Chris Rokos, founder of Rokos Capital Management, is preparing to change his tax residence from the United Kingdom to Greece and to open an office in Athens. Rokos paid an estimated £330 million in UK tax in the most recent year, placing him as the third‑largest taxpayer on the Sunday Times Tax List and giving him a reported net worth of £3 billion.
Greece’s flat‑tax regime
Under Article 5A of Law 4172/2013, individuals who transfer tax residence to Greece can elect a fixed annual tax of €100 000 on all foreign‑source income. The rate applies for up to 15 fiscal years, regardless of the amount earned abroad.
Eligibility criteria
- The applicant must not have been a Greek tax resident for seven of the eight years preceding the move.
- Within three years of applying, the individual must invest at least €500 000 in Greek property, businesses, or securities.
- Each dependent adds €20 000 per year to the flat‑tax bill.
Application process (as described by Christos Vardikos, Vardikos & Vardikos, Athens)
- Appoint a proxy to obtain a Greek tax identification number.
- Open a Greek bank account and transfer €600 000 in the applicant’s name.
- €500 000 satisfies the investment requirement.
- €100 000 covers the first year’s flat tax, payable when the status is granted.
- Provide the UK tax reference and the most recent UK tax return.
- Existing Greek property can be counted toward the €500 000 investment in certain cases.
- Submit the application online; the funds only need to be demonstrably available on the application date and are not blocked.
Residence permits and citizenship options
The tax election is separate from the right to live in Greece. British citizens must first obtain a national visa and then a temporary residence permit. Common routes include:
- Golden visa – investment‑linked residence permit.
- Financially independent person permit.
- Digital nomad visa.
Descendants of Greek emigrants in the UK, the United States, Australia and elsewhere can also acquire Greek citizenship by descent, eliminating the need for a residence permit.
End of the UK non‑dom regime
From 6 April 2025, HMRC abolished the UK’s remittance‑basis non‑dom system and replaced domicile with tax residence as the basis for worldwide taxation. All UK residents now pay tax on global income and gains as they arise.
- Foreign‑income relief is available only during the first four years of UK residence, and only for individuals who have spent at least 10 consecutive tax years outside the UK beforehand.
- Inheritance tax now applies to “long‑term UK residence,” defined as residence in at least 10 of the previous 20 tax years before a chargeable event. Non‑UK assets remain subject to UK inheritance tax for a minimum of three years after the individual leaves, extending by one year for each additional year of residence beyond 13.
These changes have triggered an outflow of high‑net‑worth Britons to jurisdictions such as Dubai, Switzerland and Monaco, according to the Sunday Times Rich List.
Comparative flat‑tax options
- Italy – from the start of 2026, a flat tax of €300 000 per year for new residents (2026 Budget Law).
- Switzerland – cantonal lump‑sum taxes ranging from CHF 250 000 to CHF 1 million annually, negotiated per canton.
Vardikos and Thessaloniki‑based lawyer Christina Georgaki consider Greece’s €100 000 flat tax the most attractive current offering for European high‑net‑worth individuals.
Potential UK tax exposure after relocation
Changing tax residence does not automatically terminate UK tax obligations. If Rokos has been a UK resident for 10 of the past 20 tax years, his non‑UK assets will remain within the scope of UK inheritance tax for several years after establishing the Athens office, potentially extending the exposure depending on the length of his prior UK residence.
Rokos Capital Management, which manages roughly US$20 billion, already operates offices in Abu Dhabi, London, New York and Singapore. The move to Greece adds a European hub while navigating the complex interaction between Greek flat‑tax benefits and lingering UK tax liabilities.
Source article: www.imidaily.com
