Portugal vs Greece Tax for Expats 2026 - NHR/IFICI vs Greek Special Regimes

Greece is the underrated player in the Mediterranean expat-tax conversation. While most people focus on Portugal vs Spain or Portugal vs Italy, Greece quietly built three distinct expat regimes between 2019 and 2021 - and one of them (the €100k HNWI flat tax) is genuinely the most aggressive on offer in the EU for ultra-high net worth individuals.

This guide compares Portugal and Greece for 2026, with full coverage of all three Greek special regimes and worked totals at typical income levels.

The headline numbers

Personal income tax brackets (2026):

Tax point	Portugal (IRS)	Greece (IRPF)
Lowest bracket	12.5% (up to €8,342)	9% (up to €10,000)
Bracket at €30k	34.9% (marginal)	28% (marginal, €20k-€30k slice)
Bracket at €60k	44.6% (marginal)	44% (marginal, above €40k)
Top bracket	48% (above €86,634)	44% (above €40,000)
Solidarity / extra	+2.5% above €80k, +5% above €250k	None (solidarity contribution suspended 2023+)

Greece’s brackets:

• 9% up to €10,000
• 22% from €10,001 to €20,000
• 28% from €20,001 to €30,000
• 36% from €30,001 to €40,000
• 44% above €40,000

The shape: Greece is friendlier than Portugal at low/middle incomes (9% from zero vs Portugal’s 12.5% from zero, faster ramp through middle brackets) but caps at 44% - meaningfully lower than Portugal’s 48% top + 5% solidarity.

Who’s lower at each income level?

€30,000 single employee:

• Portugal: IRS €3,810 + SS €3,300 = €7,110 (23.7%)
• Greece: IRPF ~€5,200 + EFKA SS ~€4,140 = €9,340 (31.1%)

Greece’s lower IRPF is offset by higher Greek employee SS (~13.8% vs Portuguese 11%). At €30k, Portugal is cheaper.

€60,000 single employee:

• Portugal: IRS €11,140 + SS €6,600 = €17,740 (29.6%)
• Greece: IRPF ~€16,200 + EFKA ~€8,280 = €24,480 (40.8%)

Portugal saves ~€7,000/year at this income level for employees, primarily because Greek SS is materially higher and the brackets compound similarly.

€100,000 single employee:

• Portugal: IRS €30,945 + SS €11,000 = €41,945 (41.9%)
• Greece: IRPF ~€34,650 + EFKA ~€13,800 = €48,450 (48.5%)

€100k single employee, standard regime

~€6,500 / year

At all three income levels in standard regime, Portugal is cheaper for employees. This flips when special regimes apply.

Greece’s three special regimes - the real story

Greece launched three distinct expat regimes between 2019 and 2021. Each targets a different worker profile.

1. Article 5C - “non-dom” working professional regime (since 2020)

For relocating high-skilled workers:

• 50% income exemption on Greek-source employment or self-employment income
• 7 years duration
• Must transfer tax residence to Greece, must NOT have been Greek tax resident for 5 of last 6 years
• Must commit to staying ≥2 years
• Foreign-source income: taxed at full Greek rates (treaty-protected as usual)

A €100k Greek-source salary holder under 5C: pays IRPEF on €50k → ~€16,400. Plus full SS.

2. Article 5A - “pensioner non-dom” regime (since 2019)

For retirees relocating with foreign pension income:

• 7% flat tax on all foreign-source income (pension, dividends, interest, rental)
• 15 years duration
• Must transfer tax residence to Greece, must NOT have been Greek tax resident for 5 of last 6 years
• Must commit to staying long-term
• Greek-source income: taxed at full Greek IRPF

A €60k UK pension holder under 5A: pays €4,200/year in Greek tax. Period. That’s it.

3. Article 5B - HNWI €100,000 flat-tax regime (since 2020)

For ultra-high-net-worth individuals:

• €100,000 / year flat tax on ALL foreign-source income, regardless of amount
• 15 years duration
• Requires €500,000 investment in Greece (real estate, securities, business) within 3 years
• Up to €20,000 add-on per family member relocating with you
• Greek-source income: full Greek IRPF
• Effectively caps annual tax on foreign wealth at €100k no matter how much you make abroad

Someone earning €10M/year in foreign dividends: pays €100k in Greece (effective 1%). The same person under standard PT/Spanish/French regime would pay €4-5M.

This is why ultra-wealthy expats pick Greece - there’s no European equivalent at this scale.

Comparison: Portugal NHR/IFICI vs Greek 5A/5B/5C

For each Greek regime, what’s the right Portuguese alternative?

Greek regime	Best Portuguese alternative	Winner - why
Article 5C (50% on Greek income, 7 years)	IFICI (20% flat on qualifying income, 10 years, foreign income exempt)	Portugal IFICI for foreign-income holders. Greece 5C for non-IFICI-qualifying high earners with no foreign passive income.
Article 5A (7% on foreign income, 15 years)	NHR with 10% pension flat (legacy only - no equivalent for new applicants from 2024)	Greece 5A wins decisively for new pensioners - 7% beats 10%, 15 years beats 10. NHR pensioners pre-2024 stay on their current terms.
Article 5B (€100k flat, 15 years)	NHR (legacy) or IFICI exempt foreign income	Greece 5B for ultra-HNW (annual foreign income > ~€500k, since 20% on €500k = €100k). Portugal NHR/IFICI for moderate HNW (annual foreign income < €500k), since 0% flat beats €100k flat.

The crossover point for HNW between Portugal NHR/IFICI (0% on foreign income) and Greece 5B (€100k flat on foreign income): roughly €500k/year of foreign income. Below: Portugal saves you the €100k. Above: Greece caps at €100k while Portugal IFICI keeps exempting.

