# Appendix E — Property Due-Diligence Checklist This appendix is the working form of Chapter 8 and §17.7. It introduces no new material: every line restates a condition, cost or test already established and cited in the body, and carries the section it derives from so that any answer can be traced back and re-argued against the chapter text. It is intended to be run by the client's lawyer, the client's engineer and the client jointly against a single candidate property, with each line closed in writing before €250,000 is committed. Every line is answered "pass", "fail" or "evidence required"; a line left open is not a pass. Where the chapters qualify a point as reported, as analysis, or as requiring confirmation at the date of application, the qualification is repeated here and travels with the line wherever the checklist is used. The general documentary requirements for Article 100 applications sit in the common-documents list of JMD 95391/2024, Article 2, incorporated by JMD 214926/2025, Article 1; that list is not reproduced here and its current content requires confirmation at the date of application. --- ## A. Programme eligibility | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | A1 | Will the applicant hold full ownership and possession (πλήρης κυριότητα και νομή) of one single property? | Deed conveying 100% ownership of one property to the applicant. | §8.1 | | A2 | Is the recorded acquisition value at least €250,000 at the time of purchase? | Consideration stated in the notarial deed; no floor area applies to this category. | §8.1, §8.3 | | A3 | Have the principal spaces been converted to residential use, with the conversion completed before the application is submitted? | Completed works, not works in progress; the conversion may be effected by buyer or seller (Article 100, Law 5038/2023, as amended by Article 64, Law 5100/2024). | §8.1 | | A4 | Is completion certified as after 5 April 2024 by the issue date of a qualifying planning act? | Engineer's technical report in the prescribed formula of JMD 214926/2025 naming a building permit, small-scale works approval (έγκριση εργασιών δόμησης μικρής κλίμακας), permit-file update (ενημέρωση φακέλου) and/or building-permit revision. The 5 April 2024 limb comes from the official administrative record, not from the statute, and requires confirmation at the date of application. | §8.1, §8.5 | | A5 | Was the property already in residential use on 5 April 2024? | Fail if yes: a property cycled out of and back into residential use does not qualify (Circular 1/2026, reported; the circular text has not been inspected). | §8.5 | | A6 | Is the conversion an actual completed change of a building's use rather than a paper amendment of the building permit? | Physical and documentary evidence of a real change of use; a paper-only conversion is a decisive stall point. | §8.5, §17.7 | | A7 | If the converted building is industrial, is five-year non-operation established? | Engineer's certification supported by a power-disconnection certificate (ΔΕΔΔΗΕ or the municipality), E2 forms for the five preceding years, or combined evidence from public authorities. | §8.5 | | A8 | Has the property previously been used for the issuance of an investor residence permit? | Fail if yes. The notary must certify the position in the deed (Article 100 §6). The once-only effect per property is reported and requires confirmation at the date of application. | §8.4, §8.14 | | A9 | Will the full price be paid before the application through the prescribed channels only? | Crossed bank cheque to the seller's account at a credit institution operating in Greece, credit transfer, or POS payment through a Greek payment provider; payment may also be made by the applicant's spouse or relatives by blood or marriage up to the second degree; all payment details recorded in the deed. | §8.1, §17.10 | | A10 | Where acquisition is through a legal person, does the applicant hold 100% of it? | Evidence of 100% holding at filing; personal ownership is the reference case. | §17.8 | | A11 | Does any arrangement reduce the effective investment below the statutory minimum? | Fail if yes: rebates, side payments or under-declaration attract revocation. | §8.5, §8.13, §17.10 | | A12 | Is the registration position covered for initial issuance? | An attestation that registration has been applied for, or a lawyer's certificate, suffices at initial issuance, with the definitive registration certificate deferred to renewal; the applicant carries registration risk in the interval. | §8.4 | | A13 | Does the file satisfy both the evidentiary test of the JMD and the substance test of the circular? | Written confirmation that eligibility does not depend on the permissive reading of either; a file that does should be treated as high-risk. | §8.5 | *Assumptions: the reference case is the restricted €250,000 change-of-use category in the Region of Attica, a single non-EU-national applicant purchasing in his own name. Derived from §8.1, §8.3, §8.4, §8.5, §8.13, §8.14, §17.8 and §17.10. Circular 1/2026 items are reported tier.