Americans moving to Greece are usually remote employees, freelancers with US clients, or retirees. Unlike other movers, you never leave your home tax system: you file in both countries. This guide covers both sides and how they interact.
The short answer
- You keep filing Form 1040 every year. The US taxes citizens wherever they live, and the 1950 treaty does not change that.
- Double tax is avoided on the US return, through the Foreign Earned Income Exclusion (up to $132,900 for 2026) or the Foreign Tax Credit for Greek tax paid.
- Social security is paid once: under the 1994 totalization agreement, freelancers living in Greece pay EFKA, not US self-employment tax.
- FBAR and Form 8938 report your Greek accounts to the US. Greek banks report you too.
- Your state may still claim you unless you break residence or domicile there.
- In Greece: Article 5C or the 7% retiree rate can lower Greek tax; if you rely on the foreign tax credit, the US can take part of a 5C saving back.
1. The US side: you keep filing
US citizens abroad report worldwide income, even when all of it is excluded. If you live abroad on April 15, you get an automatic two-month extension to June 15; interest on unpaid tax still runs from April 15.
Two tools prevent double taxation:
- Foreign Earned Income Exclusion (Form 2555). Excludes foreign earned income, up to $132,900 per person for 2026. You qualify through the physical presence test (330 full days abroad in 12 months) or the bona fide residence test (residence abroad for a full tax year). It covers salary and self-employment income, not pensions, dividends or rent; Form 2555 also carries the foreign housing exclusion.
- Foreign Tax Credit (Form 1116). Offsets US tax with Greek income tax on foreign-source income. The credit is capped at the US tax on that income; unused Greek tax carries back one year and forward ten. You cannot claim a credit on income you excluded (Publication 54).
Which works better depends on your income mix and your Greek tax; that is your US preparer’s call. Note that excluded income still counts when the IRS sets the bracket for the rest of your income, and once you revoke the exclusion you generally cannot use it again for five years without IRS consent.
2. The 1950 treaty and its saving clause
The US–Greece income tax convention was signed in Athens on 20 February 1950. Article XIV(1), the saving clause, lets each country tax its own citizens and residents as though the treaty did not exist. For Americans in Greece, the treaty does not reduce US tax; relief on the US side comes from the credit or the exclusion. In the other direction, Greece credits US tax on US-source income (Article XIV(3)).
It has no Social Security article; Article XVIII provides for exchange of information. The US and Greece also have an estate tax treaty, but no gift tax treaty.
3. FBAR, FATCA and your Greek bank account
- FBAR (FinCEN 114): required if your foreign accounts together exceed $10,000 at any time in the year. Filed with FinCEN, not with your return; due April 15, automatically extended to October 15 (IRS comparison).
- Form 8938 (FATCA): filed with your return. For taxpayers living abroad, the threshold is above $200,000 at year end or $300,000 at any time (single), $400,000 / $600,000 for joint filers.
Under the Model 1A FATCA agreement, Greek banks report US persons’ accounts to AADE (the Greek tax authority), which forwards the data to the IRS. Expect US-person questions at account opening; see opening a bank account in Greece. Be careful with Greek and other EU investment funds: for US persons they are usually PFICs, with harsh US tax treatment and an annual Form 8621.
4. Social Security: the totalization agreement
The US–Greece social security agreement has applied since 1 September 1994.
- Self-employed: covered only by the country where you live. Living in Greece, you pay EFKA, request a certificate of coverage from the Greek fund and attach a copy to your US return each year. Without it, US self-employment tax applies once net earnings reach $400, exclusion or not.
- Employees posted by a US employer for up to five years can stay in US Social Security with a certificate (USA/GR 1) the employer requests from SSA. If you moved on your own and simply work remotely from Greece, you are not posted: the work-location rule normally puts you under Greek social security (EFKA).
- Benefits: US citizens can keep receiving Social Security in Greece; up to 85% stays subject to US income tax. As a Greek tax resident you also declare the benefit in Greece.
5. State tax: leaving your state
State tax follows residence and domicile, and some states keep taxing you abroad. California, for example, treats a domiciliary who is away for a temporary purpose as still resident, with a safe harbor for employment contracts abroad of at least 546 consecutive days.
