A European passport decides where you are allowed to move and where you are allowed to work. The Greek property transfer tax, in the wording published this month, asks a different question: where do you pay tax.
“So the passport is worth nothing?”
Yoav asked me this on the phone on Tuesday evening, October 20, and I could hear the dishwasher running in the background. There was no anger in his voice. There was the surprise of someone who had built a plan on one assumption, and now someone was pulling it out from under his feet.
That assumption was one I had given him.
In early September, days after the Greek government announced that the transfer tax for foreigners would rise from 3% to 15%, Yoav sent me a WhatsApp photo of the first page of his Portuguese passport. Under the photo was a single line: “I'm covered, right?” I said yes. Every report in those weeks talked about citizens of countries outside the EU, and I too, when I was interviewed by Walla Money on October 12, said that an Israeli with an additional European citizenship would pay 3%, and an Israeli without one would pay 15% on exactly the same apartment.
Yoav is not a reckless investor. He is a fifty-two-year-old electrical engineer from Kfar Saba who obtained his Portuguese passport in 2021 through his mother's family roots. He already owns one apartment in Athens, since 2023, on a quiet street below Philopappos Hill. It is let on a long-term lease, he knows the members of the building committee by name, and he reads every report the property manager sends him to the end. This summer he decided on a second apartment, three rooms in a 1970s building in Pangrati, for 287 thousand euros. In August he signed a preliminary agreement and paid a ten percent deposit.
On October 18 the Greek Ministry of Finance put the bill “Strengthening disposable income, savings and investment” out for public consultation. By the day Yoav called, I was already sitting in front of the section itself. Under Section 16 of the published wording, from July 1, 2027 the transfer tax on a residential apartment rises to 15% of the value when the buyer is a private individual who is tax resident in a country outside the European Union and the European Economic Area. For everyone else the tax stays at 3%.
But notice that word. Resident.
Not citizen. Under the wording, what counts is the buyer's tax residency at the moment the tax liability arises, and the passport does not appear in the section at all. An Israeli with a Portuguese passport who lives and works in Kfar Saba is, as a rule, tax resident in Israel. An Israeli with no European passport at all, who has moved to Cyprus and pays tax there, may pay 3%.
There are also two things the section does not do. It does not touch the preliminary agreement, because the new rate applies to final deeds signed from July 2027 onward. And it is not yet law. The consultation closes tomorrow, November 1, and after that the bill goes to parliament, where the wording can still change.
After the call I opened the preliminary agreement Yoav had sent me in August. On the second page, in the clause on the date of the final deed, it said September 15, 2027. That date was not dictated by the seller. Yoav asked for it himself, because in summer 2027 a package of his shares vests, and he planned to pay the balance from that money. It is an entirely sensible cash-flow decision, and under the new wording it costs 34,440 euros, the difference between 3% and 15% on a value of 287 thousand.
“So the problem isn't the passport,” he said when we spoke again the next day. “The problem is the date I chose.”
What we did next took ten days. The lawyer who works with me in Athens approached the seller's lawyer and asked to bring the final deed forward to the end of May 2027. The sellers, a retired couple moving to live near their daughter on Crete, did not object to the date, but in return asked for an additional twenty percent deposit right now. Yoav, whose shares vest only in July, will have to pay the balance in May, so he arranged a two-month bridging loan in Israel. We also asked for a clause under which, if the deed is postponed past June 30 through the sellers' fault, they bear the tax difference. They agreed, but only up to a cap of ten thousand euros.
As of today, the deed is set for May 27, 2027. The interest and fees on the bridging loan, together with the legal fees for the addendum to the agreement, will cost Yoav about 5,300 euros. If parliament changes the wording, he may have paid for insurance he will not need.
“I'd rather pay five thousand for a question,” he told me, “than thirty-four thousand for an answer.”
I was wrong in September, and I told him so in that same call. I answered the question the press was asking, instead of waiting for the written wording. But what caught me in this story is not my mistake. It is the many Israelis who hold a European passport like an insurance policy, and assume it covers every risk connected to Europe. The passport covers a lot: the right to live, to work, to study. Tax is a different matter, and it is usually determined by where you actually live. The passport says where you are allowed to move. Tax asks where you sleep at night.
The question I would ask in your place
- In which country will I be tax resident on the day the final deed is signed, and what do I hold in hand that proves it?
- What date for the final deed is written in my preliminary agreement, and what happens if it slips past June 30, 2027?
- How much am I willing to pay now, in interest on a bridging loan or in a deposit I brought forward, to sign earlier because of a bill that has not yet passed?
Stories are based on real situations, with identifying details changed. Not legal advice.
Translated from the Hebrew original. עברית
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