Greek tax law expands loophole, letting wealthy families shift assets tax-free
A 2024 amendment to Greece's corporate-restructuring tax code now exempts asymmetric demergers, enabling rich families to pass multi-million-euro holdings to heirs without capital-gains or inheritance taxes.
In 2024, Greece passed law 5162/2024, extending corporate-restructuring tax breaks to asymmetric demergers that alter shareholders' stakes. The reform, promoted by former finance minister Kostis Chatzidakis, removes capital-gains, donation and parental-gift taxes that previously applied to such splits, allowing affluent owners to allocate entire subsidiaries to individual heirs tax-free. The process involves inserting children as nominal shareholders, then splitting the original firm into multiple entities, each transferred wholly to a child without any tax charge.
Simultaneously, the government stopped requiring real-estate transfer-tax declarations on the AADE’s myPROPERTY portal for these corporate moves, limiting real-time tax authority scrutiny. Oversight now rests with a small team in the Centre for Large Taxpayer Control (KEMEF), which lacks capacity to audit the complex, high-value restructurings, effectively shielding the transfers from effective enforcement.
Why it matters
The law lets Greece’s richest families move billions of euros across generations without paying taxes, shrinking state revenue.
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