* ## B. Legal title | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | B1 | Which registry branch applies to this property — the parcel-based Hellenic Cadastre or a legacy person-based registry (υποθηκοφυλακείο)? | Location status determined before the search is scoped; 99% of the country had cadastral data posted and 71% was in full cadastral operation as at mid-2026 (reported), so either branch may apply to a 2026–27 purchase. | §8.4, §17.7 | | B2 | In a cadastral area, is the full certificate set obtained? | Registration certificate against the KAEK, cadastral sheet extract, diagram copy and encumbrances certificate. | §8.4 | | B3 | In a legacy area, is the full search performed? | Searches through the general indexes, the share books and the books of mortgages, seizures and claims. | §8.4 | | B4 | Has the title chain of the seller and predecessors been searched for at least 20 years? | Lawyer's written title report; 20 years is the depth of extraordinary usucapion and is professional practice, reported tier. | §8.4, §17.7 | | B5 | Are there mortgages, prenotations of mortgage or seizures? | Nil, or discharge and deletion secured on or before completion. | §8.4, §17.7 | | B6 | Are there pending claims or litigation affecting the property? | Nil, or disclosed, quantified and provided for in the contract. | §8.4, §17.7 | | B7 | Are servitudes, easements and judicial annotations recorded against the KAEK identified? | All real rights, mortgages, easements, annotations and claims are recorded against the KAEK in cadastral areas and must be read, not assumed. | §8.4 | | B8 | Is the horizontal-ownership structure of the building established? | Horizontal-ownership table read from the Building Identity dossier: which parts are exclusively owned, which are common, and how parking and storage are held. | §8.4, §8.8 | | B9 | Is the seller's identity, capacity and — where a company — corporate standing verified? | Corporate documents, signing authority and litigation search. | §8.13, §17.7 | | B10 | Has the boundary of the legal report been stated? | Written confirmation that legal due diligence does not cover planning, land-use or forestry questions, which belong to the engineer under Section C. | §8.4, §17.7 | *Assumptions: a resale or developer sale of a single converted apartment; certificates as they stand during the cadastral transition, whose completion was targeted for end-2026 (reported). Derived from §8.4, §8.8, §8.13 and §17.7.* ## C. Building legality and planning | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | C1 | Is the Article 83 certificate available and correctly timed? | Engineer's certificate that no unauthorised constructions or uses exist, with the owner's responsible declaration, under Article 83, Law 4495/2017; filed electronically with a unique number and valid two months, so it must be timed to the deed. | §8.4, §17.7 | | C2 | Is there arbitrary-construction exposure? | Any unauthorised works are within the statutory exceptions or have been regularised, with the regularisation declarations in the dossier. | §8.4, §8.5 | | C3 | Is the Electronic Building Identity file complete? | Engineer's Completeness Certificate issued from the digital dossier — permit and amendments, approved plans, energy certificate, cadastral extract, regularisation declarations and the horizontal-ownership table (reported; indicative issue cost €120–€250 for an apartment, customarily seller-borne, but the buyer's engineer should review the file). | §8.4 | | C4 | Is an Energy Performance Certificate in hand? | Certificate under Article 12, Law 4122/2013, required on sale and on each letting to a new tenant, with the energy class stated in every commercial advertisement. | §8.4, §8.11 | | C5 | Do the works as built match the planning acts relied on for eligibility? | Engineer's comparison of the executed works with the permit file; exposure is concentrated in a conversion because the works are recent, and a defect strikes twice — at the permit, at initial grant or renewal, and at value and marketability. | §8.5 | | C6 | Has the buyer's engineer