The decision by British billionaire Chris Rokos to move his tax residence from the U.K. to Greece has put an unusually bright international spotlight on Athens’s tax regime for wealthy foreign residents. It may also be the clearest evidence yet that the program has come of age - and that Greece can now afford to charge more for it.
Rokos is no ordinary expatriate. The British hedge-fund manager, founder and chief executive of Rokos Capital Management and a former founding partner of Brevan Howard Asset Management, has an estimated fortune of $2.3 billion, according to Forbes. His recent earnings are more striking still. Following strong performance at his firm, Rokos received £477 million in annual pay. Rokos Capital manages roughly $22 billion, placing it among the significant macro hedge funds operating in global markets.
His move therefore provides an unusually vivid illustration of what Greece offers wealthy newcomers.
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Under the country’s so-called non-dom framework, qualifying individuals who transfer their tax residence to Greece can pay a flat annual tax of €100,000 on foreign-source income, regardless of how large that income is. Among the principal conditions is an investment of at least €500,000 in Greece, made directly or, under certain circumstances, through a relative or an entity in which the taxpayer holds a controlling interest.
The investment can be made in Greek real estate, businesses or securities and must be completed within the required period. The preferential treatment can continue for as long as 15 tax years. For people whose wealth and income stretch across multiple jurisdictions, the attraction isn't merely a low tax bill. It is also certainty.
The numbers make the proposition particularly stark. A billionaire like Rokos with an estimated $2.3 billion fortune and recent annual earnings of £477 million can potentially pay €100,000 a year in Greek tax on foreign-source income under the regime, assuming the relevant conditions are met, in return for making a qualifying investment of at least €500,000.
That is where the policy question begins.
Greece introduced the regime as part of its effort to compete for internationally mobile wealth, investment and taxpayers after a decade in which the country had become better known for capital flight than capital attraction. The program also offered an appealing route for wealthy Greeks who had built careers abroad, including financiers in London, and were considering returning without subjecting their worldwide income to Greece’s ordinary tax system.
Rokos’s arrival suggests that the policy has accomplished an important part of its mission. Greece no longer needs to prove that it can appear on the shortlist of jurisdictions considered by wealthy international investors. It has demonstrated that it can attract billionaires and fund managers operating at the highest levels of global finance.
That success strengthens Athens’s hand.
The €100,000 annual levy and €500,000 investment requirement were established when Greece was still building its credentials as a destination for global wealth. The question now is whether those numbers still reflect the value of what the country is offering.
Increasing them wouldn't require abandoning the philosophy of the non-dom regime. Greece could remain competitive while asking for a larger economic return from those receiving exceptionally favorable tax treatment.
The most straightforward option would be to raise the annual flat tax. Another would be to increase the minimum qualifying investment. Better still, Athens could use a higher threshold to encourage capital toward productive parts of the economy—Greek companies, investment funds, startups, innovation and projects that create jobs—rather than allowing the economic benefit to concentrate disproportionately in passive assets such as property.
A combination of a higher annual levy and a larger investment commitment may ultimately make the most sense.
There is also a case for introducing tiers. An ultra-high-net-worth individual could face a larger annual charge or investment requirement than someone with a substantially smaller fortune. Any such system would have to be designed carefully. Simplicity and predictability are among the main selling points of non-dom regimes, and Greece shouldn't turn a tax structure that can be explained in a few sentences into another exercise in fiscal engineering.
But simplicity doesn't necessarily require offering a multimillionaire and a multibillionaire precisely the same bargain.
Rokos case indicates that Greece’s negotiating position has changed. When Athens introduced the regime, the government needed to persuade wealthy individuals that Greece was a credible place to establish tax residence. The arrival of taxpayers of Rokos’s stature suggests the proposition has become sufficiently attractive that Greece can test whether the market will bear a higher price.
