Greece for Fund Managers: Article 96, Regime 5C and the Athens Relocation Case

In the second week of September 2026 the Financial Times and Bloomberg reported, within days of each other, that Chris Rokos, founder of the London macro hedge fund Rokos Capital Management, had moved his tax residency from the United Kingdom to Greece; that Millennium Management had registered an Athens office in July; and that Veriton and Elan Capital were in talks with the finance ministry about following. Bloomberg traced the plan to November 2025, when ministry officials opened discussions with Millennium about what it would take to bring a large, highly regulated manager to Athens. The result was a piece of legislation passed quietly in June, after consultation with the industry, which set the carried interest tax in Greece at 5 percent for a very specific group of people: those who manage international capital for a living.

This article explains that legislation in plain terms, works through a realistic example, sets Greece against its competitors, and then turns to the question that concerns us as advisers on residential property: where these families will live.

How a fund manager earns money

A hedge fund or private equity firm gathers capital from investors, pension funds, insurers, family offices and wealthy individuals, and invests it on their behalf. The capital belongs to the investors. The manager is paid in two ways, known in the industry as “two and twenty”.

The “two” is the management fee: roughly 2 percent of the capital each year, paid regardless of performance. It funds the firm’s offices, analysts, traders and salaries. Salaries and ordinary bonuses come out of this fee and are taxed as employment income.

The “twenty” is the performance fee, or carried interest: when the fund’s returns exceed an agreed threshold, the manager keeps around 20 percent of the profit above it. On a €1 billion fund returning 10 percent in a year, that is roughly €20 million, shared among the founder and the senior partners according to their contracts. In a poor year it is zero. Because it is variable, contingent and at risk, most jurisdictions have debated for decades whether it is salary or a capital gain. Greece has now answered the question in statute.

The three provisions

Article 96 of Law 5313/2026 amends the Income Tax Code so that carried interest and performance fees paid under a contractual right are treated as capital gains. For fund professionals who relocate to Greece, the rate is a flat 5 percent, against the standard 15 percent, for seven tax years. Three conditions apply. The individual takes employment with a company established in Greece that provides services to an affiliated fund manager, itself established in the EU or in a supervised, cooperative third country. The individual transfers tax residence under Regime 5C on the basis of that employment. And the Greek company spends at least €3 million a year in Greece, a substance test designed to reward firms that build a genuine Athens operation rather than a nameplate. A point of precision: both the FT and Bloomberg describe the 5 percent as covering carried interest and bonuses; the statute covers carried interest and performance fees under a contractual right. Ordinary bonuses remain employment income.

Regime 5C exempts 50 percent of employment income from Greek tax for seven years for executives who arrive from abroad, take a new position in Greece and commit to stay. Unlike its Italian equivalent, the exemption carries no income ceiling.

Article 97 of the same law addresses the question that matters most to the firm rather than the individual: the provision of portfolio management or advisory services by a Greek company to a foreign fund manager creates neither a place of effective management nor a permanent establishment in Greece for the fund or its manager. The fund stays taxed where it is domiciled. Greece taxes the Athens service company on its own profits, the executives on their income, and leaves the fund alone. Elsa Littlewood of BDO described this to the FT as the key differentiator from Italy, where the equivalent question remains open to the judgement of the tax authorities. Vasilis Karatzas, the adviser to finance minister Kyriakos Pierrakakis who designed the package, told Bloomberg that the Athens companies and their employees are taxed normally and that the objective is high-quality jobs, the return of Greek talent and a new ecosystem, rather than a tax haven.

The founder, whose income comes largely from personal capital held abroad, follows a different path: the Article 5A Non-Dom election, with its flat €100,000 annual charge on all foreign-sourced income, which we describe in detail in our guide to the Greek Non-Dom Program. The complete architecture, as it is being built for the first arrivals, is therefore twofold: the principal under 5A, the team under 5C and Article 96, and an Athens company that activates the Article 97 protection for the fund.

A worked example: a senior partner leaves London

Consider a partner and portfolio manager, aged 48, married with two children at school, who has just been asked to open his firm’s Athens office. Salary €1 million. Share of carried interest €10 million in a strong year. A personal portfolio held outside the UK returning €3 million a year.

London: The UK abolished its non-dom regime in April 2025 and now taxes residents on worldwide income. His salary is taxed at the 45 percent additional rate plus national insurance, roughly €470,000. His carried interest, under the rules in force from April 2026, is taxed at an effective rate near 34 percent, around €3.4 million. His personal portfolio adds approximately €1 million. Total: close to €4.9 million a year. His worldwide estate is also exposed to inheritance tax at 40 percent.

Athens: Half his salary is exempt under 5C; the remaining €500,000 is taxed on the standard scale, roughly €210,000. His carried interest is taxed at 5 percent under Article 96, €500,000. His personal portfolio is taxed at Greece’s ordinary rates on investment income, 5 percent on dividends and 15 percent on interest and capital gains, in the region of €350,000. Total: approximately €1.1 million a year. Foreign assets are exempt from Greek inheritance tax.

The difference is about €3.8 million a year, and close to €26 million over the seven-year life of the regime. That is the order of magnitude at which a family changes country, and at which a firm justifies the €3 million of annual Athens expenditure the law requires. The office is paid for by the tax differential of a single partner.

The competition

Wealth leaving London has three serious European alternatives and one in the Gulf. For the working partner in our example, they compare as follows.