verified the planning file independently? | Written report from an engineer instructed by the buyer; the seller's engineer's report was produced to sell eligibility. | §8.5, §17.7 | | C7 | Are the two engineer documents present and distinguished? | The building-legality certificate (Section C) and the change-of-use technical report (A4) serve different functions and neither substitutes for the other. | §8.5, §17.7 | *Assumptions: an apartment in a multi-unit Athens building of the age typical of convertible commercial stock; the Electronic Building Identity requirement is reported and its activating instrument and mandatory date are not pinned in this report. Derived from §8.4, §8.5, §8.11 and §17.7.* ## D. The conversion itself | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | D1 | Is the dwelling physically complete and habitable at inspection, not merely licensed? | Site inspection record from the buyer's engineer; the eligibility event is a completed change of use, not a licensed intention. | §8.5, §17.7 | | D2 | Are the principal spaces in a residential configuration as certified? | Inspection matched against the technical report and the planning acts named in it. | §8.5 | | D3 | Where the conversion is mixed — part of a building only — is the qualifying unit's position clear? | Mixed conversions are reported to be possible; the file must identify precisely which spaces changed use and how the purchased unit sits within them. | §8.5 | | D4 | Does a building not designed as housing perform as housing? | Daylight, ventilation, heating and lift provision assessed on inspection rather than assumed from the certification. | §8.8 | | D5 | Does eligibility rest on documentation alone? | Fail where the conversion is evidenced on paper but not delivered in fact; a property that fails here is replaced, not excused. | §8.5, §17.7 | *Assumptions: an office-to-residential or similar commercial-to-residential conversion in the €250,000 category. Derived from §8.5, §8.8 and §17.7; the substance requirements rest on Circular 1/2026 at reported tier.* ## E. Taxes and transaction costs | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | E1 | Which acquisition tax applies to this property — transfer tax (FMA) at 3.09% or VAT at 24%? | Written confirmation from the purchaser's lawyer and notary before signing; the two taxes are mutually exclusive and the classification is property-specific. | §8.6, §17.8 | | E2 | Which of the three limbs applies? | A pre-2006-permit or already-used building is outside VAT scope, so FMA applies; a conversion under a post-2006 construction permit sold before first use by a VAT-liable developer is within VAT scope but in practice the developer will have elected suspension, so FMA applies; a sale by a non-developer is never subject to VAT (analysis). | §8.6 | | E3 | Is the completion-date exposure closed contractually? | The VAT suspension (Law 4646/2019, currently extended by Law 5246/2025) runs to 31 December 2026 and nothing is enacted beyond that date as at 2 August 2026; a VAT-scope property completing later could face 24% instead of 3.09%. The exposure is allocated in the contract, not assumed away. | §8.6 | | E4 | Is the FMA base agreed and the payment sequence understood? | Base is the higher of contract price and objective (tax-assessed) value; the buyer is liable; the declaration is filed electronically (myProperty) and the tax paid before the deed is executed. | §8.6, §17.10 | | E5 | Is the full acquisition-cost stack quoted in writing? | Written quotations for every line in Table E-1; no published tariff market exists for technical due diligence. | §8.6, §17.7 | | E6 | Is an annual ownership budget prepared for this property? | Table E-2, with the municipality- and building-specific lines confirmed for the selected property. | §8.12 | | E7 | Has the Greek tax number (AFM) been obtained? | AFM in place before the declaration and the deed; it is a practical precondition of purchase. | §17.10 | | E8 | Are purchase funds remitted through the banking system from the buyer's own foreign accounts? | Banking evidence of the import; this also documents the acquisition against Greek deemed-income rules for a non-resident buyer. | §17.10 | | E9 | Is the first post-completion filing diarised? | E9 property declaration due by 31 January of the year following the deed — the classic first compliance failure of foreign owners. | §8.11 | *All Greek tax figures in this section are reported tier, verified against convergent professional sources with the governing instrument identified, and subject to confirmation at the date of application. Derived from §8.6, §8.11, §8.12, §17.7, §17.8 and §17.10.