Inheritance Tax in Greece: What UK Families Need to Know

If you’re a UK-domiciled family with assets in Greece, understanding both Greek and UK inheritance tax (IHT) laws is crucial for protecting your estate. Many UK families own holiday homes, investment properties, or have inherited land in Greece — and without proper planning, those assets can be taxed twice: once in Greece and once by HMRC in the UK.

Greek inheritance tax applies to assets located within Greece, with tax rates varying based on the relationship between the deceased and the heir. Meanwhile, UK-domiciled individuals are liable for IHT on their worldwide assets — including Greek property. The interplay between these two systems creates both risks and planning opportunities that we can help you navigate.

Want to protect your estate from unnecessary inheritance tax? Fill out our contact form, call us at 0117 440 1555, or book a call with our team of specialists today.

Key Takeaways

• UK-domiciled individuals face IHT on worldwide assets, including property in Greece — meaning Greek assets may be taxed under both Greek and UK inheritance tax rules.
• Greek inheritance tax rates vary based on the relationship between the deceased and the heir, with close family members benefiting from higher tax-free allowances.
• There is currently no specific UK-Greece double taxation treaty for inheritance tax, making careful planning essential to avoid or mitigate double taxation.
• Unilateral relief may be available through HMRC to credit Greek tax paid against UK IHT, but this needs to be claimed correctly.
• Lifetime trusts, wills valid in both jurisdictions, and strategic gifting can all play a role in protecting your cross-border estate.

Understanding Inheritance Tax in Greece

As a UK family with ties to Greece, grasping the nuances of both Greek inheritance tax and UK IHT is essential for effective estate planning. Greek inheritance tax operates very differently from the UK system, and understanding both is the key to keeping more of your wealth within the family.

Overview of Inheritance Tax

Greek inheritance tax is governed by the Greek Code of Inheritance Tax Legislation (Law 2961/2001), and EU Succession Regulation 650/2012 governs which country’s succession law applies to the estate. Since Brexit, UK nationals are no longer EU citizens, but the Regulation still applies within EU member states — and Greece may still recognise a UK national’s choice of law in their will. This means it is possible for your English will to govern how your Greek assets are distributed, though Greek tax will still apply to assets located in Greece.

Key aspects of Greek inheritance tax include:

• The tax is levied on the beneficiaries, not the estate itself — each beneficiary is taxed individually based on their share and their relationship to the deceased.
• Beneficiaries are divided into three categories (A, B, and C) with different tax-free thresholds and progressive tax rates for each.
• Real property in Greece is valued using the “objective value” system (antikeimenikes axies), which is often lower than the market value — though recent reforms have brought these values closer to market rates.

Eligibility and Exemptions

Understanding who qualifies for inheritance tax exemptions in Greece is vital for minimising tax liabilities. Key exemptions and thresholds include:

1. Category A beneficiaries (spouse, children, grandchildren, parents): Tax-free threshold of €150,000 per beneficiary, with progressive rates from 1% to 10% on amounts above the threshold.
2. Category B beneficiaries (siblings, nephews, nieces, grandparents, in-laws): Tax-free threshold of €30,000, with rates from 5% to 20%.
3. Category C beneficiaries (all others, including unmarried partners): Tax-free threshold of €6,000, with rates from 20% to 40%.

Special exemptions also apply to the family home in certain circumstances — for example, a surviving spouse or minor children inheriting a primary residence may qualify for a full exemption up to a certain value, provided specific conditions are met (such as not already owning a property of a certain size).

Common Misconceptions

There are several misconceptions surrounding Greek inheritance tax that can lead UK families into costly errors:

• The belief that paying Greek tax settles everything: UK-domiciled individuals remain liable for UK IHT on their worldwide estate. Greek property valued at, say, €300,000 forms part of your estate for HMRC purposes, potentially pushing you above the nil rate band of £325,000.
• The assumption that Greek law always applies to how assets are distributed: With proper planning — including an explicit choice of law clause in your will — English succession law can govern how your Greek assets pass, which is particularly important for avoiding Greece’s forced heirship rules.
• The belief that a UK will automatically covers Greek assets: While it can in principle, it is generally advisable to have a separate Greek will dealing specifically with Greek assets, carefully drafted to complement (not revoke) your English will.

