Updated: 2025-09-14
✅ Checklist: How to declare UCITS ETF investments in Greece
- Ensure the ETF is UCITS and domiciled in an EU or EEA country
- Keep all documentation (statements, commission receipts, screenshots)
- Declare purchase amount in code 743-744 (cost + commissions)
- Declare sale proceeds in 781-782
- Declare net capital gains in 659-660 as tax-exempt income
- If the ETF is accumulating (e.g. VWCE, VUAA, IWDA), don’t declare dividends, only sales
- If distributing, declare dividends in 659-660
- Keep complete records for potential AADE audit
What are UCITS ETFs
UCITS ETFs are mutual funds that trade on stock exchanges and operate under the European UCITS directive. These funds are subject to a small tax on their assets, so investors are exempt from capital gains tax or dividend tax in Greece, as long as they properly declare their details.
Requirements for Tax Exemption
For the capital gains and dividend tax exemption to apply, all of the following conditions must be met:
- Tax Residency: The investor must be a Greek tax resident
- Fund Domicile: The ETF must be UCITS-compliant and domiciled in an EU or EEA country
- Personal Investment: The investment must not be part of business/enterprise activity
- Shareholding Threshold: Must not exceed the shareholding threshold defined by law
- Proper Declaration: All transactions must be declared in the correct E1 tax form codes
Important: Even when income is tax-exempt, you must still declare it in the E1 form. Failure to declare can result in penalties.
Examples of popular UCITS ETFs:
- VWCE – Vanguard FTSE All-World UCITS ETF (accumulating)
- VUAA – Vanguard S&P 500 UCITS ETF (accumulating)
- IWDA – iShares Core MSCI World UCITS ETF (Acc)
- VWRL – Vanguard FTSE All-World UCITS ETF (distributing)
Declaring UCITS ETFs in E1: Codes and procedure
UCITS ETF investments are declared in the following E1 tax form codes:
E1 Tax Form Codes
| Code | What to Declare | Tax Treatment |
|---|---|---|
| 743-744 | Purchase cost of units/shares | — |
| 781-782 | Gross sale proceeds | Mandatory declaration |
| 659-660 | Net gain (if positive) | Report even if exempt |
| 659-660 | Dividends (distributing ETFs) | Report even if exempt |
Note: Even when capital gains or dividends are tax-exempt, you must declare both the gross sale proceeds (781-782) and the net gain (659-660). Declaration is mandatory even for tax-exempt income.
Examples
Example 1: Accumulating ETF (VWCE)
- Purchase: €5,000 + €20 commission
- Sale after two years: €6,400 – €20 commission
- Net proceeds: €6,380
- Capital gain: €1,360
E1 Declaration:
- 743-744: €5,020
- 781-782: €6,380
- 659-660: €1,360 (capital gain, tax-exempt)
Example 2: Accumulating ETF (VUAA) – Partial sale
- Purchase: €3,000 + €10 commission
- Partial sale: proceeds €1,900 – €10 commission
- Net proceeds: €1,890
- Capital gain: €440
Declaration:
- 781-782: €1,890
- 659-660: €440 (gain, tax-exempt)
- No dividend declaration required.
Example 3: Distributing UCITS ETF (VWRL)
- Purchase: €4,000 + €15 commission
- Dividends received during year: €120
- Sale: €4,300 – €15 commission
- Net sale proceeds: €4,285
- Capital gain: €270
E1 Declaration:
- 743-744: €4,015
- 659-660: €120 (dividends, tax-exempt)
- 781-782: €4,285 (sale proceeds)
- 659-660: €270 (capital gain, tax-exempt)
Dividends are declared in the same code (659-660) but separately from capital gains, to maintain clear records.
Tips for proper record keeping
- Keep all broker statements showing purchase dates, amounts, and commissions
- Screenshot fund fact sheets proving UCITS status and EU domicile
- Document dividend payments with exact dates and EUR amounts
- Calculate gains in EUR using exchange rates on transaction dates
- Separate accumulating vs distributing fund transactions clearly
Common mistakes to avoid
- Failing to declare at all: Even tax-exempt income must be declared – failure to declare can result in penalties.
- Declaring only gains without proceeds: You must declare both gross sale proceeds (781-782) and net gains (659-660).
- Wrong code: Declaring capital gains in a non-exempt field.
- Forgetting commissions: Not including commissions in purchase cost or sale proceeds.
- Overgeneralization: Assuming all ETFs have the same tax treatment – only UCITS domiciled in EU/EEA are exempt.
- Dividends: Failing to declare dividends from a distributing ETF.