U.S. taxes for Americans in Greece: what to file, and how to catch up.
Greek-American families, dual citizens and retirees make up a large community in Greece, and all of them still file a U.S. return every year. The U.S.-Greece tax treaty dates from 1950, and the U.S. still taxes its citizens. The details to get right are pensions, property and Greece’s special tax regimes. Most people who fell behind can catch up under the Streamlined procedures, with no penalty if they qualify.
Sound familiar?
- You got Greek citizenship through your family and moved over.
- You retired to Greece under the 7% flat tax for foreign pensions.
- You inherited property in Greece.
- Your Greek bank asked for your U.S. tax number.
How does the IRS treat Greek pensions, property and savings?
Accounts go on your FBAR once they add up to more than $10,000. What differs is how the IRS taxes them.
| Item | U.S. treatment | |
|---|---|---|
| EFKA pension | Greece taxes it, and the U.S. can too, with a credit for the Greek tax. | Mostly friendly |
| The 7% regime | It lowers your Greek tax, not your U.S. tax. With less Greek tax to credit, the U.S. bill on your pensions can be higher. | Plan ahead |
| Inherited property | No U.S. tax just for inheriting it, but a large inheritance may need Form 3520, and U.S. tax may apply when you sell. | Plan ahead |
| Rental income | Reported on your U.S. return with U.S. depreciation. Greek tax on it can usually be credited. | Report it |
| Greek funds | Usually PFICs (Form 8621), with complex reporting and tax rules. | Watch out |
| Bank accounts | Interest is taxable for the U.S., and the accounts count toward your FBAR total. | Taxable |
Which Greek investments are PFICs?
Greek mutual funds (amoivaia kefalaia) sold by Greek banks, and the European funds and ETFs Greek brokers offer. For U.S. tax they’re passive foreign investment companies, or PFICs, with their own reporting and harsh default tax rules.
- Each fund needs its own Form 8621 in most years, and gains can be taxed at the top U.S. rate plus an interest charge, unless an election was made in time.
- Not PFICs: shares of individual companies on the Athens exchange, Greek government bonds, bank deposits, and property you own directly.
- Many Greek-Americans keep investments in the U.S., which avoids the PFIC rules entirely.
What does the U.S.–Greece tax treaty actually say?
The treaty was signed in 1950 and is one of the oldest the U.S. still has in force. For Americans living in Greece, these parts matter most:
- Citizens stay taxable. The U.S. keeps the right to tax its citizens living in Greece, as under every U.S. treaty.
- Relief from double tax. The U.S. gives a credit for Greek income tax on the same income, such as a Greek salary, rent or pension.
- It predates modern pension rules, so it doesn’t defer U.S. tax on Greek pension savings the way newer treaties do.
Social security contributions are covered by a separate U.S.–Greece agreement, which generally means you pay into one system, not both. Read the U.S.–Greece tax treaty on IRS.gov.
When are Greek and U.S. taxes due?
Both tax years run January to December, so each Greek year lines up with one U.S. return. Your Greek tax assessment (ekkatharistiko) gives most of what the U.S. return needs.
| Greece | United States | |
|---|---|---|
| Tax year | January to December | January to December |
| Annual return | Filed online through Taxisnet, usually by mid-July | April 15, moved to June 15 automatically when you live abroad, or October 15 with an extension |
| Paying the tax | Withheld from salaries and pensions, with any balance paid in installments from July | April 15, even if you file later |
| Foreign accounts | Foreign income goes on the Greek return | The FBAR, due October 15, filed online |
Foreign tax credit or exclusion: which wins in Greece?
Usually the foreign tax credit for people paying normal Greek tax. Greek income tax reaches 44%, so tax on a mid-career salary is normally close to or above the U.S. tax on it.
- Special regimes change the math. The 7% regime for pensioners and the 50% exemption for workers who move to Greece both leave less Greek tax to credit, so the U.S. bill can be higher, and the exclusion, up to $130,000 for 2025, can help workers.
- Retirees on U.S. Social Security, pensions and IRAs use neither much: that’s U.S. income, outside the exclusion.
- Families with children often keep the credit, because it allows the refundable part of the U.S. child tax credit, up to $1,700 per child for 2025.
We run your returns both ways before choosing. How we compare the exclusion and the credit.
A worked example: a dual citizen in Athens
Maria was born in Chicago to Greek parents and moved to Athens in 2014. She earns €30,000, and in 2023 she inherited her grandmother’s apartment in Thessaloniki, which she now rents out. She has never filed a U.S. return.
| Item | How it’s handled |
|---|---|
| Salary | Greek tax is higher than the U.S. tax on it, so with the foreign tax credit her U.S. tax on it is $0. |
| The inheritance | Not taxed by the U.S., but over $100,000 from a non-American, so Form 3520 for 2023. |
| Rent | On her U.S. return with U.S. depreciation, with a credit for the Greek tax on it. |
| Catching up | Three years of returns and six FBARs under the Streamlined procedures, with no penalty if she qualifies. |
Catching up from Greece
Most Americans in Greece who fell behind without meaning to can catch up under the Streamlined Foreign Offshore Procedures: three years of returns, six years of FBARs and, if you qualify, no penalties. If only FBARs are missing, or you’ve moved back to the U.S., another route may fit better. See every IRS catch-up option for expats, compared.
Common questions
Do I pay U.S. Social Security tax in Greece?
Generally not if you pay into the Greek system. The U.S.-Greece totalization agreement prevents paying into both systems for the same work in most cases.
I’m a dual citizen who has never filed. Is it too late?
No. Under the Streamlined Foreign Offshore Procedures you usually file the most recent three returns and six FBARs.
I inherited property in Greece. What do I report?
Possibly Form 3520 if the inheritance is large, an FBAR for any Greek accounts you received, and rental income if you rent it out. We’ll sort out what applies.
Does the 7% regime help with my U.S. taxes?
No. It lowers your Greek tax, not your U.S. tax, and with less Greek tax to credit, the U.S. bill on your pensions can be higher. We plan around it.
Is my EFKA pension taxed by the U.S.?
It can be. Greece taxes it, and the U.S. can too, with a credit for the Greek tax so you’re not taxed twice in full.
Does Greek property tax (ENFIA) count as a foreign tax?
No. ENFIA is a tax on property, not income, so it doesn’t count toward the foreign tax credit. On a property you rent out, it can be deducted as a rental expense instead.
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