Worked example: €70k pensioner, foreign pensions only

This is the cleanest comparison. A retired couple with €70,000/year in foreign pensions (UK + US Social Security):

Country & regime	Annual tax
Portugal - NHR pensioner (legacy holder)	10% × €70k = €7,000
Portugal - Standard (post-NHR / non-eligible)	Progressive brackets ≈ €16,800
Greece - Article 5A	7% × €70k = €4,900
Greece - Standard (post-5A / non-eligible)	Progressive brackets ≈ €21,400

Greek 5A wins by €2,100/year over Portuguese legacy NHR. And it’s available to NEW residents - NHR’s pensioner regime is closed since 2024.

For pensioners, Greece is now the winning EU jurisdiction.

Worked example: €80k self-employed software developer, year 3

Not eligible for Portuguese IFICI (general consulting work), considering Article 5C in Greece:

Country & regime	Income tax	SS	Total tax
Portugal standard Cat B	~€16,300	~€12,000	€28,300 (35.4%)
Greece standard	~€22,400	~€21,000 (EFKA full)	€43,400 (54.3%)
Greece Article 5C (50% exempt)	~€8,800	~€21,000	€29,800 (37.3%)

Greek 5C closes the gap to roughly tied with Portuguese standard, but doesn’t beat it because Greek self-employed SS (EFKA full) is much higher than Portuguese Cat B SS.

For self-employed in this income range, Portugal standard regime wins even vs Greek 5C.

Other taxes - VAT, property, vehicles

Tax	Portugal	Greece
VAT (standard)	23%	24%
VAT (intermediate)	13%	13%
VAT (reduced)	6%	6%
Property tax (annual)	IMI 0.3-0.45% of VPT	ENFIA 0.1-1% (varies by property type and value)
Property purchase	IMT 0-8% + Selo 0.8%	Transfer tax 3% (or 24% VAT if new)
Inheritance tax	None for direct relatives	1-10% direct relatives, up to 40% non-relatives
Capital gains	28% flat	15% flat on shares, 0% on real estate held >5 years

Greece’s CGT is substantially friendlier than Portugal’s - 15% vs 28%. For an investor selling shares, Greece beats Portugal cleanly. Real estate held over 5 years exits Greece tax-free.

Worked total: €60,000 single freelancer, Year 3

Tax	Portugal	Greece (standard)	Greece (Article 5C eligible)
Income tax	€11,652	~€16,200	~€6,000 (50% exempt)
Social Security	€8,988	~€16,800 (EFKA self-employed)	~€16,800
VAT on €30k consumption	~€5,000	~€5,200	~€5,200
ENFIA / IMI on €200k home	€700	~€600	~€600
Total	~€26,340	~€38,800	~€28,600

Even with the 50% income exemption, Greek 5C is roughly tied with Portuguese standard at this level - Greek SS for self-employed is the limiting factor.

When to choose which

Choose Portugal if:

• You’re an employed professional in standard or IFICI regime - Portugal IFICI’s 20% flat on foreign+local + foreign exemption beats Greek 5C’s 50% Greek-only exemption
• You’re a self-employed freelancer - Portuguese Cat B SS is much lower than Greek EFKA full
• You have moderate foreign passive income (under €500k/year) - NHR/IFICI exempts; Greece 5B caps at €100k flat (only works at higher incomes)
• You’re committing to 10+ years - IFICI runs 10y vs Greek 5C’s 7y

Choose Greece if:

• You’re a foreign-pension retiree under Article 5A - 7% × foreign income for 15 years is unbeatable in the EU
• You’re ultra-high-net-worth (foreign income > €500k/year) and want the €100k flat cap (Article 5B)
• You’re a high-earning Greek-source-only employee whose work doesn’t qualify for IFICI
• You’re an investor heavily in Greek/EU shares - 15% CGT beats Portugal’s 28%
• You prefer Greek climate, cuisine, or specific island/city - at moderate income these aren’t decisive on tax alone

Common comparison mistakes

Confusing the three Greek regimes. 5A is for pensioners. 5B is HNWI €100k flat. 5C is workers 50% exempt. They have totally different rules.

Forgetting the €500k Greek investment requirement on 5B. The HNWI flat tax requires you to invest €500k in Greece within 3 years. If you don’t, you lose the regime. This is a real opportunity cost vs Portuguese NHR/IFICI which require nothing.

Ignoring Greek SS rates. Greek employee SS is 13.8% (vs PT 11%); Greek self-employed EFKA is much higher than Portuguese Cat B (€16-21k/year on €60k income vs ~€9k/year in PT).

Treating Greek 5C as 50% off everything. The 50% exemption applies only to Greek-source employment/self-employment income. Foreign income is not discounted under 5C (unlike NHR/IFICI which exempt foreign income).

Comparing Greek 5A pensioner regime to current PT NHR. The PT NHR pensioner regime is closed to new applicants since 2024-01-01. Articles published before this often list NHR as a viable option - it isn’t, for new movers.

Run your own numbers

The TAXCLARA calculator handles the Portuguese side. For the Greek side, Greek AADE’s official calculator is the most reliable source for IRPF + EFKA. Apply for any of the three special regimes within 3 months of becoming Greek tax resident.

For deeper PT context: see the Portugal vs Spain comparison and Portugal vs Italy comparison for the broader Mediterranean picture.

Sources

• Portal das Finanças - IRS 2026
• AADE - Greek Tax Authority
• Article 5A - Greek Income Tax Code (pensioner) - Law 4646/2019
• Article 5B - Greek HNWI flat tax - Law 4646/2019
• Article 5C - Greek non-dom worker regime - Law 4758/2020
• PwC - Greece Individual Tax Summary
• EFKA - Greek Social Security contribution rates 2026