Greece already offers its own low-tax route for people moving money in, which changes the honest comparison for anyone moving out. A Greek freelancer weighing Georgia's 1% is comparing against EFKA, the fixed monthly social charge that hits a low earner almost as hard as a high one, and against a residency test that shifts the burden of proof onto anyone trying to leave. This guide works through what Article 4 requires to break Greek residency, what Article 5A's non-dom regime does and does not do here, whether Greek CFC rules reach a Georgian company, and what EFKA really costs once you strip out the marketing.
What a Greek freelancer actually pays, here and there
A Greek freelance developer invoicing 50,000 EUR a year, with the low costs typical of a remote services business, pays Greek income tax on a progressive scale: 9% on the first 10,000 EUR, 20% on the next 10,000, 26% on the next 10,000, 34% on the next 10,000, and 39% on the remainder up to 60,000, under the current scale published by PwC. That works out to roughly 12,800 EUR in income tax alone.
On top of that sits EFKA, Greece's mandatory social security fund for the self-employed. Contributions run in six bands, from a reduced band for certain new professionals near 150 EUR a month up to Category 6 above 650 EUR, reported against the 2026 e-EFKA circular. Most newly self-employed people land on Category 1, currently 250.77 EUR a month, plus a flat 10 EUR monthly OAED unemployment charge - about 3,129 EUR a year, in full, before a single euro of profit is considered.
| Greece (income tax + EFKA) | Georgia (Small Business Status) | |
|---|---|---|
| Turnover / taxable profit | 50,000 EUR | Same |
| Income tax | ~12,800 EUR (progressive 9-39%) | ~500 EUR-equivalent (1%) |
| Mandatory EFKA contributions | ~3,129 EUR | None required by the status itself |
| Total, all-in | ~15,929 EUR (~32%) | ~500 EUR-equivalent (~1%) |
The comparison above uses a 50,000 EUR earner, but EFKA's real bite is on the freelancer earning far less. A Greek self-employed person invoicing 15,000 EUR still owes roughly the same 3,129 EUR in EFKA contributions as the 50,000 EUR earner in the table, because the charge is a fixed monthly amount tied to a chosen category, not a percentage of turnover. On a lean year, EFKA alone can consume a fifth of everything invoiced before income tax is even calculated. That is the number worth knowing before assuming the Greek "before" figure is only about the 39% bracket.
Does Georgia's 1% actually apply to your income in the first place
The Greek-side math only matters once the 1% genuinely applies, which is a Georgian-side question first. Small Business Status taxes Georgian-source income, and for a services business that generally means work physically performed in Georgia or income earned while you are genuinely a Georgian tax resident - not work invoiced through a Georgian registration while sitting in Athens. We cover the full mechanics in Georgia's 1% tax and the source test specifically in Georgian-source income rules, and neither changes for a Greek national. Consulting activities, including tax consulting, sit outside the regime entirely regardless of nationality.
What Greece does when you leave
Greek tax residency under Article 4 of Law 4172/2013 is tested two independent ways, confirmed on AADE's own guidance summarised by PwC: spending more than 183 cumulative days in Greece in a 12-month period, or having your permanent home, habitual abode, or centre of vital interests there. Either one alone is enough to keep you Greek-resident, so genuinely leaving means closing both - the day count and the personal and economic ties.
Leaving is also not automatic. A departing taxpayer files Form M0 with attachments M1 and M7 by 10 March of the year following departure, then supplies secondary evidence - a foreign tax residency certificate, a rental contract, utility bills, a local work certificate - by 10 September if the certificate is not yet available. The tax office has two months to respond, and the burden of proof sits with the taxpayer throughout: you have to show your family, work and vital interests moved, not merely assert it. Treat this filing as part of the move itself, not paperwork to get to later.
A regime that comes up constantly in this conversation is Article 5A, Greece's own non-dom programme: a flat 100,000 EUR annual charge on foreign-source income for people who transfer their tax residence into Greece and invest at least 500,000 EUR locally. It is worth naming precisely because it does nothing for the reader of this guide - it is built for wealthy individuals moving into Greece, not a route available to a Greek national moving out. If you have seen it mentioned as an alternative to leaving, it is not one.
Greek CFC rules under Article 66 are the sharper technical point. They reach a foreign entity where a Greek resident holds more than 50%, its effective tax rate falls below half the Greek corporate rate (roughly 11%), and at least 30% of its income is passive. A Georgian Individual Entrepreneur has no separate legal personality, so Article 66 generally has no foreign company to attribute profit from. A Georgian LLC is different: it clears the rate test easily given Georgia's 0% treatment on retained profit, so real, active service income to unrelated clients - not the automatic EU/EEA substance exemption, which does not extend to Georgia - is what actually keeps a genuinely trading LLC out of scope.
Georgia is also absent from Greece's published preferential-tax-regime and non-cooperative-jurisdiction lists, which run mostly to small offshore centres and a handful of EU members with low headline rates, and the treaty is confirmed in force on Georgia's Ministry of Finance list - see Georgia's double tax treaties for how the tie-breaker actually gets invoked. Neither list changes the CFC analysis above, but their absence rules out an additional blacklist penalty on top of it.
EFKA contributions stop once you formally cease Greek business activity - deregistering with the tax authority and closing your EFKA registration - the same way the tax filing obligation does. There is no ongoing multi-year EFKA tail once that step is genuinely completed.
The steps, in order
- Confirm your activity qualifies. Georgia's Small Business Status excludes consulting, legal, medical, auditing and licensed activities outright - check your registered activity against that list before anything else.
- Decide between an IE and an LLC. An Individual Entrepreneur generally sits outside Article 66's CFC test; an LLC needs the passive-income and control thresholds checked properly first, since the automatic EU/EEA exemption does not reach Georgia.
