Inheritance Tax Greece for UK Nationals: AFM, Diathiki, and the Cross-Border Estate

When a British national dies in Greece with assets there — a retirement property, bank accounts, even a car — the estate enters the Greek succession system. Greek inheritance tax applies to those assets regardless of the deceased's nationality, and the administrative machinery requires documents and procedures that UK families have never encountered.

How Greek Inheritance Tax Works

Greece taxes inherited assets on a sliding scale that depends on the relationship between the heir and the deceased. For close relatives (Category A — spouse, children, parents, grandchildren), the tax-free threshold is €150,000, with rates from 1% to 10% above that. More distant relatives face lower thresholds and steeper rates.

For a typical British expat who owned a property in Crete or the Peloponnese, the practical question is whether the property's declared value exceeds €150,000. Greek property values are assessed using the "objective value" system (antikeimenikes axies), which is set by the tax authority and often sits below market value — so a property that sold for €250,000 might be assessed at €180,000 for inheritance tax purposes.

For an heir resident abroad, the Greek inheritance tax return must be filed with the Independent Authority for Public Revenue (AADE/IAPR) within twelve months of the death, or, if a will exists, from the date the will is officially probated. Missing this deadline triggers penalties and interest that compound quickly.

The AFM Tax Number

Every person who interacts with the Greek tax system needs an AFM (Arithmos Forologikou Mitroou) — a tax identification number. If the deceased had one from owning property or filing Greek taxes, the heirs need it to access the estate's tax records and file the inheritance return.

If an heir does not already have an AFM, they must apply for one through the Greek tax office or appoint a Greek tax representative (typically a lawyer or accountant) to act on their behalf. This appointment requires a notarised Power of Attorney, which itself must be apostilled for use in Greece if it was executed in the UK.

The estate's Greek tax work should include checking the deceased's AFM status and any outstanding obligations with a Greek tax representative.

Greek Wills (Diathiki) and Law 5303/2026

A Greek will (diathiki) can take three forms: a public notarial will, a holographic (handwritten) will, or a secret will deposited with a notary. If the deceased left a Greek will, it governs the succession of Greek assets.

Under Law 5303/2026, which applies to deaths occurring on or after 16 September 2026, the forced heirship rules changed significantly. Previously, excluded family members received automatic physical co-ownership shares in Greek real estate — fragmenting titles and locking estates. Now, the forced heirship claim (nomimi moira) is converted into a purely monetary claim. Excluded relatives have a creditor claim for a cash payment equal to half their intestate share, but the designated heir keeps sole ownership of the property.

For UK nationals, the most important tool remains EU Regulation 650/2012. Although the UK is no longer in the EU, Greek courts still apply Brussels IV. A British national can include a "Choice of Law" clause in their English will specifying that English law governs their worldwide estate — effectively bypassing Greek forced heirship rules entirely. Without this clause, Greek succession law applies to any Greek real estate by default.

Proving Next of Kin in Greece

This is where UK families hit a wall. Greek civil registries and hospitals do not recognise a generic "next of kin" status. Greek citizens have a Family Status Certificate (Pistopoiitiko Oikogeneiakis Katastasis) that is automatically generated from the municipal Mitroo Politon register — it proves relationships in a form Greek authorities accept.

British citizens do not appear in this register. Instead, UK families must present original UK birth certificates, marriage certificates, or civil partnership certificates to prove their relationship. These UK documents are not recognised in Greece without two additional steps:

1. FCDO Apostille — the UK document must be legalised with a Hague Apostille by the Foreign, Commonwealth & Development Office
2. Certified Greek translation — by a translator registered with the Greek Ministry of Foreign Affairs or a qualified Greek Bar Association lawyer

This creates the administrative loop that catches most families: you cannot collect the death certificate because you cannot prove you are next of kin, and you cannot prove you are next of kin because your UK documents are not legalised for Greek use. Having apostilled copies of your marriage or birth certificate before travelling to Greece — or arranging them urgently by courier from the UK — breaks the loop.

UK-Side Inheritance Tax Implications

The UK-Greece double taxation treaty does not cover inheritance tax. A UK-domiciled individual's worldwide estate (including Greek assets) is subject to UK inheritance tax, and the Greek assets are separately subject to Greek inheritance tax. The UK does offer unilateral relief — you can credit Greek inheritance tax paid against the UK IHT liability on the same assets — but this requires careful coordination between a UK probate solicitor and a Greek tax representative.

The practical risk is paying twice without claiming relief, or missing the Greek filing deadline while waiting for UK probate to complete. The two processes need to run in parallel, not sequentially.

Getting the Sequence Right

The British Person Dies in Greece — Family Emergency Guide maps out the complete inheritance and estate sequence — from securing the AFM and filing the Greek tax return to coordinating with UK probate so the IHT credit works correctly. It includes a document-status tracker and estate timeline planner designed specifically for the cross-border complications UK families face.