Greek residence-by-investment is Greek law, decided by Greek authorities, on thresholds that have changed and been regionally differentiated more than once. That half of the question belongs to a Greek lawyer, and this page does not answer it.
The half that does not belong to them is the one that goes wrong more often: where the money leaves from, what holds the asset, and what the Greek decision does to a position in Montenegro that does not end because a second permit begins. All three are questions of Montenegrin law, and all three are answerable before anyone applies.
Sources. Zakon o sprečavanju pranja novca i finansiranja terorizma, "Službeni list CG" br. 110/2023, 065/2024, 024/2025, 041/2026 — a decision of the Constitutional Court — and 059/2026; the consolidated Zakon o porezu na dobit pravnih lica, chain through 104/26 of 17.07.2026; the Zakon o porezu na dohodak fizičkih lica, chain through 160/25 of 30.12.2025; and the Ministry of Finance's own published list of Montenegro's double taxation conventions, retrieved 5 September 2026. General information about Montenegrin law, not advice on a particular transaction, and not Greek legal or tax advice.
Moving the money is a reported event
The purchase price has to leave Montenegro, and Montenegrin law has two independent rules about how.
Article 65(1) of the AML Act prohibits any legal person, company, entrepreneur or natural person from receiving or making a payment in cash of 10,000 euros or more. Article 65(2) extends that to two or more linked transactions reaching 10,000 euros in total — and says expressly that this includes loan transactions, which closes the obvious workaround. Article 65(3) then requires a payment of that size to be made by payment or transfer to a transaction account opened at a credit institution in Montenegro.
Article 65(6) pushes the same restriction onto the banks themselves. Credit institutions and payment service providers must apply the cash limit against obliged entities dealing in immovable property, refusing cash proceeds from a property transaction unless the price is below 10,000 euros — and against the obliged entities in the following indents where a single invoice reaches 10,000 euros. The restriction is therefore enforced at the counter, not only against the payer.
So the funds move through a Montenegrin bank account, and that is where the second rule engages.
Article 66(1) requires an obliged entity to deliver the customer due diligence data to the Financial Intelligence Unit without delay and at the latest within three working days of the transaction, for:
| Transaction | Threshold | Obliged entity |
|---|---|---|
| Any non-cash transaction | 100,000 euros or more | general rule |
| Cash transaction in an occasional transaction | 3,000 or more but under 10,000 euros | Article 4(2) point 12 and point 13 indents 3, 4 and 8 |
| Cash transaction | 10,000 euros or more | credit institutions and payment service providers |
| Any transaction | 2,000 euros or more | Article 4(2) point 10 — gaming operators |
Article 66(2) lowers the non-cash threshold to 20,000 euros or more for the obliged entities in Article 4(2) point 13 indents 5, 10, 11, 12 and 13. Article 66(3) requires a report for any transaction of 20,000 euros or more carried out on the accounts of persons in high-risk third countries.
The practical consequence is not that the transfer is difficult. It is that a transfer large enough to buy Greek property is, by design, described to the Financial Intelligence Unit within three working days — with the source-of-funds narrative the bank was given. Where a Montenegrin lawyer, notary or estate agent has also been involved in raising the money, they are obliged entities in their own right under Article 4, and their account of the same funds reaches the same unit. The narratives have to be the same one.
Where the money comes from usually creates its own tax event
Most Greek purchases funded from Montenegro are funded by selling something here, or by taking money out of a company here. Both are taxable events before the euros ever reach Greece.
If the asset sold is Montenegrin real estate held by a non-resident company, the charge and the filing sit on the seller under Article 29c of the corporate profit tax act, on a 30-day clock and through an appointed tax representative — the position we set out in what a foreign company owes on a Montenegrin sale.
If the seller is a Montenegrin resident company, the gain is simply part of its profit. Article 3(1) of the corporate profit tax act treats a legal person as resident where it is either incorporated in Montenegro or has the seat of actual management and control on Montenegrin territory, and Article 4(1) taxes a resident on profit realised in Montenegro and outside Montenegro. Extracting the proceeds to the owner is then a second step with its own withholding.
Neither of those changes because the destination is Greek.
The Greek permit does not end your Montenegrin residence
This is the assumption that causes the most trouble, and Montenegrin law disposes of it in one article.
Article 3(1) of the personal income tax act makes a natural person a Montenegrin tax resident where they either:
- have a prebivalište, or the centre of business and vital interests, on Montenegrin territory; or
- stay in Montenegro for more than 183 days in the tax year.
