The clock that nobody starts deliberately
Greek succession does not work like American probate. There is no court appointment that opens the estate, and no executor who takes control of the assets before anyone becomes an owner. Under Greek law an heir is treated as having accepted the inheritance, assets and liabilities together, unless a formal renunciation is filed within a fixed period.
That period is four months where the deceased and the heir were both resident in Greece. It extends to one year where the heir was living abroad when the period began, or where the deceased's last residence was outside Greece. For a US family the longer year is normally the one that applies, and it sounds generous until you look at what starts it. The clock runs from the point at which the heir learns of the death and of the basis on which they are called to inherit. It does not wait for a US probate court to appoint anybody, and it is not paused by a will contest, a slow bank, or a family that has simply not got round to dealing with a house on an island.
Miss it and acceptance is deemed to have happened. That matters because acceptance is not selective. It brings whatever the property carries with it: unpaid ENFIA and municipal charges, a Greek mortgage, a co-owner's claim, and the cost of resolving building work that was never regularised. Most Greek holiday homes carry none of that, and for those families a deemed acceptance is harmless. The point is that nobody finds out which case they are in until somebody looks.
Renunciation is filed at the Magistrate's Court, the Eirinodikeio, for the district of the deceased's last residence in Greece. An heir abroad can act through a Greek consulate, or through a Greek lawyer holding a notarised power of attorney, so nobody has to fly. It is also a serious step rather than an administrative one, because renouncing passes the inheritance down the line to whoever is next in order, which can mean a sibling, a child or a grandchild who was not expecting it. Decide deliberately, and decide early.
Greek inheritance tax is far lighter than most US families expect
The Greek regime sorts beneficiaries into categories. Category A covers a spouse or registered civil partner, children, grandchildren and parents, which is where most family transfers sit. Each Category A beneficiary has a tax-free allowance of 150,000 euros, and the allowance is applied to that beneficiary's own share rather than to the estate as a whole. Above the allowance the scale is modest by any standard: 1% on the first band, then 5%, then 10% on amounts higher still.
The per-beneficiary point does a great deal of work. An apartment in Athens passing to four children is measured as four separate shares against four separate allowances, so a property assessed at 500,000 euros can pass entirely within the exemptions and produce no Greek tax at all. Set against what American families brace themselves for when a foreign country is involved, this is a strikingly light regime.
There is also an enhanced allowance of 400,000 euros per beneficiary where the deceased leaves a spouse and minor children only. For the spouse, that enhanced figure depends on a lawful marriage having lasted at least five years before the death. Whether your family fits the pattern the rule is aimed at is a question for a Greek tax advisor rather than an assumption to build a will around.
Two cautions. First, the taxable value of Greek real estate is set by an official valuation system rather than by what you believe the property would fetch, so the number the allowance is measured against is not the asking price. Second, the allowances for more distant relatives and for unrelated beneficiaries are far smaller and the rates far higher. If the plan is to leave the house to a niece, a stepchild or a friend, ask what that costs before the will is drafted rather than after.
The acceptance of inheritance is a deed, not a form
Where the estate includes Greek real estate, the heirs execute an acceptance of inheritance, the apodochi klironomias, as a notarial deed before a Greek notary. It is then registered with the Ktimatologio, the national cadastre, or with the older Hypothikofylakeio land registry in districts where the cadastre has not yet taken over. Until that deed is signed and registered, the heirs are not in a position to sell the property, mortgage it, or in practice do anything useful with it.
Assembling it is where the real time goes. Every heir needs a Greek tax number, the AFM, including heirs who have never set foot in Greece and including minors. Non-resident heirs generally need a Greek tax representative. The inheritance tax return has to be filed. The property has to be described in the deed as it actually stands, which is where any discrepancy between the building on the ground and the building on the permits comes to the surface. And the title chain has to be traced back through whatever the previous owners did or did not register, which on older island properties can be genuinely slow.
None of that is exotic. It is the same Greek infrastructure a buyer sets up at purchase: a tax number, a lawyer, a power of attorney. The families who find the process painless are, almost without exception, the ones who kept that infrastructure alive rather than letting it lapse once the purchase completed.
Which country's law decides who inherits
Since 17 August 2015, cross-border successions in the participating EU states have been governed by Regulation 650/2012. Two features of it matter to an American owner.
The first is that it has universal application. A Greek notary applies its rules whatever nationality the deceased held, and even where the law those rules point to is the law of a country outside the EU. You do not opt out of it by being American. The second is the default rule in Article 21: the law of the deceased's last habitual residence governs the succession as a whole, movable and immovable property together. So for a US citizen habitually resident in Florida who dies owning a house on Crete, the Greek notary is directed to Florida law for the entire estate, Greek house included.
Article 22 allows you to override that by choosing, expressly in your will, the law of the state whose nationality you hold. For a US national this raises a complication the Regulation itself anticipates. The United States is a state with more than one legal system, and succession is state law rather than federal law. Article 36 addresses that by pointing to the internal conflict rules of the country concerned, and failing those, to the territorial unit with which the deceased had the closest connection. In drafting terms the answer is simple and easy to get wrong: name the jurisdiction. A clause choosing the law of the State of New York does the job. A clause choosing the law of the United States invites an argument.
