Moving to Greece from Canada or Australia: one of you has a treaty that exempts the first CAD 15,000 of pension, the other has no treaty at all

A page about moving to Greece from a particular country is usually a page about Greece with the country's name in the title. The routes, the thresholds and the clocks are the same whoever you are, and they are proved elsewhere on this site with the instrument behind each figure.

What differs by origin is whether the country you are leaving stops taxing you, and on what terms. For Canada and Australia the answers are not variations of each other. They are opposites.

The short answer. Canada decides whether you have left on residential ties rather than on a day count, and the Canada–Greece convention signed at Athens on 29 June 2009 then decides the money: its pension article lets Greece tax a Canadian pension, but Canada must exempt the first fifteen thousand Canadian dollars of pensions paid to a Greek resident in a calendar year, with periodic payments above that capped at the lesser of 15% and a rate based on your Greek tax. Australia taxes residents on worldwide income under four statutory tests, and has no income tax treaty with Greece: the Australian Taxation Office's own list of treaty countries, updated 30 May 2026, names Greece with an airline profits agreement only. So the Australian case has no tie-breaker to invoke and no pension article to rely on.

The Greek half is the same for both, and it is proved elsewhere on this site

Nothing in Greek law turns on whether you arrive from Toronto or from Melbourne. Residence by investment asks €800,000 in Attica and €400,000 elsewhere with two €250,000 exceptions; living on your own income asks €3,500 a month; remote work runs under article 68 of Law 5038/2023; retirement has no visa of its own and uses the sufficient-resources permit; and citizenship is three, seven or twelve years depending on nationality and on whether your residence title is on a closed list.

Every one of those is set out with its instrument and the date it was read in moving to Greece, which routes to the page that proves each one. This page does not repeat them and does not introduce a Greek figure of its own.

Moving to Greece from Canada: residential ties, not a day count

The Canadian departure test is the same wherever you are going, and we proved it at source for the Dubai case: the Canada Revenue Agency decides residency on residential ties rather than on days, with a home in Canada, a spouse or common-law partner in Canada and dependants in Canada as the three significant ties. Keeping them while living abroad can leave you a factual resident, taxed as one.

The detail, with the CRA's own wording and the dates, is on moving to Dubai from Canada or India. What follows is the part that is specific to Greece, because the treaty that resolves a double claim is a different instrument for every destination.

The Canada–Greece pension rule exempts the first CAD 15,000 at source

Article 18 of the convention is the provision with money attached, and it is built in an unusual way.

Paragraph 1 lets the state where you are resident tax a pension arising in the other state. Paragraph 2 then lets the source state tax it as well — but with a floor carved out first: the source state "shall exempt from tax fifteen thousand Canadian dollars or the equivalent amount in euros" of the total pensions paid to a resident of the other state in a calendar year. Above that exemption, tax on periodic pension payments is capped at the lesser of two figures: 15% of the gross amount above the threshold, and a rate computed by reference to the tax the recipient would pay in the state of residence.

Paragraph 3 deals with annuities separately and caps the source state's tax at 15% of the portion taxable there, excluding lump-sum surrender payments and certain payments under contracts whose cost was deductible. A note on the text we read: the published English version prints this figure as "l5 per cent", with a lowercase letter L in place of the digit one. We read it as 15% because paragraph 2 uses 15% for the same purpose, and we say so rather than silently correcting a government text.

Social security pensions are not given their own rule in article 18. The only place the convention touches them is article 28(3), which defines "pension plan" to include "a pension plan created under the social security system in a Contracting State" — and that provision is about the treatment of contributions, not about taxing payments. So this page does not state a separate answer for a CPP or OAS payment, because the article we read does not give one.

The same Canadian pension is treated differently in Greece and in Portugal

This is the comparison only available from having read both conventions, and we have.