The two limbs are independent, and the first has no day threshold at all. A person who takes a Greek residence permit, spends most of the year outside Montenegro, but keeps a home, a family and a business here has not left the first limb. Residence in Montenegro is not surrendered by acquiring a permit somewhere else; it is a factual test applied by Montenegrin law to Montenegrin connections.
The same is true on the company side. A Montenegrin d.o.o. whose owner moves does not stop being resident under Article 3(1) of the corporate act — and if the owner starts directing it from Greece, the "seat of actual management and control" limb becomes a live question in the other direction.
And there is no tie-breaker article to fall back on
When two states both treat the same person as resident, a double taxation convention normally decides between them: a ladder of permanent home, centre of vital interests, habitual abode, nationality, and finally agreement between the two tax authorities. We set out how that works for a comparable move in Montenegro and Portugal.
Montenegro's Ministry of Finance publishes the list of the conventions Montenegro applies. Retrieved on 5 September 2026, it enumerates 39 states, and they include Albania, Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Finland, France, Germany, Hungary, Ireland, Italy, Latvia, Luxembourg, Malta, the Netherlands, North Macedonia, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Sweden, Switzerland, Türkiye, Ukraine and the United Kingdom.
Greece is not on that list. Cyprus is, which is precisely the kind of near-miss that makes a fast scan of a regional table dangerous.
One caution belongs with that statement, and it is a real one. A convention functions only if both states apply it, so the honest test is two-sided: the country has to be absent from Montenegro's list and Montenegro absent from the other state's. The Montenegrin side is verified here from the Ministry's own file; the Greek side should be confirmed against a current Greek source before any position is taken, because tax authority tables in this area are frequently out of date in both directions.
If that confirmation holds, the consequences are concrete and none of them is dramatic:
- no tie-breaker article — dual residence is resolved, if at all, by each state's domestic law rather than by an agreed ladder;
- no capped withholding — dividends, interest and royalties crossing between the two carry each state's domestic rate, with no treaty ceiling;
- no mutual agreement procedure — if the two administrations take different views of the same income, there is no forum in which they are obliged to reconcile them;
- relief only where a domestic system gives it unilaterally, on its own terms and its own limits.
What holds the asset changes the Montenegrin answer
Buying the Greek property through a Montenegrin company is a common instinct and it has a specific consequence here. Under Article 4(1) of the corporate profit tax act, a Montenegrin resident company is taxed on profit realised in Montenegro and outside Montenegro — so the Greek rental income and any Greek gain come into the Montenegrin base, and without a convention the relief for Greek tax depends on whatever unilateral credit Montenegrin law allows rather than on a treaty article.
Buying it personally keeps the asset outside the company but leaves the personal residence question of Article 3(1) doing all the work.
And where the individual and their own company deal with each other along the way — a shareholder loan to fund the deposit, a sale of an asset between them, a company-owned apartment made available — those are transactions in which a personal interest exists under the Companies Act, with a notice due before the transaction and approval by those without an interest. We set out that machinery, including the 5% threshold and the 12-month aggregation rule, in dealing with your own Montenegrin company.
Montenegro's own property route is a different legal object
It is worth saying once, because the two are constantly compared. Montenegro does not operate a residence-by-investment programme; it has a Law on Foreigners with grounds for temporary residence, one of which relates to owning property. That is an ordinary immigration ground rather than a package, and the difference changes what is being bought — set out in does Montenegro have a golden visa.
The comparison matters here only in one respect: a person holding both keeps two sets of obligations, not one, and the Montenegrin set does not go quiet because the Greek one is newer.
The four answers to have before applying
None of these needs a Greek adviser, and all of them are cheaper to establish before the money moves.
Where the funds leave from, and whether the same source-of-funds account has been given to the bank and to every Montenegrin obliged entity that touched the transaction — because Article 66 sends all of them to the same place within three working days.
What is being sold to raise them, and whether that sale is inside Article 29c, inside the company's ordinary profit, or neither.
Whether Montenegrin residence actually ends on the facts, tested against both limbs of Article 3(1) rather than against the day count alone.
What holds the Greek asset, remembering that a Montenegrin company brings the Greek income home under Article 4(1), and that without a convention there is no treaty relief waiting on the other side.
If you are considering the Greek route from a Montenegrin base, our Greece golden visa work covers the Montenegro side of the file, and international tax covers the residence and structuring position behind it.
