Technical article

Greece and Malta: Does It Matter That the Trust Assets Are Abroad?

Income works on a remittance basis for a resident who is not domiciled: only Maltese income and foreign income brought into Malta is taxed.

By Neil Solomon · 4 min read

Imagine a family where a father in Australia holds a trust with shares and cash in several countries. One daughter is looking at a home on a Greek island. A son is looking at Malta. Each asks whether it matters to the tax office that the trust assets are held somewhere else.

For both countries the sources say it matters a good deal, and in a favourable direction for the assets-abroad case.

Greece. Inheritance tax falls on the heir and reaches Greek-situs property only. PwC, tier B, says foreign property is outside Greek inheritance tax regardless of residency or nationality. The scale depends on the relationship. Class A, which is spouse, children and parents, pays 1%, 5% and 10% above EUR 150,000. Class B pays 5% to 20% above EUR 30,000. Class C pays 20% to 40% above EUR 6,000. Gifts of money run at 10%, 20% and 40%, and Class A has a one-time allowance of EUR 800,000 (about US$880,000).

Greece has two regimes for newcomers. The pensioner regime taxes a foreign pensioner's foreign income at 7% a year. The investor regime is a lump sum of EUR 100,000 a year for up to 15 years, with a EUR 500,000 investment and seven of the prior eight years spent as a non-resident. Relatives may join the investor regime for EUR 20,000 each, with no inheritance or gift tax. A trust payout is not a pension, so the 7% regime is a different matter from the one in this question.

On trusts, Greece treats a trust as a legal entity under a 2017 circular. Greek-source passive income of a foreign trust bears a final withholding of 5%, 15% or 20%. Look-through applies for a beneficiary: inheritance or donation tax rules are used where the payout is taxed in Greece. This comes from the Chambers 2026 guide, tier B.

Malta. There is no inheritance, estate, gift or wealth tax. A stamp duty of 5% applies to inherited Maltese property and 2% to Maltese company shares. A dwelling passing to a spouse or direct descendants is exempt. Income works on a remittance basis for a resident who is not domiciled: only Maltese income and foreign income brought into Malta is taxed. A law firm's 2023 article, tier C, says that for a trust whose beneficiaries are all resident but not domiciled, foreign trust income is taxed only when remitted, and foreign capital gains received by the trust are exempt even if remitted. The top rate is 35% over EUR 60,000. The residence programmes tax remitted income at 15%, with a minimum of EUR 15,000 for one and EUR 7,500 for the other. New rules from 1 January 2027 set a minimum of EUR 35,000.

You might say: "That sounds too easy. There must be a catch." The catch the sources show is in the details. In Greece, the income side has its own withholding rates, and the 7% pensioner regime does not fit a trust payout. In Malta, the benefit depends on leaving money outside the country, so the day the money is brought in is the day it is counted. A family that plans to spend the money in Malta meets that rule head on.

You could ask what each daughter or son will buy with the money: a home, shares, a business. Where the asset sits changes the rule in both places. You could also ask whether the family wants the heir to join the Greek investor regime for the relatives' flat sum.

This touches the next generation too. A grandchild is placed in a Class under the Greek scale, and a Maltese home passing to a descendant is exempt from stamp duty when it is a dwelling.

If you have looked at Greece or Malta for an heir, what did you find hardest to price? Share it here. Another family may be asking the same thing.

Figures are estimates for planning, based on public data. Date read: October 2026.