. No 6-year limit: up to 15 years of flat fee

For HNW individuals planning to stay 10-15 years, Greece offers a window almost three times longer than Beckham. After 6 years in Spain, the taxpayer moves to ordinary IRPF (up to 47%), while in Greece the flat fee continues for up to 15 years.

4. Efficient family extension

The Greek regime allows adding family members for only EUR 20,000 per additional person. For a family of 4 (holder + 3 family members), the total fee would be EUR 100K + 3 × EUR 20K = EUR 160K, covering all foreign income for the entire family. The Beckham family extension exists but is more limited in application conditions.

Where Spain Beckham outperforms Greece non-dom

1. For executives with Spanish salary up to approximately EUR 420K

The mathematical threshold where Greece’s EUR 100K flat fee equals Beckham’s 24% on Spanish income is when Spanish salary is EUR 417,000 (EUR 100K / 0.24). For Spanish salaries below this threshold, Beckham is less expensive. The vast majority of clients consulting the Beckham regime have salary levels in the EUR 100K–400K range, where Beckham is significantly more efficient.

2. No minimum commitment: only pay on what you earn

The risk of the Greek non-dom is that it is a EUR 100,000 annual commitment regardless of actual income. If in a restructuring year foreign income is low, you still pay EUR 100K. Under Beckham, in a year with minimal Spanish income, the tax can be minimal.

3. Larger economy and strategic hub

Spain is the EU’s seventh-largest economy, with a labour market, business ecosystem, and infrastructure network that Greece currently cannot match. For entrepreneurs and professionals needing presence at the heart of the European and Latin American markets, Madrid has an unreachable position.

4. The Mbappé stacking: no Greek equivalent

The combination of Beckham + 0% wealth tax Madrid + 0% inheritance tax Madrid has no Greek equivalent. Greece has reduced inheritance rates and no wealth tax, but does not reach the 0% effective rate on intergenerational transfers that Madrid offers. For large estates with active succession planning, Madrid can be superior even post-Beckham.

5. More mature and predictable regime

The Greek non-dom was introduced in 2020 and has less than 6 years of case law and administrative practice. Spain’s Beckham has been in force since 2004 with hundreds of DGT rulings, economic-administrative court decisions, and consolidated tax doctrine. The predictability for advisor and taxpayer is substantially greater under Beckham.

Which regime suits which profile?

Choose Spain Beckham if:

• You have Spanish-source salary up to approximately EUR 420,000 per year
• You want to live in a major European economy with world-class infrastructure
• Your horizon is 3–6 years with a planned exit thereafter
• You value predictable legal environment and Spain’s broad CDI network
• You have active succession planning (Madrid 0% inheritance tax)

Choose Greece non-dom if:

• Your foreign-source income is very high (over EUR 700K per year) and will dominate your total income
• You have a 7–15 year planning horizon and want a stable flat annual fee
• You can meet the requirement to invest in Greek assets
• Your family also wants to benefit and the EUR 20K/person extension is attractive
• You have a large foreign-source business exit planned and want to cap the tax in that year at EUR 100K

Conclusion: the crossover point is determined by income level

The Greece vs Spain comparison is essentially a comparison between a percentage rate (24% on Spanish income under Beckham) and a flat fee (EUR 100K on foreign income under Greek non-dom). Mathematically:

• Below EUR 420K in Spanish income: Spain Beckham wins
• Between EUR 420K and EUR 700K in Spanish income with foreign income exemption: similar, depends on the mix
• Above EUR 700K in Spanish income: Greece non-dom potentially wins
• For foreign income of any amount with EUR 0 Spanish income: tie (both exempt, but Greece still requires paying the EUR 100K)

The correct analysis for each HNW client combines future income projection, time horizon, active/passive income mix, succession planning, and European citizenship objectives. BMC recommends 10-year numerical modelling before choosing between these two structures.

For a personalised analysis, see our Beckham Law Guide 2026 or speak with our international tax team.

Related: Spain Beckham vs Portugal NHR-extinta and IFICI · Spain Beckham vs Cyprus Non-Dom 2026 · Spain Beckham vs Malta GRP 2026