* ### Table E-1 — Acquisition-cost stack on a €250,000 purchase | Line | Basis | Low | High | |---|---|---:|---:| | Transfer tax (FMA), including municipal surcharge | 3.09% of taxable value | €7,725 | €7,725 | | Notary | 0.8–1.2% + 24% VAT | €2,480 | €3,720 | | Land registry / cadastre registration | ≈0.5% + fixed charges | €1,250 | €1,250 | | Lawyer (conveyancing) | ≈1–2% + 24% VAT | €3,100 | €6,200 | | Technical due diligence (conversion property) | banded estimate, analysis | €300 | €1,500 | | **Subtotal — no buyer's agent instructed** | | **€14,855** | **€20,395** | | Buyer's estate agent (only if instructed) | 2–4% + 24% VAT | €6,200 | €12,400 | | **Total — buyer's agent instructed** | | **€21,055** | **€32,795** | *Assumes taxable value = price = €250,000, the FMA (suspension) regime rather than VAT, and all professional lines separately instructed. Subtotal without a buyer's agent is 5.9–8.2% of price; total with one is 8.4–13.1% (§8.6 presents the same arithmetic rounded to the nearest €100, at approximately €14,900–€20,400 and €21,100–€32,800, and quotes 6.0–8.2% on the rounded lower figure). Professional bands are reported market rates; the technical-due-diligence band is analysis, no published tariff market exists, and written quotations are required. Every column foots to the exact sum of the lines above it. Derived from §8.6; the integrated cost model including non-property lines sits at §10.6 and §10.8.* ### Table E-2 — Annual ownership-cost budget | Annual line | Low | High | Status | |---|---:|---:|---| | ENFIA (state property tax) | €300 | €700 | illustrative for a €250,000 Athens apartment | | TAP (municipal duty, via the electricity bill) | €40 | €90 | 0.25‰–0.35‰ of assessed value; illustrative | | Municipal refuse and lighting fees | €100 | €300 | municipality-specific; illustrative | | Building common charges (κοινόχρηστα) | €360 | €1,200 | building-specific; no statutory scale; illustrative | | Buildings insurance | €200 | €600 | reported market band | | Outsourced tax compliance, where engaged | €250 | €500 | reported, basic tier; rental filings higher | | **Total** | **€1,250** | **€3,390** | exact sum of the band endpoints | *Assumes a single Greek property below the €500,000 ENFIA surcharge threshold, taxable value at or below price, and every line engaged. Excludes letting costs, maintenance, management, the 15–25%-of-rent allowance of §12.6, and the health insurance required for the permit. Insuring against fire, earthquake and flood earns a 20% ENFIA discount at taxable values up to €500,000, subject to the prior-year coverage mechanics; from 1 January 2027 TAP is replaced by a Local Development Fee of 0.30‰–0.70‰, so the municipal line steps up (reported). Derived from §8.12.* ## F. The property as an investment | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | F1 | What is the implied price per square metre, and how does it compare with district norms? | Price divided by measured area, tested against district comparables rather than against the statutory floor. A unit at €250,000 sized 60–100 m² implies €2,500–€4,167 per m², at or above average central-Athens asking levels, in districts where conventional stock trades well below the Athens average (analysis on reported price data). | §8.3, §8.15 | | F2 | Have district comparables been assembled on a per-square-metre basis for conventional stock in the same district and street? | Written comparables file. Reported Athens-Centre conventional asking examples include a one-bedroom flat at €135,000 and a two-bedroom at €205,000 (asking-based, reported). | §8.3, §8.7 | | F3 | Is the price explicable only by the €250,000 threshold? | Where it is, the premium is quantified in writing and carried into the capital arithmetic as part of the cost of the structure rather than as retained asset value (§12.2–§12.4). | §8.3, §8.15 | | F4 | Does the construction cross-check support the price? | Trade guides put a standard full renovation at ≈€350–€730 per m² and new-build construction at ≈€800–€1,400 per m²; no published conversion-cost series exists and the €500–€1,200 per m² band is analysis, not a citable fact. | §8.3 | | F5 | Is a guaranteed-rent promise attached to the sale? | Treat as a pricing warning: such promises capitalise the visa rather than the flat, and below-market letting by absentee predecessors (reported at 10–15% below comparable rents) is the documented aftermath. | §8.3, §8.13 | | F6 | What competing supply sits in the same district? | Reported