- Register the Georgian structure. In person this runs a few days; under power of attorney through remote company registration it runs two to three weeks.
- Genuinely relocate your vital interests, not just your invoicing address - family, home, and the bulk of your economic ties.
- File Form M0 with M1 and M7 by 10 March of the year after departure, and gather your Georgian tax residency evidence early.
- Supply secondary evidence - a Georgian tax residency certificate, lease, utility bills - by 10 September if the certificate is not ready by March.
- Deregister EFKA and your Greek business activity once the move is genuine, to stop both filings and contributions.
- File your final Greek return covering the stub period you were still resident that year.
- Set up Georgian monthly compliance - the declaration cycle starts immediately and does not wait for Greek paperwork to clear.
Timeline and cost
The Georgian side is the fast part: an IE with Small Business Status typically registers within days in person. The Greek side sets the real pace - the M0 filing runs on a fixed annual calendar, and the tax office has two months to respond once your file is complete. Budget several months for the Greek transfer overall, and run the two in parallel rather than in sequence.
We'll work through your Article 4 residency position, whether an IE or an LLC makes more sense given Article 66's CFC test, and what your Form M0 filing actually needs to show, before you register anything here. Written summary included.
See what it costs
The verdict for a Greek national
Georgia is a strong fit for most Greek freelancers and IT contractors. The treaty is in force, Georgia sits outside Greece's blacklist-style catalogues, and an IE generally clears Article 66 without difficulty. The real work is procedural rather than legal: filing Form M0 properly and on time, with evidence that actually shows the move.
The one caveat worth carrying into the decision is EFKA, not the headline tax rate. It is a fixed cost that hits a modest earner harder, proportionally, than a comfortable one, which means the case for moving is stronger the higher your turnover already is - and still genuinely strong even below that, given how far 1% sits from anything Greece charges.
For the Balkan neighbour with the closest domestic analogue to Georgia's own regime, see moving from Czechia to Georgia. Our full country-by-country guide compares the treaty position and headline trap across every country we cover, and a free consultation is the fastest way to check whether your specific numbers change any of the conclusions above.
Key takeaways
- Greek tax residency breaks only if both the 183-day test and the centre-of-vital-interests test fail - either alone keeps you Greek-resident.
- Leaving Greece requires filing Form M0 by 10 March and supporting evidence by 10 September, with the burden of proof on you throughout.
- EFKA is a fixed monthly charge of roughly 250-260 EUR, not a percentage of income - it hits a lean year almost as hard as a strong one.
- Article 5A's non-dom regime is for people moving into Greece. It offers nothing to a Greek national moving out.
- Article 66 CFC rules can reach a Georgian LLC, since the automatic EU/EEA substance exemption does not extend to Georgia; a Georgian IE generally sits outside the test entirely.
- Georgia is absent from Greece's preferential-regime and non-cooperative-jurisdiction lists, and the treaty between the two countries is in force.
Frequently asked questions
Does registering a Georgian IE automatically end my Greek tax residency?
No. Greek tax residency under Article 4 depends on your day count and your centre of vital interests, not on registering a foreign business. You also have to file Form M0 to formally change your status - without it, the Greek tax authority has no record that you have left.
What is the burden of proof when leaving Greece?
It sits with you, not the tax office. When you file Form M0, you are required to prove - with a foreign tax residency certificate, a lease, utility bills, or equivalent evidence - that your family, work and vital interests have genuinely moved, rather than simply asserting that they have.
Does Greece have an exit tax like some other EU countries?
Not in the way France or the Netherlands do. There is no deemed disposal of unrealised gains purely on ceasing Greek tax residency. The mechanism that matters for most readers of this guide is the residency test and the M0 filing, not a capital gains charge at departure.
Can I use Greece's non-dom regime instead of moving to Georgia?
Article 5A is built for people transferring their tax residence into Greece, with a 500,000 EUR local investment requirement, in exchange for a flat 100,000 EUR annual charge on foreign income. It is not available to a Greek national who already lives in Greece and is not relevant to someone planning to leave.
Do Greek CFC rules reach a Georgian Individual Entrepreneur?
Generally not. Article 66 is built to reach a foreign corporation controlled by a Greek resident. A Georgian IE has no separate legal personality - it is the individual trading under their own name - so there is no separate entity for the rule to attribute profit from.
Do Greek CFC rules reach a Georgian LLC?
They can, if a Greek resident controls more than 50%, the effective tax rate is below roughly 11%, and at least 30% of income is passive. Genuine, active service income to unrelated clients is the strongest defence, since the automatic EU/EEA exemption does not extend to Georgia.
Is Georgia on Greece's tax haven or preferential-regime list?
No. Georgia does not appear on either Greece's non-cooperative-jurisdictions catalogue or its preferential-tax-regime list, both updated annually and both running mostly to small offshore centres and a handful of low-rate EU members.
How much does EFKA actually cost?
Most newly self-employed people land on Category 1, currently 250.77 EUR a month plus a flat 10 EUR OAED charge - about 3,129 EUR a year, fixed, regardless of how much you actually earned that year. It is the single biggest reason the real Greek "before" number is closer to 32% than the 39% top bracket alone would suggest.
Is there a tax treaty between Greece and Georgia?
Yes, and it is in force, confirmed on Georgia's Ministry of Finance treaty list. That gives a working tie-breaker for resolving a genuine dual-residency dispute, on top of everything the domestic Article 4 test already settles in most cases.
Should a Greek freelancer register an IE or an LLC in Georgia?
For most solo freelancers, an IE is the simpler, lower-risk choice, since it generally sits outside Article 66's CFC test entirely. An LLC makes more sense with partners or significant reinvested profit, but it brings the CFC passive-income and control tests into play in a way an IE does not, and it is worth checking properly before registering either.