Clarifying these misconceptions early is the foundation of effective cross-border estate planning.

The Process of Inheritance Tax Assessment

Understanding the process of inheritance tax assessment in Greece is crucial for UK families who own assets there. The Greek system involves several distinct steps that differ significantly from the UK’s process of obtaining a Grant of Probate and filing an IHT return with HMRC.

How Valuations are Conducted

In Greece, property valuations for inheritance tax purposes are primarily based on the “objective value” (antikeimenikes axies) — a government-set value determined by location, size, age, and characteristics of the property. This is not the same as market value, though recent reforms have been narrowing the gap. For other assets such as bank accounts and investments held in Greece, the value at the date of death is used.

Key factors considered during valuation include:

• The objective (government-assessed) value of real property, based on its location, floor area, and condition
• Current market values for financial assets, vehicles, and other personal property
• Any outstanding debts, mortgages, or liabilities that can be deducted from the taxable estate

Required Documentation

Greek inheritance tax must generally be filed within six months of death for residents and twelve months for non-residents. To facilitate a smooth assessment, beneficiaries typically need:

• A death certificate (translated and apostilled for use in Greece)
• The deceased’s will, if one exists — along with a Greek probate court acceptance (or renunciation) of the inheritance
• A Greek tax identification number (AFM) for each beneficiary
• Property details including ENFIA certificates (annual property tax certificates) and title deeds
• Details of any Greek bank accounts, investments, or other assets
• Documentation of any debts or liabilities related to the Greek estate

Having comprehensive documentation ready can significantly streamline the process. On the UK side, the Greek assets must also be reported on the IHT400 form submitted to HMRC. For more information on managing inheritance tax in the UK, visit our page on inheritance tax in the UK.

Timeline for Payment

Beneficiaries in Greece are generally required to file and pay within the six-month (residents) or twelve-month (non-residents) window. Extensions may be available in certain circumstances, but late filings attract penalties and surcharges. Importantly, beneficiaries must formally “accept” the inheritance through the Greek courts before they can deal with the assets — and this acceptance also makes them liable for any debts of the deceased up to the value of the inheritance (unless they choose “acceptance with benefit of inventory,” which limits liability).

Missing deadlines in either Greece or the UK can result in penalties from both the Greek tax authorities and HMRC. Our specialists can help coordinate the process across both jurisdictions to ensure all obligations are met on time.

Recent Changes to Inheritance Tax Regulations

Greece has made several significant changes to its inheritance tax system in recent years, and these changes directly affect UK families with Greek assets. Staying informed is essential — and so is reviewing your estate plan whenever the rules change in either country.

Legislative Updates

In recent years, Greece has reformed its objective property values (bringing them closer to market rates), revised tax-free allowances, and introduced electronic filing requirements for inheritance tax returns. Key changes affecting UK families include:

It is worth noting that Greek tax rules are updated periodically, and the figures above reflect the current position as of 2025. Always verify current thresholds with a qualified Greek tax adviser before relying on specific numbers.

Impact on UK Families

These changes can have a significant impact on UK families with assets in Greece. The increase in objective property values, for instance, means that Greek properties may now be assessed at a higher value for inheritance tax purposes — potentially increasing the tax payable in Greece. At the same time, UK families must remember that HMRC assesses Greek property at its actual market value (converted to pounds sterling), not the Greek objective value.

This creates a dual consideration: you may pay Greek inheritance tax on a lower objective value, but HMRC will calculate IHT based on the true market value. Understanding this distinction is critical, particularly when claiming credit for Greek tax already paid.