pipeline of 1,000–2,000 completed conversion apartments marketed from spring 2026 and an estimated 3,000–5,000 more by 2027, clustered in Exarcheia, Metaxourgeio, Kypseli and Piraeus (reported, single major daily with corroborated reproduction). | §8.7 | | F7 | Has the downside been tested against the verified history rather than the recent boom? | National apartment prices fell 42.4% nominal from Q3 2008 to Q3 2017 (Athens 44.7%, Q2 2008 to Q1 2017), over nine consecutive negative years, and approximately 46% in real terms; the national index in 2025 remained approximately 18% below its 2008 average in real terms. | §8.2 | | F8 | Has the comparator evidence been read for what it is? | In Portugal, transaction prices exceeded fiscal values by an average of approximately €38,000 at the €500,000 threshold, with bunching at the threshold (IZA Discussion Paper No. 16857). This is Portugal evidence; no Greece-specific econometric study was located, and the Athens mechanism is analysis. | §8.3 | | F9 | Would the property remain commercially defensible if the immigration benefit were ignored? | A written answer to the property-without-immigration test: price against district comparables, rent against achievable long-term lettings in that building and street, exit against a buyer with no immigration motive after both sides' transaction costs, downside against the verified history. | §8.15 | *Assumptions: the client is a non-EU-national investor buyer, not an owner-occupier, and no owner-occupier relief or short-stay income is available to him. Yield, asking-price and pipeline data are reported tier and asking-based where stated; the per-square-metre and premium analyses are labelled analysis in the body. Derived from §8.2, §8.3, §8.7, §8.13 and §8.15.* ## G. Usability and letting | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | G1 | Do parking and storage exist, and are they in the title? | Included as horizontal property or appurtenance in the deed and the horizontal-ownership table, not assumed from the marketing. | §8.8, §8.4 | | G2 | Do size and layout serve the district's actual tenant pool? | Assessment of size, layout, aspect, frontage and any active commercial uses in the building; the category imposes no minimum floor area, no layout standard and no requirement that the dwelling suit anyone's occupation. | §8.8 | | G3 | What do the horizontal-ownership structure and common-area condition imply for charges and disputes? | Table read and building condition inspected; a 40-year-plus Athens building requires actual maintenance and the owner participates in common charges whether present or not. | §8.8, §8.11 | | G4 | Is the letting plan long-term only? | Client's written acknowledgement. Article 100 §7 expressly permits long-term letting; §7A prohibits short-term letting in the framework of the sharing economy and sub-letting for the post-2024 categories, with revocation of the permit and a standalone €50,000 administrative fine on the owners or possessors. | §8.9, §8.10 | | G5 | Is the company-seat prohibition acknowledged? | A change-of-use property may not be used as the seat or branch of a business; the precise mapping of fines to that prohibition requires confirmation against the gazette text. | §8.10 | | G6 | Is the three-year lease commitment understood? | Greek primary-residence leases carry a mandatory minimum duration of three years even if a shorter term is agreed, with early exit by defined cause or subsequent agreement, in practice by notarial deed at least six months after commencement (Law 1703/1987, Article 2, as amended by Law 2235/1994, Article 1(5); the gazette text has not been independently inspected). There is no short-notice recovery of vacant possession. | §8.9 | | G7 | Is achievable rent evidenced by local comparables rather than a vendor's guarantee? | Written comparables. A realistic planning band for a floor-priced central conversion, long-let, is 4.0–5.0% gross before costs, taxes and voids (analysis); portal averages of 4.38% nationally and 5.52% in Athens are asking-based and transacted yields are lower (reported). | §8.9 | | G8 | Has rental income been modelled net rather than gross? | Individual rental income taxed, for income earned from 1 January 2026, at 15% to €12,000, 25% to €24,000, 35% to €36,000 and 45% above, on 95% of gross rent; rents to be paid into a landlord bank account declared to the tax administration, reported with effect from 1 April 2026, on pain of losing the 5% deduction (all reported, pending gazette confirmation). | §8.9 | | G9 | Are management, maintenance, voids and