Navigating Greek Inheritance Laws: Essential Guide for International Property Owners

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Table of Contents:

• Introduction to Greek Inheritance Laws
• The Legal Framework
  • Greek Civil Code Fundamentals
  • EU Regulations and International Property
• Types of Succession in Greece
  • Intestate Succession: When No Will Exists
  • Testamentary Succession: Greek Wills and Recognition
• The Forced Heirship System
• Inheritance Taxes and Property Transfer Costs
• Practical Considerations for Foreign Owners
• Real-World Inheritance Scenarios
• Expert Recommendations
• Frequently Asked Questions

Introduction to Greek Inheritance Laws

Thinking about securing your legacy through Greek property? You’re joining thousands who’ve fallen for the Mediterranean charm of Greek real estate. Whether you already buy house in Greece or are considering it, understanding the inheritance framework isn’t just paperwork—it’s peace of mind.

Greek inheritance laws present a unique blend of continental European principles and distinctive local provisions that can surprise foreign owners. The stakes? Significant. Without proper planning, your beneficiaries could face unexpected legal hurdles, tax implications, and administrative delays measured in years, not months.

This comprehensive guide cuts through the complexity. We’ll examine how Greek inheritance laws intersect with international regulations, explore the forced heirship provisions that might override your wishes, and provide actionable strategies to ensure your Greek property transfers according to your intentions.

The Legal Framework

Greek Civil Code Fundamentals

The cornerstone of Greek inheritance law rests within the Greek Civil Code (Articles 1710-2035), which establishes the foundation for all succession matters in Greece. Unlike common law systems prevalent in the UK or US, Greece follows a civil law tradition with some distinctive features:

• Applicable Law: Greek law applies to all immovable property within Greek territory, regardless of the owner’s nationality or residence.
• Forced Heirship: The law reserves mandatory portions (legitim) for close family members that cannot be freely disposed of by will.
• Reserved Portion: Depending on the surviving relatives, between 1/2 and 3/4 of an estate may be subject to forced heirship rules.

Maria Papadopoulos, a senior inheritance attorney in Athens, notes: “Many foreign clients are surprised to discover that under Greek law, they cannot freely dispose of their entire estate. The protection of family members through reserved portions represents a fundamental principle of our inheritance system that often conflicts with expectations from common law jurisdictions.”

EU Regulations and International Property

Since August 2015, the EU Succession Regulation (Brussels IV) has significantly impacted cross-border inheritance cases involving Greek property:

• Choice of Law: Non-Greek nationals can elect to have the law of their nationality apply to their entire succession, potentially circumventing Greek forced heirship rules.
• Habitual Residence: Without an explicit choice, the default applicable law is that of the deceased’s last habitual residence.
• Exception: Despite Brussels IV, Greek property taxation and transfer procedures remain governed by Greek law.

Consider this practical scenario: A British national residing in Germany who owns a villa in Crete can explicitly choose British law in their will, potentially allowing greater testamentary freedom. However, the actual property transfer process will still follow Greek procedural requirements.

Types of Succession in Greece

Intestate Succession: When No Will Exists

Dying without a will (intestate) triggers Greece’s statutory distribution scheme. The order of succession follows clear hierarchical classes:

A surviving spouse inherits concurrently with any class but receives different portions depending on which class they share with:

• With first class heirs: 1/4 of the estate
• With second or third class heirs: 1/2 of the estate
• With no other heirs: The entire estate

Testamentary Succession: Greek Wills and Recognition

To direct your Greek property according to your wishes, you’ll need a valid will. Greek law recognizes several forms:

• Holographic Will: Entirely handwritten, dated, and signed by the testator. Simple but prone to validity challenges.
• Public Will: Drafted by a notary in the presence of witnesses. Most secure and recommended for property matters.
• Secret Will: Delivered sealed to a notary with witnesses. Maintains privacy while ensuring formality.
• Foreign Wills: Generally recognized if complying with either Greek law or the law of the country where executed.

Attorney Nikos Stavropoulos emphasizes: “For international clients with Greek properties, I strongly recommend a public will executed before a Greek notary, specifically addressing the Greek assets. This minimizes potential disputes and accelerates the inheritance process considerably.”

The Forced Heirship System

Perhaps the most challenging aspect for foreign property owners is Greece’s forced heirship system (legitim). Unlike common law jurisdictions that generally allow complete testamentary freedom, Greek law reserves mandatory portions for close relatives, specifically:

These rules mean that regardless of your written will, qualified heirs can claim their reserved portion, potentially overriding your expressed wishes. However, several strategies exist to navigate these restrictions:

• Choice of Law: EU nationals can designate their national law to govern succession.
• Inter Vivos Gifts: Transferring property during your lifetime, though subject to lookback periods.
• Usufruct Arrangements: Separating ownership rights from usage rights.
• Company Structures: Holding property through corporate entities rather than directly.

Inheritance Taxes and Property Transfer Costs

Greek inheritance tax rates vary based on the relationship between the deceased and the beneficiary, with three categories determining the applicable tax rates:

• Category A (closest relatives): Spouse, children, parents
  • First €150,000: Exempt
  • Next €150,000: 1%
  • Next €300,000: 5%
  • Next €700,000: 10%
  • Above €1,300,000: 20%
• Category B (extended family): Grandchildren, siblings, etc.
  • First €30,000: Exempt
  • Next €70,000: 5%
  • Next €200,000: 10%
  • Above €300,000: 20%
• Category C (other beneficiaries): Unrelated individuals
  • First €6,000: Exempt
  • Next €66,000: 20%
  • Next €195,000: 30%
  • Above €267,000: 40%

Beyond taxes, heirs should anticipate additional costs:

• Notary fees: 0.8-1% of property value
• Property transfer taxes: 3% of assessed value
• Land registry fees: Approximately 0.5%
• Legal fees: Typically 1-2% for complex estates

Practical Considerations for Foreign Owners

If you’re a non-Greek national with property in Greece, several practical considerations warrant attention:

• Documentation: Ensure all property titles are clear and registered properly in the Greek land registry and cadastre.
• Tax Compliance: Maintain current property tax payments to prevent complications during inheritance.
• Power of Attorney: Designate a Greek legal representative to handle matters when you’re unavailable.
• Greek Tax Number (AFM): Both the deceased and heirs require a Greek tax identification number to process inheritance.
• Probate Timeline: Allow 12-24 months for the complete process, longer in contested cases.