Advice for Planning Ahead

To minimise potential tax liabilities across both jurisdictions, we recommend the following strategies:

• Have two complementary wills — one English will covering UK assets and one Greek will covering Greek assets, carefully drafted so they do not inadvertently revoke each other.
• Consider lifetime trust planning for UK assets to reduce the overall UK estate value, making it easier to absorb the Greek property within the nil rate band (£325,000 per person, frozen since 2009 and confirmed frozen until at least April 2031).
• Explore whether gifting Greek property during your lifetime could reduce both Greek and UK tax exposure — though note that Greek gift tax applies on a similar basis to inheritance tax, and gifts by UK-domiciled individuals to other individuals are potentially exempt transfers (PETs) for UK IHT purposes only if the donor survives seven years.
• Seek specialist cross-border advice — the interaction between Greek and UK tax is complex, and general financial advisers are unlikely to understand both systems. As Mike Pugh says, “The law — like medicine — is broad. You wouldn’t want your GP doing surgery.”

By staying informed and planning ahead, you can protect your estate and ensure that your loved ones are not unduly burdened by inheritance tax in either country.

Comparing Inheritance Tax in Greece and the UK

Understanding the differences between Greek inheritance tax and UK IHT is essential for any family holding assets in both countries. The two systems are fundamentally different in structure, and knowing how they interact can save you tens of thousands of pounds.

Tax Rates and Allowances

Greek and UK inheritance tax differ fundamentally in their structure. Greece taxes each beneficiary individually, based on their relationship to the deceased, with progressive rates and separate tax-free allowances for each person. Category A beneficiaries (spouses, children, grandchildren, parents) enjoy a €150,000 tax-free threshold with rates ranging from 1% to 10%. More distant relatives and unrelated beneficiaries face lower thresholds and rates up to 40%.

The UK, by contrast, taxes the estate as a whole. The nil rate band is £325,000 per person (frozen since 2009 and confirmed frozen until at least April 2031), and anything above that is taxed at a flat rate of 40%. For married couples and civil partners, unused nil rate band can transfer to the surviving spouse or civil partner, giving a combined allowance of up to £650,000. The residence nil rate band (RNRB) adds up to £175,000 per person — but only if a qualifying residential interest is passed to direct descendants (children, grandchildren, or step-children). This means a married couple could potentially pass up to £1,000,000 before IHT applies.

Importantly, the RNRB does not apply to Greek property. It only applies to a UK residential interest that was the deceased’s home. This is a critical planning point for UK families whose main asset is a Greek property rather than a UK home.

Exemptions and Reliefs

Both countries offer exemptions, but they work very differently. In Greece, the primary residence exemption can eliminate tax entirely for a surviving spouse or minor children inheriting the family home (subject to value limits and conditions about not owning other property). Greece also provides exemptions for certain agricultural and business assets in specific circumstances.

In the UK, key reliefs include the spouse exemption (unlimited transfers between spouses and civil partners, completely IHT-free), Business Property Relief (BPR), Agricultural Property Relief (APR), and the ability to reduce the IHT rate to 36% if 10% or more of the net estate is left to charity. From April 2026, BPR and APR will be capped at 100% relief on the first £1 million of combined qualifying property, with 50% relief on the excess.

Greece’s more generous per-beneficiary allowances mean that close family members often pay little or no Greek inheritance tax on modest properties. However, the same property could push the overall UK estate above the nil rate band, triggering a 40% IHT charge on the excess. This is precisely why cross-border planning matters.

Cross-Border Tax Implications

For UK-domiciled families with assets in Greece, the crucial issue is double taxation. The UK taxes worldwide assets of UK-domiciled individuals, while Greece taxes assets situated within its borders. This means a Greek holiday home could, in theory, be subject to both Greek inheritance tax and UK IHT.

There is currently no specific UK-Greece double taxation treaty covering inheritance tax. However, HMRC does allow “unilateral relief” under UK domestic law, which means you can claim a credit against your UK IHT for any inheritance tax actually paid in Greece on the same assets. This doesn’t eliminate the tax entirely — if Greek tax is lower than UK IHT on those assets, the difference is still payable to HMRC.