There is a further reason to make the choice expressly. Where the applicable law is that of a country outside the EU, its own conflict rules can be taken into account, and several US states refer questions about immovable property back to the law of the place where the property sits. That would land the Greek house back under Greek law. A valid Article 22 choice closes that route off. How it is worded, and whether it is the right move for your family, is a question for a Greek lawyer and your US estate attorney together.
Forced heirship has no American equivalent
If Greek law does govern the succession, the reserved portion applies. The nomimi moira, set out in the Greek Civil Code from Article 1825 onwards, protects children, a spouse and in some circumstances parents, and gives each protected heir half of the share they would have received had there been no will at all. A will cannot reduce it, and a protected heir who has been left out can bring a claim.
Most US states have nothing comparable. A spousal elective share exists in many of them, but the idea that adult children hold an enforceable claim against a parent's estate is foreign to American practice. So a will that leaves everything to one child, or everything to a second spouse, can be entirely valid at home and vulnerable in Greece. This, far more than the tax, is why the Article 22 choice deserves attention while the owner is alive, and why it is worth having a Greek lawyer read the American will rather than assuming it travels.
The US side, and an unusually old treaty
US citizens are taxed on the worldwide estate, wherever the assets sit. The Greek house is inside it, valued in dollars, and it is reported on Form 706 where the estate exceeds the filing threshold.
What has changed the practical picture is the size of the exclusion. Legislation enacted on 4 July 2025 set the basic exclusion amount at 15,000,000 dollars per person from 2026, made it permanent rather than subject to a sunset, and left it indexed for inflation. Because it is per person and portable between spouses, the great majority of families who own one holiday home abroad sit comfortably below it. Confirm your own figure, and your own state's position, since a number of states impose an estate tax of their own at far lower thresholds.
The technical curiosity is the treaty. The United States maintains estate tax treaties with only a short list of countries, and Greece is on it. The convention was signed on 20 February 1950 and supplemented by a protocol in 1953, and it covers estate tax only, not gift tax. It is older than most of the properties this article is about, and it is genuinely easy for an American executor to assume no such treaty exists. It allocates taxing rights between the two countries and provides relief from double taxation, and where a large estate does produce tax on both sides, the treaty sits alongside the foreign death tax credit, evidenced with Form 706-CE, as the mechanism that stops the same asset being taxed twice. How it applies to a particular estate is a question for a US estate attorney who has read it, not a conclusion to draw from the fact that it exists.
Two smaller filings are worth knowing about. A US person who inherits from a decedent who was not a US person, a Greek relative rather than an American parent, reports the receipt on Form 3520 once it exceeds the threshold for bequests from foreign persons. It is an information return that raises no tax by itself, and the penalties for missing it are real. And an inherited Greek bank account brings the heir straight into the reporting covered in our guide to ENFIA, FBAR and FATCA.
What all of this actually adds up to
Put the two sides together and the honest conclusion is not the one families brace for. With a 15,000,000 dollar US exclusion and Greek allowances of 150,000 euros per Category A beneficiary measured against an assessed value, most American families who own one Greek property face no meaningful inheritance tax in either country. What they face is administration, and occasionally a forced heirship problem that nobody saw coming.
That reframing matters, because it changes what is worth spending money on. The expensive outcomes here are not tax bills. They are a house that cannot be sold because the acceptance deed was never registered, a deemed acceptance that carried debts nobody checked for, and a family disagreement resolved by Greek default rules instead of by the owner's intentions.
All three are cheap to prevent while the owner is alive. A will that addresses the Greek asset explicitly and makes a considered choice of governing law, tax numbers in place for the likely heirs, a Greek lawyer who already holds the title file, and a note in the estate papers telling the family that a renunciation clock exists. The cost is measured in hundreds of euros and one conversation. The alternative is measured in years.
If you are still at the buying stage, this is worth settling with the same Greek lawyer who handles the purchase, at the same time, while the file is open and the power of attorney is already signed. It is the cheapest hour of legal advice in the whole transaction, and it sits naturally alongside the preliminary agreement and finance conditions you are negotiating anyway.
What to put in place while the owner is alive
- A will that names the Greek property explicitly and states which law is chosen to govern the succession.
- A named US state in that choice of law clause, not the United States as a whole.
- A Greek tax number for the owner, and ideally for the likely heirs, obtained before it becomes urgent.
- Contact details for the Greek notary and lawyer holding the title file, given to whoever will act as executor.
- A note in the estate papers recording that a renunciation deadline exists and how it is calculated.
- ENFIA declared and paid every year, so no arrears travel with the property.
- Purchase price, closing costs and improvement receipts kept, since the heirs may well sell.
Questions US families ask
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This guide is general information, not personal financial, legal, tax or currency advice. Greek succession rules, allowances and deadlines depend on the facts of each estate, and US estate tax treatment depends on your individual position; confirm both with a Greek lawyer and a US estate attorney before acting. Mortgage availability is subject to credit, income, valuation and lender criteria.