insurance provided for? | The report's stated assumption is 15–25% of gross rent all-in; no verified data exist on Greek eviction and arrears enforcement timelines, so void assumptions should be conservative. | §8.9, §8.11 | | G10 | Has any short-stay income been excluded from the valuation? | Fail where short-term-letting income is priced in: the owner cannot lawfully operate it, the property can never be marketed with a registration attached, and new registrations are barred in the 1st, 2nd and 3rd Municipal Communities of Athens through 31 December 2026, with registrations in restricted zones no longer transferring on sale or inheritance from 2026 (reported). | §8.10 | *Assumptions: a single let unit held by a non-resident individual, long-term tenancy by elimination, no owner occupation. Tax figures are reported tier and subject to confirmation at the date of application; yield figures are asking-based; the 4.0–5.0% planning band and the 15–25% allowance are stated assumptions of this report. Derived from §8.4, §8.8, §8.9, §8.10 and §8.11.* ## H. Counterparty | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | H1 | Is the developer's or seller's standing verified? | Corporate standing, planning history, delivery record and litigation searched and reported in writing, alongside the property file. | §8.13, §17.7 | | H2 | Is the stock completed and certified at the point of payment? | Preference for completed and certified stock; a client who pays against an uncompleted conversion has capital out while eligibility does not yet exist. | §8.13 | | H3 | Where payment must precede completion, is it staged? | Payment staged against the issuance of the planning acts named in the JMD formula, with a meaningful final tranche retained until the engineer's report and the Article 83 certificate can actually be issued. | §8.13 | | H4 | Is security for staged payments in place? | Greek counsel instructed on securing the staged payments; the protection is contractual and must be negotiated, not assumed. | §8.13 | | H5 | Does the payment evidence rest where the JMD puts it? | The notarial deed record, not informal receipts: the JMD relies wholly on the notarial certificate for payment evidence and requires no separate bank-statement file. | §8.13 | | H6 | Is the seller's VAT status established? | Seller's VAT status and course-of-business position documented; it is one limb of the E1 classification, and the seller must also be certified in the deed as to prior investor-permit use of the property. | §8.6, §8.13 | | H7 | Has the marketing material been reviewed for what it claims? | Any capitalised short-stay income, guaranteed rent or implied approval is challenged in writing; one-stop services are reported to be directed to refer misleading advertising and suspicious flows to the tax authority and the anti-money-laundering authority. | §8.10, §8.13 | | H8 | Are the documented abuse patterns present? | FATF and OECD record Hellenic FIU case studies of resale and overvaluation schemes organised by real-estate professionals to lift sub-€100,000 properties to the €250,000 threshold; any resemblance is a stop, and enforcement lands on the buyer's permit whoever designed the scheme. | §8.3, §8.13 | | H9 | Has any reservation payment been made before due diligence is complete? | Fail if yes. No reservation payment before Section B to D work is complete, and any reservation instrument is reviewed by the lawyer first; reservation practice is not regulated by the permit legislation. | §17.10 | | H10 | Is the funds route compliant end to end? | Statutory payment channels only, full price stated, cash nowhere in the sequence. | §8.1, §17.10 | *Assumptions: an arm's-length purchase from a developer or a prior investor-owner; no view is taken here on any particular counterparty. Circular 1/2026 items are reported tier. Derived from §8.1, §8.3, §8.6, §8.10, §8.13 and §17.10.* ## I. Exit | Ref | Question | Pass condition / evidence required | Source | |---|---|---|---| | I1 | Who is the realistic buyer at or above €250,000? | While the category remains open on current terms, the natural buyer is another investor-visa applicant: Article 100 §8 allows resale during the permit's validity to a qualifying third-country national, who acquires a permit right while the seller's permit is simultaneously revoked. | §8.14 | | I2 | Does a resold conversion re-qualify a new €250,000 application? | Open administrative question; the once-only effect is reported, the deed-statement duty is statutory, and the position requires confirmation at the date of any resale. Do not