We strongly recommend working with specialists who understand both jurisdictions to ensure that any available reliefs are claimed and that the overall tax burden is minimised as far as legally possible.

Planning for Inheritance Tax in Greece

Greece’s inheritance tax landscape can be complex, but with the right strategies, UK families can significantly reduce their cross-border tax exposure. The key is planning well in advance — not reacting after a death has occurred, when options are severely limited.

Strategies to Minimise Liabilities

There are several practical strategies that can help minimise combined Greek and UK inheritance tax liabilities:

• Lifetime gifting: Gifts of Greek property during your lifetime are subject to Greek gift tax (at similar rates to inheritance tax), but for UK IHT purposes, a gift to an individual is a potentially exempt transfer (PET) that falls outside your estate entirely if you survive seven years. This can be particularly effective for Greek holiday homes you no longer use regularly. Bear in mind the taper relief rules — if the donor dies between three and seven years after making the gift and the cumulative value of PETs exceeds the nil rate band (£325,000), taper relief reduces the tax payable rather than the value of the gift.
• Lifetime trusts for UK assets: By placing your UK home into a properly structured lifetime trust, you can reduce the value of your UK estate. This means that when your Greek property is added to your worldwide estate for HMRC purposes, you’re less likely to exceed the nil rate band. A Family Home Protection Trust or Gifted Property Trust from MP Estate Planning can be set up from as little as £850 — the equivalent of roughly one week’s care home fees, yet the protection lasts a lifetime. Important to note: a trust must be irrevocable to achieve IHT benefits, as a revocable trust leaves assets treated as still belonging to the settlor for HMRC purposes.
• Dual wills: Having a separate Greek will for your Greek assets and an English will for your UK assets ensures each jurisdiction’s succession process runs smoothly. This can also prevent the delays and costs of having a UK Grant of Probate recognised in Greece.
• Using annual exemptions: In the UK, you can gift up to £3,000 per tax year free of IHT (with one year’s carry-forward), make small gifts of up to £250 per recipient, and make regular gifts from surplus income under the normal expenditure out of income exemption. These may seem modest individually, but used consistently over many years, they reduce the estate steadily.

Gifting can be an effective way to reduce your estate’s value, but it’s crucial to understand the tax implications in both countries before transferring any asset. In particular, the UK’s gift with reservation of benefit rules mean that if you gift Greek property but continue to enjoy it — for example, by using the holiday home without paying full market rent — HMRC will treat the property as still forming part of your estate for IHT purposes, even if you survive seven years.

Importance of Professional Guidance

Cross-border inheritance tax planning sits at the intersection of Greek tax law, UK IHT law, EU succession regulation, and international property law. This is not an area for DIY planning or general financial advice. You need specialists who understand both systems and how they interact.

Professional guidance is not just about compliance; it’s about strategic planning to safeguard your legacy across borders. We work closely with our clients to understand their unique circumstances — including the mix of UK and Greek assets, family structure, and long-term goals — and develop tailored plans that work in both jurisdictions.

Role of Trusts and Gifts

Trusts and gifts can play a significant role in reducing overall IHT exposure for UK families with Greek assets. It’s important to understand that trusts work differently in Greece and the UK — Greece does not have a trust law tradition equivalent to England’s 800-year-old system, so trusts are primarily useful for managing the UK side of the equation. Under English law, a trust is a legal arrangement (not a separate legal entity) where trustees hold legal ownership of assets for the benefit of named beneficiaries.

For UK lifetime trusts, the most commonly used structure is a discretionary trust, where the trustees have absolute discretion over how and when to distribute income and capital to beneficiaries. No beneficiary has an automatic right to the trust assets — and this is precisely what provides protection against care fee assessments, divorce claims, and sideways disinheritance. A properly structured discretionary trust can last for up to 125 years under English law.

