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AOW, pension and the 7% scheme: fifteen years — unless you were with the ABP

Greece lets whoever moves their tax residence pay 7% on all their foreign income for fifteen years. The treaty with the Netherlands does indeed allocate AOW and occupational pension to Greece — but article 20 keeps pensions from government service in the Netherlands. For one person the scheme is worth tens of thousands of euros, for another exactly nothing.

5 min readLast updated:

Of all destinations on this site, Greece has the most spectacular tax scheme for pensioners — and the sharpest exception to it. You need to know both before you decide anything, because together they determine whether this move brings you thousands of euros a year or nothing.

First: which country may levy?

That is governed by the tax treaty between the Netherlands and Greece, and the answer differs per type of pension.

Article 19 — pensions. "Pensions and other similar remuneration paid to a resident of one of the States in consideration of past employment shall be taxable only in that State." So your occupational pension is taxed in Greece, as soon as you are a tax resident of Greece. For non-periodic payments — a lump sum — there is an exception: the source country may tax those.

Your AOW. The treaty doesn't mention social security separately. If your AOW (the Dutch state pension) falls under article 19 as "similar remuneration", the state of residence levies. If it falls outside it, it ends up under article 23 (other income) — and that article too allocates the taxing right exclusively to the state of residence. By both routes, then, it ends up in Greece.

Article 20 — government service. And this is what matters. A pension paid by or out of funds of the Dutch State may be taxed by the Netherlands. That means: an ABP pension you built up in government service stays taxed in the Netherlands. Civil servants, teachers in state education, police, armed forces — for them little changes fiscally. The exception to that exception applies only if you are both a resident and a national of Greece, and that is rarely the case for Dutch emigrants.

Many people have a mixed pension: partly ABP from government years, partly a pension fund from private-sector years, plus AOW. Work those parts out separately.

Then: the 7% scheme of article 5B

For the part that is taxed in Greece, article 5B of Law 4172/2013 stands ready. Whoever moves their tax residence to Greece can opt for a flat tax of 7% on all their foreign income — and that is broader than pension alone: rental income, dividends, interest and capital gains from abroad also fall under it.

The conditions:

  • You were not a Greek tax resident for five of the last six years.
  • You move your residence from a country with which Greece cooperates on tax matters. The Netherlands meets that.
  • The scheme runs for fifteen tax years.
  • You apply by 31 March of the tax year at the latest.
  • You can step out of it any year; it is a choice, not a trap.

And then the condition most often missing from what you read about it. If in any tax year you don't pay the full amount, you fall outside article 5B from that year and are from then on taxed on your worldwide income. That is not a fine but the end of the scheme — for whoever counted on fifteen years at 7%, the heaviest condition of all, heavier than the application date, because that one you can meet again a year later.

One more thing the AADE itself adds: article 5B expressly leaves the tax treaties untouched. What the Netherlands may levy as source state on your house, your dividends or your interest here therefore continues to apply — see what the Netherlands keeps levying despite the 7%.

Compare that with the ordinary Greek brackets and you see what is at stake. Since tax year 2026 those run from 9% up to € 10,000, via 20%, 26% and 34%, to 39% between € 40,000 and € 60,000 and 44% above that. An occupational pension of € 45,000 thus comes to well over € 10,000 in tax before the tax reduction of € 777 comes off; under article 5B it is € 3,150.

That difference became slightly smaller with the 2026 reform — the old table jumped from 36% straight to 44% above € 40,000 — but it remains the heart of the matter.

The sum you do before you leave

Put the three pieces side by side:

  1. Which part of your income may Greece tax? AOW and private pension yes, ABP from government service no.
  2. What does that part cost under 7%, and what under the Greek brackets?
  3. What do you pay now in the Netherlands on that same part?

Only when those three figures are on the table do you know what this move does fiscally. For a retired couple with two private pensions, that can run into the hundreds of thousands over fifteen years. For a former teacher with mostly ABP, the difference is almost nil.

This article explains the rules; it is not tax advice. Applying them to a mixed pension, an owned home in the Netherlands or a substantial shareholding belongs with a tax adviser who knows both systems — see also when you need an adviser and when you don't.

Two things you mustn't forget

The protective assessment. If you have annuities or a substantial shareholding, the Netherlands imposes a protective assessment on emigration. It is not collected as long as you do nothing that makes it payable. For annuities and pension it usually lapses after ten years — but for a substantial shareholding it is valid indefinitely. See the protective assessment on emigration.

The date. 31 March is a hard limit. Whoever moves in May and only thinks about their tax affairs in the autumn misses the first year. Put it in your diary before you leave.

In Vertrekklaar this is phase 2 of 5 of the journey: the same steps, but applied to your situation — in your order, tickable, and with the deadlines monitored. See the whole journey to Greece.

What this rests on

The facts in this article come from these official pages. Rules change — when in doubt the source is leading, not this article.

Read on

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