How Does Dual Citizenship Affect Inheritance Rights in Greece?

For the millions of Greeks abroad who hold both Greek and another citizenship, the interaction between dual citizenship and inheritance rights is an important and often misunderstood area. The short answer is that holding dual citizenship does not diminish your inheritance rights in Greece in any way, but it does create a set of questions about which country's law governs your estate and how your assets in multiple countries will be treated after your death.

Greek Nationality Always Takes Precedence

When a person who holds Greek citizenship alongside another nationality passes away, Greek law is unambiguous on one point. In case the deceased had multiple citizenships, Greek nationality takes precedence. This means that for Greek citizens who also hold American, Australian, Canadian, or British citizenship, Greek inheritance law governs the succession of their Greek assets regardless of what the other country's law might say. Your Greek citizenship is always the dominant factor when Greek assets are involved.

Your Rights as a Dual Citizen Heir Are the Same as Any Greek Heir

If you are a dual citizen inheriting from a Greek relative, your inheritance rights are identical to those of any other Greek citizen heir. You are entitled to your full legal share of the estate, subject to the same rules on forced heirship, the same tax obligations, and the same deadlines. Your second citizenship does not reduce your share, change your tax category, or affect the documentation you need to provide. You are treated as a Greek heir in every legal sense. If you have Greek ancestry but have not yet formally obtained your Greek citizenship, that step is worth taking before an inheritance situation arises. Visit our Greek Citizenship page to find out if you qualify and how GetGreece can help.

Which Country's Law Governs Your Own Estate

This is where dual citizenship creates genuine complexity. When you pass away, the question of which country's inheritance law governs your estate depends on several factors. Under EU Regulation 650/2012, which applies to all EU member states, the default rule is that the law of the country where you habitually resided at the time of death governs your entire estate. This means a Greek-American who has lived their whole life in the United States may have American succession law govern their estate by default, even for their Greek property.

However, the regulation also allows you to make a choice of law in your will, selecting the law of your nationality to govern your succession. For a Greek-American, this means you can explicitly choose Greek law to govern your entire estate in your will, or alternatively choose American law. This choice has significant implications, particularly around forced heirship. Greek law imposes mandatory shares for close relatives that cannot be overridden, while American law in most states gives testators far more freedom to distribute their assets as they wish.

The 25-Year Rule for Greeks Abroad

One of the more technical but meaningful provisions in Greek inheritance law involves Greeks who have lived outside Greece for at least 25 consecutive years. Under Article 21 of Law 1738/1987, which was proposed for abolition in the 2026 reform but ultimately retained, Greeks who have resided abroad for 25 or more consecutive years are exempt from Greek forced heirship rules for assets located outside Greece. This means a Greek-American who has lived in the United States for 25 or more years has greater freedom to distribute their foreign-located assets by will without being constrained by the Greek nomimi moira rules. Greek property is still governed by Greek law regardless of this exemption.

Double Taxation Considerations

Dual citizens who inherit assets in both Greece and another country may face double taxation on the same inheritance if both countries impose inheritance or estate taxes. Greece taxes inheritance on Greek-located assets for all heirs regardless of where they live. The United States, for example, also imposes federal estate taxes on certain estates. Whether a tax treaty between Greece and your country of residence reduces or eliminates this double exposure depends on the specific treaty and the structure of the estate. Professional tax advice from someone familiar with both systems is important in these situations.

Estate Planning Matters More for Dual Citizens

Dual citizenship creates more planning opportunities but also more complexity. The ability to choose governing law, the interaction between two countries' forced heirship rules, and the potential for double taxation all mean that dual citizens with Greek assets benefit significantly from proper estate planning. A Greek will that explicitly addresses your Greek assets and makes a clear choice of law removes much of the ambiguity that heirs would otherwise face. GetGreece can assist with Greek estate planning as part of the Property Inheritance and Estate Planning service, helping you structure your affairs so your wishes are respected and your heirs are not left navigating competing legal systems.