Apodohi Klironomias: How U.S. Heirs Accept a Greek Inheritance

Ownership of Greek property doesn't transfer to an heir automatically. Not by will, not by intestate succession, and not by court order. If your family member died owning real estate in Greece, you must complete a formal legal procedure called the Apodohi Klironomias — the Acceptance of Inheritance — before a licensed Greek notary. Greek bank accounts and other assets follow separate bank and succession procedures. Until that deed is executed and registered, the transfer of ownership is not legally finalized.

What the Apodohi Klironomias Requires

The acceptance of inheritance is a notarial deed, not a court filing. You (or your attorney acting under a power of attorney) appear before a Greek notary with a specific set of documents:

• Apostilled and translated Greek death certificate — the Lixiarchiki Praxi Thanatou, authenticated with a Hague Apostille and certified English translation
• Certificate of non-publication of another will — issued by both the local Magistrate's Court (Eirinodikeio) and the Court of First Instance (Protodikeio), confirming that no other will has been probated
• Family status certificate (Pistopoiitiko Oikogeneiakis Katastasis) — proving the relationship between the heir and the deceased
• Property title deeds — the prior ownership documents for any real estate in the estate
• Topography plans — up-to-date survey plans for the property
• Tax clearance certificates — proving the property was registered for the Unified Property Tax (ENFIA) for the five years preceding the death

Once the notary drafts and executes the deed, it must be registered with either the local Land Registry (Ypothikofylakeio) or the Hellenic Cadastre (Ktimatologio). Ownership is legally finalized only when the registration receipt is issued.

The Tax Filing That Must Come First

Before the notary will execute the acceptance deed, the Greek inheritance tax return (Dilosi Forou Klironomias) must be filed. For heirs who reside outside Greece, the filing deadline is 12 months from the date of death. If a will was discovered and probated, the 12-month clock starts from the date the will was published by the Greek court.

The return is filed electronically through the digital portal myAADE via the myPROPERTY application. To access it, you need a Greek Tax Identification Number (AFM), which means you first need to register at the Tax Office for Foreign Residents (DOY Katoikon Exoterikou) with your certified, translated, and apostilled passport and birth certificate.

You also need to appoint a Greek Tax Representative (Forologikos Antiprosopos) — a permanent resident of Greece who receives all tax assessments, notifications, and annual property tax bills on your behalf. This is a legal requirement for non-resident heirs, not optional.

Missing the 12-month filing window triggers penalties of approximately 2.5% of the tax due for each month of delay, up to a 100% penalty cap, plus statutory interest.

Conditional vs. Unconditional Acceptance

Greek law gives heirs two options:

Unconditional acceptance makes the heir personally liable for all the deceased's debts and obligations — even if the debts exceed the value of the inherited assets. This is the default if you don't specify otherwise.

Acceptance with benefit of inventory limits your liability to the appraised value of the estate's assets. If the estate carries hidden debts, mortgages, or outstanding tax liabilities, this is the safer choice.

If the estate is clearly insolvent, you have a third option: file a formal Declaration of Renunciation (Dilosi Apopoiisis) with the competent Greek court. For heirs living abroad, the deadline is 12 months from the date you became aware of the death and your status as heir. Miss this window and Greek law treats your silence as unconditional acceptance — you inherit the debts.

Handling It from the United States

You don't need to fly to Greece for the acceptance deed. Most American heirs execute a specialized Greek Power of Attorney (Plirexousio) that authorizes a trusted Greek attorney to handle the tax filing, sign the notarial deed, and complete the cadastre registration on their behalf.

The power of attorney can be signed before a Greek consular officer in the United States, or drafted by a Greek lawyer, signed before a U.S. notary public, authenticated with a state-issued Apostille, and sent to Greece for certified translation.

The American Dies in Greece — Family Emergency Guide covers the full inheritance workflow — from securing your AFM through the notarial deed — with document checklists and a timeline that maps each step to the 12-month deadline.