Italy offers the regime impatriati: a 50 percent exemption on employment income, capped at €600,000 of income, for five years. Above the cap, full IRPEF at 43 percent plus regional surcharges. Carried interest is taxed at 26 percent as financial income, provided the manager has invested at least 1 percent of the fund personally, the carry is paid only after investors recover capital and hurdle, and the interests are held for five years. Italy’s flat tax on foreign income, the counterpart of Greece’s 5A, was introduced at €100,000 in 2017 and has since been raised twice, to €300,000 from 1 January 2026, plus €50,000 per family member; Greece has held its €100,000 rate unchanged since 2019, a point Bloomberg singled out as the predictability relocating families look for. On our partner’s numbers, Milan costs roughly €3 million a year, for five years, with the fund’s own tax residence left to the discretion of the authorities.

Switzerland reserves its lump-sum taxation for residents who do not work in the country. A partner running money from Zug pays ordinary cantonal and federal tax on salary and carry alike, around 25 percent in the cheapest cantons and over 40 percent in Geneva. On our numbers, roughly €3 million in Zug and more than €4 million in Geneva.

Dubai levies no personal income tax. The arithmetic is unbeatable; the trade is distance from Europe, a different schooling landscape and a different life from the one the family chose when it settled in London. Bloomberg adds a newer consideration: since the outbreak of hostilities between the United States and Iran in February 2026 and the retaliatory strikes on the Emirates, recruiters report that some traders and their families are reconsidering the Gulf and looking for alternatives, even as Abu Dhabi and Dubai continue to grow.

Greece combines the lowest flat tax in Europe for the principal (€100,000, with €20,000 per family member), the lowest rate on carried interest for the team (5 percent), the longest window among the European regimes (seven years), statutory protection for the fund, and a capital three hours from Heathrow. Karatzas put the government’s intention plainly to the FT: the aim is to bring real businesses to Greece.

Where they will live

Both wires named the same constraint. The FT pointed to the supply of executive-grade housing, high-quality office space and international school places in Athens. In Bloomberg, Dimitrios Andriopoulos of Dimand, the Athens developer, called residential property of the standard these professionals expect, with private schools close to it, the number one challenge of the moment. Inspired Education, which acquired the Moraitis and Costeas-Geitonas schools in 2024, is building a third, 1,300-place campus at the Ellinikon for exactly this reason.

Our transaction data shows where relocating wealth lands. Non-dom buyers rose from no meaningful presence before 2024 to 29 percent of our transaction volume in 2025; 53 percent of them hold British passports; 88 percent of their purchases are on the Athens Riviera, at a median value of €2.95 million. A partner arriving under Article 96 fits this profile precisely: a primary residence of institutional quality, within reach of the new international school at the Ellinikon, the private hospitals of the southern suburbs and the airport. Vouliagmeni, Voula and Glyfada, together with the Ellinikon itself, are where the first wave will look. The northern suburbs of Psychiko and Filothei, closer to the established international schools, are the alternative for families who prefer greenery to sea.

For a family whose annual tax saving approaches the median price of a Riviera home, the property decision is the last piece of the relocation and the one that determines whether the move feels like a gain in life rather than only a gain on paper. Advising on that decision, with verified data rather than estimates, is what we do.

Frequently Asked Questions

Are there tax incentives for hedge fund and private equity managers relocating to Greece?
Yes. Article 96 of Law 5313/2026 taxes carried interest and performance fees at a flat 5 percent for seven years for professionals who take employment with a Greek entity servicing an affiliated foreign fund manager and relocate under Regime 5C, provided the Greek entity spends more than €3 million a year in Greece. Regime 5C separately exempts 50 percent of employment income for seven years.

Does moving a fund manager to Greece make the fund taxable in Greece?
Article 97 of the same law provides that services rendered by a Greek company to a foreign fund manager create neither a place of effective management nor a permanent establishment in Greece for the fund or the manager. The fund’s tax residence stays where it is.

Which funds have moved to Athens so far?
As reported by the Financial Times and Bloomberg in September 2026: Rokos Capital Management, whose founder transferred his tax residence to Greece; Millennium Management, which registered an Athens office in July 2026; and Veriton and Elan Capital, in talks with the finance ministry.

Can the founder and the team use different regimes?
Yes. The principal, with income mainly from personal capital abroad, typically elects the Article 5A Non-Dom regime (€100,000 flat). Employees relocating for a role in the Athens entity use Regime 5C and Article 96. The two are separate elections.

How does Greece compare with Italy for a working fund manager?
Greece exempts half of salary with no ceiling for seven years and taxes carry at 5 percent; Italy exempts half of salary up to €600,000 for five years and taxes carry at 26 percent under conditions. Italy’s flat tax on foreign income is €300,000 against Greece’s €100,000.

Where do relocating fund professionals buy in Athens?
Our records show 88 percent of non-dom purchases on the Athens Riviera, with a median value of €2.95 million. Vouliagmeni, Voula, Glyfada and the Ellinikon lead demand; Psychiko and Filothei are the northern alternative.

Further reading from the Intelligence Hub.

This analysis is part of our ongoing coverage of the relocation of private wealth to Greece. For the underlying data, see The State of Greek Luxury Property — Mid-Year 2026, our half-year market report (full edition on Issuu), and The Greek Non-Dom Program: Why Global Wealth Is Choosing Greece for the Article 5A regime that applies to fund principals. All reports are available in the Intelligence Hub.

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This article provides general information and does not constitute tax or legal advice; individual circumstances require qualified counsel.