Articles 96 to 98 of Law 5313/2026 expand Greece's carried interest tax framework, extending favourable treatment beyond fund managers to employees of Greek companies that service EU and third-country alternative investment fund (AIF) managers.
Under the new provisions, qualifying recipients may be taxed on carried interest at a preferential rate of 5%, compared with the standard 15% rate that would otherwise apply. The legislation also confirms that carried interest payments are deductible as a business expense for the paying entity.
Of particular significance for cross-border structures, the law clarifies that neither a place of effective management nor a permanent establishment is created in Greece merely because an EU or third-country AIF is serviced by a Greek entity. This removes a longstanding source of uncertainty for fund managers considering Greek-based operations.
Article 94 makes separate amendments to Articles 5A and 5B of the Greek Income Tax Code. These changes shift payment deadlines for lump-sum taxes to December, remove the previous 31 March filing deadline for applications to be included in the lump-sum regime, and transfer related regulatory authority to the Governor of the Independent Authority for Public Revenue (AADE).
Taken together, the measures are designed to position Greece as a more competitive location for alternative investment activity, both by broadening the pool of individuals who can access the preferential carried interest rate and by providing structural certainty for foreign AIF managers engaging Greek service providers.