6. Where each type of income ends up
| Income or topic | Taxed where | What to file |
|---|---|---|
| Freelance income earned in Greece | Greece; US with exclusion or credit | Greek E1 + E3; Form 1040 with 2555 or 1116 |
| Salary from a US employer, working from Greece | Greece once you are resident; US with exclusion or credit | Greek return; Form 1040 |
| Social security contributions | One country only (totalization) | EFKA + certificate of coverage attached to 1040 |
| US rental property | US; Greece taxes residents’ worldwide income, with credit | Schedule E; Greek return |
| US Social Security | US (up to 85%); declared in Greece, which generally credits US tax | Form 1040; Greek return |
| Greek and other foreign accounts | Reporting only | FBAR; Form 8938 above thresholds |
7. Residence routes and the tax side
Beyond 90 days in 180, Americans need a national visa and residence permit. The routes that shape your tax setup:
- Digital Nomad Visa: €3,500 net per month, work only for employers and clients outside Greece. DNV holders cannot use Article 5C (5C vs the Digital Nomad Visa, DNV guide).
- Financially independent person permit: €3,500 per month of stable income, no right to work. The usual retiree route.
- Golden Visa: €800,000 in Attica, Thessaloniki, Mykonos, Santorini and larger islands, €400,000 elsewhere, or €250,000 for certain conversions to residential use and listed-building restorations.
- Employment or self-employment permits: the routes into Article 5C.
8. The Greek side
You become Greek tax resident with your main home or centre of life here, or after 183 days in a 12-month period. Step one is your AFM, also needed before buying property (AFM for buyers). Income tax runs from 9% to 44%; the return is filed mid-March to 15 July.
Freelancers register a business, join EFKA by the 10th of the month after starting (new starters €150.46 per month plus €10 for most freelancers; lowest standard class €250.77), file VAT monthly for the first 24 months and pay a tax advance on next year’s tax (55%, halved in the first year with business income). Mandatory B2B e-invoicing is being phased in from 2 November 2026; check with your accountant when it applies to invoices to US clients. Steps: freelancer setup, EFKA guide.
Article 5C exempts 50% of Greek employment or business income for seven years, if you were not Greek tax resident in 5 of the last 6 years and take a Greek job or register a business here (how 5C works). The move must come from a tax cooperation state; for the US that rests on the treaty’s information exchange and the FATCA agreement, so confirm it when you apply.
Article 5B taxes retirees’ foreign income at 7% for 15 years, if you were not Greek tax resident in 5 of the last 6 years; apply by 31 October of the year you want it to start (A.1192/2026) (7% flat tax guide).
The US catch. The foreign tax credit only counts Greek tax actually paid. When 5C lowers Greek tax on foreign-source earnings, your US credit falls too, and the US may collect the difference. US-source pensions and Social Security are taxed by the US either way, so 5B mainly removes the Greek top-up. If you plan to own a Greek company (IKE), check the US side first: US owners of foreign companies usually face extra filings (Form 5471) and US tax on company profits.
How we can help
At taxomade, we prepare and file the Greek side: tax residency, business registration, the 5C or 7% application, and monthly bookkeeping from €89/month. Your US return, FBAR and state exit stay with your US tax preparer; we can share the Greek figures and documents they need. Send us a message on WhatsApp or through the form.
Frequently asked questions
Do I still have to file US taxes if I live in Greece?
Yes. The US taxes citizens on worldwide income wherever they live, and the 1950 treaty’s saving clause keeps it that way. You file Form 1040 every year (automatic extension to June 15 when abroad) plus a Greek return once you are Greek tax resident.
Should I use the Foreign Earned Income Exclusion or the Foreign Tax Credit in Greece?
It depends on your income mix. The exclusion (Form 2555, up to $132,900 for 2026) covers earned income only. The credit (Form 1116) offsets US tax with Greek tax actually paid, so it shrinks when Article 5C lowers your Greek tax. A US preparer should compare both.
Do I pay US self-employment tax if I freelance in Greece?
No, if you are covered by EFKA. Under the totalization agreement in force since 1 September 1994, self-employed people living in Greece are covered only by Greece. Attach the Greek certificate of coverage to your US return each year.
Can Americans get Greece’s 50% tax break (Article 5C)?
Generally yes, if you were not Greek tax resident in 5 of the last 6 years, take a Greek job or register a business in Greece and stay at least two years. Digital Nomad Visa holders are not eligible. If you use the foreign tax credit, the US can take part of the saving back.
Is my US Social Security taxed in Greece?
The 1950 treaty has no Social Security article. US citizens stay subject to US tax on up to 85% of benefits, and as a Greek tax resident you also declare them in Greece, which generally credits US tax on US-source income. How this works with the 7% retiree regime needs an individual check.
Rules as of October 2026. US and Greek rules change; check the current figures before you act.