Our team can help you plan effectively, ensuring that you are making the most of these strategies. With the right guidance, you can protect your estate on both sides of the equation and secure your family’s future. Plan, don’t panic.

Tax Treaties between Greece and the UK

For UK families with Greek assets, understanding the tax treaty position between the two countries is essential — and the reality may be less protective than many people assume.

What They Mean for UK Residents

The UK and Greece have a double taxation agreement covering income tax and capital gains tax, which can provide relief in certain situations involving rental income from Greek property or gains on the sale of Greek assets. However, there is no specific UK-Greece double taxation treaty covering inheritance tax. This is a critical distinction that many families — and some general advisers — overlook.

Without a specific inheritance tax treaty, relief from double taxation depends on HMRC’s unilateral relief provisions under UK domestic law. In practice, this means you can claim a credit for Greek inheritance tax actually paid against the UK IHT due on the same assets, but the process requires proper documentation and careful calculation.

Understanding Double Taxation

Double taxation occurs when the same asset is taxed by both Greece and the UK on death. For UK-domiciled individuals, this is a real risk with Greek property. Here’s a practical example of how it works:

The key point is that unilateral relief only credits the foreign tax actually paid. If Greek tax on a property is, say, €5,000 but UK IHT attributable to the same property would be considerably more, you still owe the difference to HMRC. And because Greece uses objective values (often lower than market value) while HMRC uses actual market value, the UK tax bill on Greek property can be higher than expected.

Benefits and Limitations

The availability of unilateral relief is a genuine benefit — without it, families would face the full tax burden in both countries with no offset. However, the limitations are significant:

• Relief must be actively claimed — it is not automatic.
• It only covers tax on assets that are genuinely taxed in both jurisdictions — you cannot credit Greek tax on one asset against UK IHT on a different asset.
• The calculation can be complex, particularly when exchange rates, different valuation methods, and different beneficiary structures are involved.
• Some families assume that paying tax in Greece means no UK IHT is due — this is incorrect. The UK liability is calculated independently, and the Greek credit simply reduces the amount payable.

By understanding the true position — rather than relying on assumptions — you can plan your estate to minimise the combined Greek and UK tax burden. We are here to guide you through this process, ensuring you claim every relief available while remaining fully compliant with both countries’ tax laws.

Common Challenges Faced by UK Families

UK families inheriting or managing property in Greece face a unique set of challenges that go well beyond simply understanding the tax rates. Here are the most common issues we see — and how to address them.

Navigating Legal Complexities

Greek succession law includes forced heirship provisions (called “nomimi mira”), which reserve a portion of the estate for close family members regardless of the deceased’s wishes. This can conflict with an English will that distributes assets differently. Key issues include understanding how forced heirship interacts with EU Succession Regulation 650/2012, whether a choice of law clause in your will is enforceable post-Brexit, and how Greek property transfer taxes and registration requirements apply on inheritance.

UK families also face the challenge of dealing with two separate processes — obtaining a Grant of Probate (or Letters of Administration) in England and Wales for UK assets, and going through the Greek court acceptance process for Greek assets. These processes run on different timelines and have different documentation requirements, making coordination essential. During the UK probate process, all sole-name assets are frozen — bank accounts, property, and investments cannot be accessed until the Grant is issued. Assets held in a properly structured lifetime trust, by contrast, bypass probate entirely and can be dealt with by the trustees immediately.

Language Barriers

All Greek legal and tax documents are in Greek, and the inheritance tax filing process requires interaction with the Greek tax office (AADE). Clear communication is crucial — mistranslations or misunderstandings can lead to incorrect filings, missed deadlines, or failure to claim available exemptions.

We can connect you with English-speaking Greek solicitors and tax advisers who specialise in cross-border inheritance matters, ensuring nothing is lost in translation and that your interests are properly represented in both jurisdictions.