For a retiree with a modest Canadian pension the difference is not cosmetic: under the Greek convention the first CAD 15,000 a year is outside Canadian tax altogether, where under the Portuguese one the 15% applies from the first dollar. Two destinations, one departure country, and a measurable gap that follows from the drafting rather than from anything about either country's tax rates.

The Portuguese side of that comparison is set out, with the article quoted, on moving to Portugal from Canada, India or South Africa.

Where the Canada–Greece tie-breaker reaches nationality, and where it stops

Article 4(1) defines a resident of a state as a person liable to tax there "by reason of the person's domicile, residence, place of management or any other criterion of a similar nature".

Article 4(2) then decides between two claims, in a fixed order:

• (a) the state where you have a permanent home; if you have one in both, the state of your centre of vital interests, meaning closer personal and economic relations;
• (b) failing that, the state of your habitual abode;
• (c) if you have a habitual abode in both or in neither, "the State of which the individual is a national";
• (d) if you are a national of both or of neither, the competent authorities settle it by mutual agreement.

Two things are worth drawing out. Nationality is in this treaty, at step (c) — unlike the UK–UAE convention, where it plays no part, which is set out on moving to Dubai from the UK. And the order means a home kept in Canada is examined long before your passport is: the first question is where the permanent home is, not who you are a citizen of.

For companies, article 4(3) inverts the usual order and puts nationality first, with place of effective management second. We note it because it is unusual, and because a reader moving a company rather than a household will want to start there.

Moving to Greece from Australia: there is no income tax treaty, and the ATO's own list says so

The Australian Taxation Office publishes a list titled "A list of the countries and jurisdictions that have a tax treaty with Australia", as an attachment to its guide to the foreign income tax offset rules. We read it on 12 November 2026; the page is last updated 30 May 2026.

Greece appears on that list — with "Airline Profits Agreement only" beside it. There is no comprehensive income tax convention between Australia and Greece on the list we read.

That distinction is exactly the sort of thing a reader is likely to get wrong, and not through carelessness: the country is on the treaty page, so a glance suggests a treaty exists. What exists covers the profits of airlines. It does nothing for a pension, a tie-breaker or a rate at source.

Three consequences, each the mirror image of something the Canadian half of this page relies on:

• No residence tie-breaker. If both Australia and Greece treat you as resident, nothing in a treaty decides between them.
• No pension article. There is no equivalent of the CAD 15,000 exemption, and no cap on what either side may charge.
• No reduced withholding at source on dividends, interest or royalties, and no mutual agreement procedure to take a dispute to.

One more thing from the same list, because it bears on another page here: Portugal is listed as "not yet entered into force as at 18 March 2026", as are Croatia, Slovenia and Ukraine. So an Australian moving to Portugal is, on that list, in the same treaty-less position for now.

What an Australian resident is taxed on, and the four statutory tests

From the ATO's own page on being an Australian resident for tax purposes, last updated 3 June 2026: "If you're an Australian resident for tax purposes, you must declare all income you've earned in Australia and overseas" — and that obligation holds even if you have already paid tax on that income overseas, which is the sentence that matters most when there is no treaty to prevent the second charge.

The page states that "There are 4 statutory tests to determine your residency" and names them: the resides test, the domicile test, the 183-day test and the Commonwealth Superannuation test.

On thresholds it gives two figures: residents get "the full tax-free threshold of $18,200", and "Part-year residents have a tax-free threshold of at least $13,464", with the remaining $4,736 pro-rated by the number of months of residency. The year you leave is therefore usually a part-year, and the threshold in that year is not the full one.

What the ATO page does not say: whether residency ends when you leave

We looked for it and it is not there. The page we read does not state what happens to residency when a person leaves Australia permanently, or whether residency ends on departure. All it says on timing is that a part-year resident must include "the date that you became or stopped being an Australian resident for tax purposes" — which assumes an answer the page does not give.