“The most significant delays in Greek inheritance cases arise from incomplete documentation and untraceable heirs,” explains Eleni Constantinou, a property law notary in Athens. “Maintaining organized property records and informing your heirs about Greek assets can reduce the inheritance timeline by months or even years.”

Real-World Inheritance Scenarios

Case Study 1: The British Family with a Santorini Villa

The Simpsons, a British family, purchased a villa in Santorini in 2005. When Mr. Simpson passed away in 2020, he left a UK will stating the property should pass entirely to his second wife. However, his two children from his first marriage invoked Greek forced heirship rules, claiming their reserved portion.

Outcome: Despite having a valid UK will, the Greek courts recognized the children’s legitim claims. The second wife received 1/2 of the property, while each child received 1/4, reflecting Greek forced heirship principles rather than Mr. Simpson’s expressed wishes.

Case Study 2: The German Entrepreneur with Foresight

Dr. Mueller, a German businessman, acquired several properties in Rhodes. Aware of Greek inheritance complexities, he established a German limited company that owned the properties. His shares in the company were governed by German law.

Outcome: Upon his death, the company shares transferred according to his German will, effectively bypassing Greek forced heirship restrictions. While this approach involved higher maintenance costs, it provided greater testamentary freedom.

Expert Recommendations

Based on decades of collective experience with Greek inheritance matters, experts consistently recommend:

1. Create a Greek-specific will: A public will executed before a Greek notary, specifically addressing Greek assets, provides maximum security.
2. Explicitly choose applicable law: EU citizens should clearly designate their national law to govern succession if they wish to avoid forced heirship rules.
3. Consider ownership structures: For significant properties, holding them through companies or trusts may offer greater flexibility.
4. Regular reviews: Update estate plans every 3-5 years or after major life changes (marriage, divorce, births).
5. Professional guidance: Work with an attorney familiar with both Greek inheritance law and your home country’s legal system.

Dimitris Alexopoulos, estate planning specialist, advises: “The most effective inheritance strategies for Greek properties combine multiple approaches—appropriate legal structures, carefully drafted wills, and lifetime planning. No single solution works for everyone, but proper preparation always yields benefits.”

Your Grecian Legacy: Securing Tomorrow’s Inheritance Today

Navigating Greek inheritance laws requires balancing technical compliance with practical realities. While the legal framework may seem restrictive initially, proactive planning opens numerous pathways to achieve your succession goals.

Remember that each inheritance situation presents unique challenges and opportunities. A villa in Mykonos has different inheritance implications than an apartment in Athens or agricultural land in Crete. Your family structure, nationality, and long-term objectives all shape the optimal approach.

To protect your loved ones and your Greek property investment:

• ✓ Consult with dual-qualified legal experts
• ✓ Document your assets comprehensively
• ✓ Consider the tax implications across jurisdictions
• ✓ Communicate your intentions clearly to beneficiaries
• ✓ Review inheritance plans when regulations change

What meaningful legacy do you hope to leave through your Greek property? Beyond the legal technicalities, this question should guide your inheritance planning. Whether your Greek home represents family traditions, investment potential, or a personal sanctuary, thoughtful succession planning ensures your vision extends beyond your lifetime.

Frequently Asked Questions

Can I completely disinherit my children from my Greek property?

Under standard Greek inheritance law, you cannot completely disinherit your children as they are entitled to a reserved portion (legitim) of your estate—typically 1/2 of what they would receive under intestate succession. However, EU citizens can potentially circumvent this by explicitly choosing their national law to govern their entire succession under the EU Succession Regulation (Brussels IV), provided their home country allows disinheritance. Even with this choice, challenges can arise if your children contest the will in Greek courts.

What happens to my Greek property if I die without a will?

If you die without a will (intestate), Greek statutory succession rules automatically apply to your Greek property, regardless of your nationality. Your estate will be distributed according to a hierarchy of heirs: first to descendants (children/grandchildren), then to parents and siblings, then to grandparents and their descendants, and finally to great-grandparents. Your spouse inherits concurrently with these classes, receiving between 1/4 and the entire estate depending on which other heirs exist. This process typically takes longer and offers no flexibility for your personal wishes regarding distribution.

How can married couples best structure ownership of Greek property?

For married couples, carefully considering how to title Greek property can significantly impact future inheritance proceedings. Joint ownership with right of survivorship doesn’t exist under Greek law as it does in some common law countries. Instead, couples typically choose between: (1) equal ownership shares (50/50), which follow standard inheritance rules upon death; (2) unequal ownership reflecting financial contributions; or (3) usufruct arrangements where one spouse owns the property while the other maintains lifetime usage rights. For maximum flexibility, couples might consider combining a carefully drafted will with a marriage contract that addresses property rights. Each approach has different tax and succession implications that should be evaluated with professional guidance.

Article reviewed by Alexandros Ioannidis, Senior Wealth Manager | Multi-Asset Portfolio Specialist | Building Customized Investment Solutions for High-Net-Worth Clients, on April 29, 2025