# Buying in Crete as a US Citizen: The House Is Easy, the IRS Is Not

> An American can buy in Crete on the same terms as any other non-EU buyer. What changes is everything the US expects from you afterwards — and a planned Greek transfer tax that would hit non-EU buyers from mid-2027.

- Canonical URL: https://honestcrete.com/buying/buying-in-crete-as-a-us-citizen/
- Author: Fotis (Honest Crete, Heraklion)
- Section: Buying property in Crete · Stage: Deciding
- Rules verified: October 2026 · Updated: 2026-10-04 · Published: 2026-10-04
- How to cite: "Honest Crete — Buying in Crete as a US Citizen: The House Is Easy, the IRS Is Not (rules verified October 2026), https://honestcrete.com/buying/buying-in-crete-as-a-us-citizen/"
- Disclosure: Honest Crete does not sell or list property and nobody here is an estate agent. Enquiries sent from this section go to a licensed, registered estate agent, not to us. No article names a developer or a specific property. Adverts on these pages are labelled as adverts and buy no say in the text.
- Sources:
  - IRS (read October 2026) — FBAR, FinCEN Form 114: US persons file when foreign accounts exceed $10,000 in aggregate at any time in the year; due 15 April, automatic extension to 15 October; filed electronically with FinCEN, not with the tax return: https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar
  - IRS (read October 2026) — Comparison of Form 8938 and FBAR: 8938 thresholds ($50,000/$75,000 single in the US; $200,000/$300,000 single abroad, doubled for joint filers); foreign real estate held directly is reportable on neither form; held through a foreign entity, the entity is a specified asset: https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements
  - IRS, Revenue Procedure 2021-28 (read October 2026) — section 168(g)(1)(A): property used predominantly outside the US must use ADS; ADS recovery period for residential rental property 30 years for tax years after 2017, previously 40: https://www.irs.gov/pub/irs-drop/rp-21-28.pdf
  - IRS, US–Greece income tax convention (signed Athens, 20 February 1950; read October 2026) — Article XIV(1) saving clause; Article XIV(2) Greek tax allowed as a credit against US tax; Article VIII rents from real property; no capital-gains article: https://www.irs.gov/pub/irs-trty/greece.pdf
  - UN Treaty Series, US–Greece estate tax convention (signed 20 February 1950, in force 30 December 1953; read October 2026) — Article VI credit for tax imposed by the other state on property situated there: https://www.worldlii.org/int/other/treaties/UNTSer/1954/209.pdf
  - EU Delegation to the United States, ETIAS for US citizens (read October 2026) — €20, valid three years or until passport expiry; EES biometric registration from 12 October 2025; ETIAS launch to be announced at least six months ahead: https://www.eeas.europa.eu/delegations/united-states-america/travelling-europe-etias_en?s=253
  - US Treasury, Greece FATCA Model 1 agreement (read October 2026) — Greek financial institutions report name, address, US TIN, account number and year-end balance of US account holders; self-certification required for new accounts: https://home.treasury.gov/system/files/131/FATCA-Agreement-Greece-1-19-2017.pdf
  - Πύλη Στεγαστικής Πολιτικής, stegasi.gov.gr (read October 2026) — 15% capital-gains tax on property transfers (άρθρο 41 ΚΦΕ) suspended until 31/12/2026 by ν. 5162/2024, άρθρο 90: https://stegasi.gov.gr/programs/anastoli-epivolis-forou-yperaxias-apo-metavivasi-akiniton/
  - newmoney.gr (September 2026) — transfer tax to rise from 3% to 15% for non-EU individuals buying residential property, from 1 July 2027; companies, EU citizens and long-term residents excluded; bill not yet published: https://www.newmoney.gr/roh/palmos-oikonomias/oikonomia/akinita-se-pious-epivallete-o-foros-metavivasis-15-ti-allaxe-meta-tis-antidrasis/
  - ERT News (January 2026) — 2026 rental income tax scale: 15% up to €12,000, 25% from €12,001 to €24,000: https://www.ertnews.gr/eidiseis/oikonomia/akinita-pos-tha-forologithoun-to-neo-etos-ta-eisodimata-apo-enoikia-oi-foroapallages-gia-tis-kleistes-katoikies-o-enfia-kai-oi-anakainiseis/