assume the successor bid exists. | §8.14 | | I3 | What is the value if the successor visa bid is unavailable, or the category closes or thresholds rise? | Residual value reverts to district fundamentals materially below floor-set pricing, with a domestic household or landlord as the marginal buyer in a market where outstanding housing loans fell 2.6% in 2024 after −3.5% in 2023. | §8.3, §8.14 | | I4 | What competing supply will the resale face? | The 2026–2027 conversion pipeline concentrated in the same few districts, and earlier investor-owned units reported returning to the market. | §8.7, §8.14 | | I5 | What liquidity assumption is used? | No official time-on-market statistics are published; marketing-sector estimates suggest weeks to months for well-priced central stock in current conditions, and 2008–2017 demonstrates conditions in which Greek residential property became effectively illiquid for years. The downside assumption is stated in years, not weeks. | §8.14 | | I6 | Is the seller's own exit stack budgeted? | Agent 2–4% plus 24% VAT if instructed; lawyer ≈1–2% plus VAT if instructed; Energy Performance Certificate; Article 83 engineer's certificate and owner's declaration, valid two months; ENFIA certificate covering five years, without which the notary may not execute; a municipal TAP-clearance certificate is reported no longer required since 1 January 2024. Plan at roughly 3–6% of gross price with an agent, 1–2% without (reported bands). | §8.14 | | I7 | Is the buyer's side of the resale priced in? | A rational buyer prices the same 5.9–13.1% acquisition friction of Table E-1 into the offer. | §8.6, §8.14 | | I8 | Is contingent capital-gains tax carried? | The 15% tax on individuals' real-estate gains is suspended through 31 December 2026 (Article 90, Law 5162/2024, suspending Article 41, Law 4172/2013) and nothing is enacted beyond that date as at 2 August 2026. If it lapses as the provisions stand, the documented gain since acquisition becomes taxable with holding-period reductions — illustratively about €2,590 on a €250,000 to €300,000 sale at year ten, approximately 0.9% of proceeds (analysis on a single-source coefficient table). | §8.14 | | I9 | Has the permit interaction been put to the client in writing? | Selling to cut losses revokes the permit, so a client who still wants the residence position cannot sell; a sitting three-year tenancy prevents delivery with vacant possession on short notice. | §8.14 | | I10 | Is demand at the category's own gate rising or falling? | Monthly new investor filings fell from 864 in March 2025 to 427 in March 2026, with 10,032 investor applications pending as at March 2026, 7,613 of them in Attica. | §8.7, §8.14 | | I11 | Is the marginal foreign bid rising or falling? | Net foreign inflows for Greek property purchases were approximately €2.75bn in 2024 (+28.9%) and approximately €2.06bn in 2025 (−25.3%, reported), with no domestic credit bid to replace them. | §8.7 | *Assumptions: resale by an individual non-resident owner of a single unit; tax positions stated as at 2 August 2026, reported tier, and subject to confirmation at the date of any resale. Derived from §8.3, §8.6, §8.7 and §8.14.* --- ## Decision rule Eligibility and investment quality are two separate questions, and this checklist answers them separately by design. Sections A to E answer the first: does the property qualify for the residence permit, on a documentary test that contains no test of location, size, build quality, achievable rent or resale value. Sections F to I answer the second: would the property remain commercially defensible if the immigration benefit were ignored. A positive answer to the first does not establish a positive answer to the second, and a property must pass both before it is approved for the reference structure (§8.15). Where the second question fails — where the price is explicable only by the statutory threshold — the difference between price and defensible value is, economically, part of the cost of the structure rather than part of the retained asset, and must be treated that way in the capital arithmetic (§8.15, §12.2–§12.4). A client may knowingly pay a premium for eligibility, priced and disclosed as such. Where the premium is large, the letting case weak and the exit dependent on the programme's continuation, the correct advice may be not to proceed with that property, or not to proceed at all (§8.15, §13.14). A property that cannot pass this checklist may still, in law, deliver a residence permit. It should not, on that ground alone, receive the client's €250,000 (§8.16).