Expert Column · Tax and Policy
Expert Opinion / Policy Commentary
Housing policy should ask what an investment does to the supply of homes, as well as who makes it. My view is that acquiring an existing residence and creating residential space from a suitable non-residential building deserve separate analysis. That distinction should inform the design of Greece’s announced transfer-tax change, with clear rules and evidence requirements for adaptive reuse.
I write as a founder involved in property development, with a commercial interest in workable conversion projects. This is policy commentary, not personal legal or tax advice. The argument below is my proposed policy approach, and the market implications are scenarios rather than predictions.
What is confirmed
In his 6 September 2026 speech at the 90th Thessaloniki International Fair, the Prime Minister announced an increase in property transfer tax from 3% to 15% for buyers from third countries outside the EU, citing pressure on residents’ access to housing. This verifies an announcement, not enacted legislation.
The government’s technical presentation, published 7 September 2026, gives totals of 3.09% and a proposed 15.45% including the municipal levy. It narrows the proposal to residential property, excluding business premises, plots and other property. It discusses natural persons and tax residence in third countries, alongside nationality and exceptions involving Greeks, persons of Greek origin, EU/EEA citizens and long-term residents; it also references first-home exemption categories. The final bill and enacted law must settle how these descriptions and exceptions interact.
The current government housing-policy page confirms the optional new-building VAT suspension through 31 December 2026. The transaction’s own VAT position still needs professional examination.
The technical presentation’s table of measures not yet legislated includes an announced extension for 2027–2030 of the new-building VAT measure. As of 8 September 2026, that extension and the transfer-tax proposal are not enacted measures in the evidence reviewed here; no exact commencement date is asserted.
Expert analysis
Measure the housing contribution
A policy aimed at easing competition for existing homes has a different starting point from one governing the reuse of genuinely non-residential space. In my view, conversion policy should examine the documented previous use, the residential space created and the quality of the result. It should also examine displacement, the loss of useful commercial activity and whether the new homes can serve lasting residential needs. A conversion label alone is too weak a test.
This is not a claim that every conversion improves affordability. If a scheme displaces an active business, produces poor living conditions or does not add usable residential space, its public value needs to be challenged. I would favour transparent evidence of the starting condition and proposed residential contribution, with property-level technical scrutiny. That is a policy recommendation, not the government’s settled position.
Five transaction scenarios to examine
Existing homes. If the final law applies a higher transfer-tax rate to a particular buyer purchasing an existing residence, the acquisition budget would need to absorb that cost or the parties would need to reconsider price and terms. Demand could respond, but the announcement alone cannot establish the scale of any price or rent effect.
Commercial property bought before conversion. The technical presentation excludes business premises from its stated residential scope. A buyer should not treat this as confirmation that every planned conversion will remain outside the eventual rule. The treatment is unknown until legislation defines the relevant classification and timing, and a tax adviser applies those rules to the actual acquisition.
First sale after developer-led conversion. If the property is residential when transferred to the investor, its earlier commercial use may not determine the tax treatment. Whether the final legislation distinguishes newly created homes, and how transfer tax interacts with the seller’s VAT position, remain open questions. A development model should show those uncertainties explicitly before a reservation is priced.
Corporate and beneficial-owner structures. References to natural persons in a technical presentation do not establish a company exemption or a lawful way around the proposed charge. Advisers must examine the final provisions, ownership disclosures and any anti-avoidance treatment. A corporate structure also raises separate investor-residence questions; the current Mitos procedure requires full investor ownership of the acquiring company in the stated Greece/EU company route.
Transitional milestones. Reservation, payment, the final deed, registration, conversion and residence filing may occur at different times. Which event, if any, governs a transitional rule is unknown. Investors should ask for a dated chronology and contract advice, without assuming that a deposit or early agreement locks in future tax treatment.
Make the policy distinction reviewable
The strongest argument for adaptive reuse is an evidence-based account of what becomes housing and why it is fit for that use. Developers should be prepared to show the starting records, proposed works and professional assessments. Policymakers could use that evidence to distinguish investment that competes for existing homes from investment that creates suitable residential capacity, while retaining checks against relabelling or avoidance.
For an investor deciding now, the useful output is a budget with explicit tax assumptions and a list of unresolved legal questions. Escalate those questions to the appointed Greek tax adviser, lawyer and notary. Proceed only when the decision uses the rules actually applicable to the transaction and the investor understands the exposure to a later change.
Investor checklist
- Record the proposed purchaser, nationality, tax residence and any claimed exception for the tax adviser to assess.
- Request the evidence of the property’s use at acquisition and any planned conversion, keeping commercial and residential stages distinct.
- Ask for separate treatment of transfer tax and VAT in the written budget, with each legal assumption dated.
- Map reservation, payments, deed, registration, conversion and filing so the lawyer can assess any eventual transitional provisions.
- Ask advisers to examine corporate and beneficial-owner implications before choosing an ownership structure.
- Stop relying on a quoted future tax outcome if it rests only on an announcement; escalate for written transaction-specific advice.
- Keep a contingency decision in the commercial terms for material tax uncertainty, subject to the lawyer’s review.
Case evidence
Illustrative Scenario. Imagine two hypothetical proposals: purchasing an existing residence and assessing whether unused office space could become homes. Neither proposal refers to a real property; this is not a Santheos project, and no private client or internal project outcome is being presented.
A policy comparison would ask what evidence distinguishes existing housing from potential additional residential space, including lawful use, technical feasibility and the relevant transaction stage. It would not assume that the conversion proceeds, adds occupied homes or receives a particular tax treatment. The example illustrates a policy question, not a measured market effect or a prediction.
For the earlier housing-policy discussion, see The Athens Housing Crunch: A Post-Pandemic Predicament. Use the Santheos Golden Visa Q&A to distinguish residence questions from the tax questions you send to your advisers.
Official sources
- Office of the Prime Minister, Speech at the 90th Thessaloniki International Fair; published 6 September 2026; housing-policy passage announcing the transfer-tax change; retrieved 8 September 2026.
- Greek Government / Ministry of National Economy and Finance, Technical presentation of the 90th TIF economic measures; published 7 September 2026; section H on residential transfer tax and the new-measures table on VAT for 2027–2030; retrieved 8 September 2026; announcement status.
- Government Housing Policy Portal / Ministry of Social Cohesion and Family, VAT suspension on new buildings; publication date not displayed; current programme description through 31 December 2026; retrieved 8 September 2026.
- Ministry of Migration and Asylum / Mitos, Permanent investor residence permit — change of use, initial issuance; updated 3 August 2026; company-acquisition condition 7; retrieved 8 September 2026.