So this page names the four tests and does not tell an Australian which of them ends their residency or when. The ATO has a public ruling on residency for individuals; the page we read does not cite one and we did not read it. That is the next piece of work on the Australian side, and until it is done we would rather point at the gap than fill it.

What no treaty means in practice for an Australian in Greece

The relief mechanism in that situation is domestic rather than treaty-based, and the clue is in where the ATO keeps its treaty list: inside the guide to the foreign income tax offset rules. That offset is the Australian credit for foreign tax paid, and it is what stands between an Australian taxed in both countries and paying twice.

We did not read those rules, so this page states no limit, no formula and no cap for the offset, and no equivalent for the Greek side. With no treaty, that credit is the whole of the machinery, which makes it the thing to take to an adviser in both countries rather than the thing to read about on a page.

The order to do this in

1. Settle the Greek route first, because the thresholds and the clocks are the same whoever you are and they decide the timetable: moving to Greece.
2. Canadians: decide between severing ties and relying on the treaty, because they are different routes with different evidence. The CRA decides on residential ties, and the convention only arbitrates once two countries both claim you.
3. Canadians with a pension: do the arithmetic on CAD 15,000 before choosing a destination. The same pension meets a 15% cap from the first dollar in Portugal and a clear exemption for the first CAD 15,000 in Greece.
4. Australians: assume no treaty and plan around the credit. There is no tie-breaker and no pension article; the foreign income tax offset is the mechanism, and we have not read its rules.
5. Australians: expect a part-year in the year you leave, with a tax-free threshold of at least $13,464 rather than the full $18,200.
6. Both: get the departure test confirmed at home, not in Greece. Nothing Greece does decides whether Canada or Australia has let go.

What this page does not state

Whether Australian residency ends on departure. The ATO page we read does not say, and we did not read the ruling it does not cite.

The foreign income tax offset rules. Named as the mechanism, not described. No limit, formula or cap appears here.

Greek figures of our own. Every Greek number on this site is proved on the page that quotes its instrument; this page routes and does not restate.

Social security pensions under the Canada–Greece convention. Article 18 gives them no separate rule and article 28(3) is about contributions, so we state no answer for CPP or OAS.

The Canada–Greece convention's other articles. We read articles 4, 18 and 28(3). Employment income, business profits and the credit articles are not on this page.

Frequently asked questions about moving to Greece from Canada or Australia

Where each part of this is proved

Article 4(1), the tie-breaker order in 4(2), the inverted order for companies in 4(3), article 18(1) to 18(3) with the CAD 15,000 exemption, the cap on periodic payments and the annuity rule, article 28(3) on pension plans, and the signing at Athens on 29 June 2009 come from the Convention between Canada and the Hellenic Republic as published by the Department of Finance of Canada, read on 12 November 2026. The absence of an income tax treaty between Australia and Greece, the airline-profits-only entry and the not-yet-in-force entries for Portugal, Croatia, Slovenia and Ukraine come from the Australian Taxation Office's list of countries and jurisdictions that have a tax treaty with Australia, last updated 30 May 2026, read the same day. The worldwide-income statement, the four statutory tests and the tax-free threshold figures come from the ATO's page on being an Australian resident for tax purposes, last updated 3 June 2026. Each is on the sources page.

The Canadian departure test on residential ties is quoted from the Canada Revenue Agency on moving to Dubai from Canada or India, and recorded under the Emirates where it was first read: the CRA line. The Greek side: routes, thresholds and the five corrections in moving to Greece; the investment route and its price zones in Greek residency; the three, seven and twelve-year clocks in Greek citizenship; the absence of a retirement visa and the 7% regime in retiring in Greece; article 68 and the remote-work permit in the Greek digital nomad visa; the cost of living from the state's own survey in living in Greece; and the border areas, which almost nothing in English mentions, in buying a Greek island. The same axis for a third destination: moving to Portugal from Canada, India or South Africa, and for a treaty-less case proved off an official list, moving to Argentina from the US.