Identifying Local Resources

Finding reliable professionals in Greece who understand the needs of UK families — and who can communicate effectively with your UK advisers — can be challenging. Many UK families discover too late that their general UK solicitor has no experience with Greek property succession, or that their Greek contact has no understanding of UK IHT.

By leveraging our network of trusted cross-border professionals, UK families can access coordinated support across both countries. This joined-up approach prevents the costly mistakes that arise when Greek and UK advisers work in isolation from each other.

Protecting Your Estate from Inheritance Tax

For UK families with properties in Greece, safeguarding their legacy from inheritance tax requires a coordinated approach across both jurisdictions. The goal is not just to minimise Greek tax or UK IHT in isolation, but to optimise the combined position — ensuring your family keeps as much of the wealth as legally possible.

Importance of Estate Planning

Estate planning for cross-border assets is about more than just reducing tax — it’s about ensuring your wishes are respected in both countries, avoiding family disputes, and preventing assets from being frozen in lengthy administrative processes. The UK nil rate band has been frozen at £325,000 since 2009, and with the average home in England now worth around £290,000, it doesn’t take much for a Greek property to push a family’s total estate well into IHT territory.

• Understand how Greek inheritance tax and UK IHT apply to your combined estate — not just each country in isolation.
• Identify whether the residence nil rate band (RNRB) is available for your UK home (it’s worth up to £175,000 per person, but only applies to qualifying residential property passed to direct descendants — it is not available for nephews, nieces, siblings, or friends).
• Consider whether placing your UK home into a lifetime trust could free up your nil rate band to absorb the value of Greek assets. Depending on the type of trust used, you may still retain the RNRB — for example, MP Estate Planning’s Family Home Protection Trust (Plus) is specifically designed to protect the home while preserving RNRB eligibility.

Steps to Safeguard Your Legacy

To protect your estate across both Greece and the UK, consider the following steps:

For more detailed guidance on Greek inheritance tax, you can refer to our comprehensive guide on inheritance tax in Greece.

Seeking Professional Help

Given the complexity of managing Greek inheritance tax alongside UK IHT, seeking professional help is not just advisable — it’s essential. Cross-border estates are one of the most complex areas of tax planning, and mistakes can be extremely costly. Trusts are not just for the rich — they’re for the smart, and UK families with overseas property have even more reason to plan carefully.

By taking proactive steps now, you can protect your estate from unnecessary tax in both countries, ensure your family isn’t left navigating two separate legal systems during a difficult time, and secure your legacy for future generations. Not losing the family money provides the greatest peace of mind above all else.

How to Get in Touch with Our Specialists

We understand that navigating inheritance tax across Greece and the UK can feel overwhelming. The rules are complex, the stakes are high, and the interaction between two countries’ tax systems creates challenges that most general advisers simply aren’t equipped to handle. That’s exactly why we’re here.

Expert Guidance at Your Fingertips

To learn more about our services or to discuss your specific cross-border estate planning needs, you can fill out our contact form, call us at 0117 440 1555, or book a call with our team of specialists today. Whether you need help understanding how your Greek property affects your UK IHT position, want to explore lifetime trust planning for your UK home, or need guidance on setting up dual wills — we can help.

Personalised Support

Every family’s situation is different. The value of your Greek and UK assets, your family structure, your long-term plans for the property, and your domicile status all affect the best approach. We don’t offer one-size-fits-all advice — we take the time to understand your circumstances and develop a tailored plan that works across both jurisdictions. Our proprietary Estate Pro AI runs a 13-point threat analysis on your estate to identify risks you may not have considered.

Safeguarding Your Legacy

At MP Estate Planning, founded by Mike Pugh, we are committed to safeguarding legacies through expert inheritance tax planning and estate planning — whether your assets are in the UK, Greece, or both. England invented trust law over 800 years ago, and we use that deep legal tradition to protect families today. Keeping families wealthy strengthens the country as a whole — and we look forward to the opportunity to support you in protecting your assets and securing your family’s financial future.

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