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An American can buy a house in Crete as easily as any other non-EU buyer: the Greek paperwork is the same, and nothing in Greek law singles out US citizens. What differs is that the United States never lets go. The house is not reported to the IRS, but the bank account behind it is, the rent is taxed twice before a credit evens it out, and the sale is taxed in dollars even while Greece's own capital-gains tax is switched off. Greece has also announced a fivefold transfer tax for non-EU buyers from mid-2027. My view: buy if you want the house and will keep the paperwork tidy, never because a Greek tax break looks generous — the IRS usually takes back what Greece forgives. Rules and figures as they stood in October 2026, checked against IRS.gov, FinCEN, the two 1950 US–Greece treaties, EU travel pages and Greek government and press sources.

I am not a lawyer or a US tax preparer, and this is not legal or tax advice. Before you buy, talk to a US-qualified accountant who handles foreign rental property and to an independent Greek lawyer. You will need both.

**Buying in Crete as a US citizen in one minute.** Crete is not one of the Greek **border areas** where non-EU buyers need a permit. You can stay **90 days in any 180** across Schengen without a visa; **ETIAS** (**€20**, valid three years) is not yet running. Your Greek account goes on an **FBAR** once all foreign accounts top **$10,000** at any point, and on **Form 8938** above **$50,000** at year-end or **$75,000** at any time (single, in the US). The house, held directly, is on **neither** form. Rent is taxed in Greece first and again in the US, with a **foreign tax credit**; US depreciation runs over **30 years**. Greece's **15%** capital-gains tax is suspended to **31 December 2026**, but the US taxes the gain anyway. A **15% transfer tax** for non-EU buyers of homes is announced for **1 July 2027** — not yet law.

## Buying is open, but the 2027 transfer tax changes the timing

Greek law (ν. 1892/1990) makes non-EU buyers get a prior permit in designated border areas — the Dodecanese, Evros, Lesvos, Samos, Chios, Santorini and a few others. Crete is not on that list. The process — tax number, bank account, lawyer, notary — is the one every foreign buyer follows; see [getting a tax number and bank account](https://honestcrete.com/buying/tax-number-and-bank-account-greece/).

The real change is cost. In September 2026 the government confirmed that the transfer tax on homes bought by non-EU individuals will rise from **3% to 15%** from **1 July 2027** — roughly €30,900 instead of €6,180 on a €200,000 house, including the municipal surcharge. Companies, EU citizens and long-term residents are reported to be excluded; converted commercial buildings are unclear. The bill had not been published by early October 2026.

## Staying: 90 days in 180, EES now, ETIAS later

A deed gives a US citizen no extra right to be in Greece. The limit is 90 days in any 180 across Schengen, and since 12 October 2025 the EU's Entry/Exit System has fingerprinted and photographed visitors at external borders, so overstays are logged, not guessed from stamps. ETIAS — a €20 authorisation valid three years — had been planned for the last quarter of 2026; in October 2026 no start date had been announced, and the EU promises at least six months' notice. Staying longer needs a residence permit, covered in [moving to Crete from outside the EU](https://honestcrete.com/buying/moving-to-crete-from-outside-the-eu/), or the [Golden Visa](https://honestcrete.com/buying/golden-visa-crete/), which in Crete means a single home of at least €800,000.

## The Greek bank account and the IRS forms

Greek banks open American accounts under the Greece–US FATCA agreement. Every year they send AADE your name, address, US taxpayer number, account number and year-end balance, and AADE passes it to the IRS. New accounts need a tax self-certification, usually an IRS Form W-9. Each American client is an annual reporting duty — which is why some branches are slower and more cautious with US persons.

The purchase money passing through that account almost guarantees an **FBAR** in the year you buy: it is due once all your foreign accounts together exceed $10,000 at any time, filed electronically with FinCEN by 15 April (automatic extension to 15 October), separately from your tax return. **Form 8938** goes with your return above $50,000 at year-end or $75,000 at any point for a single filer in the US — double for joint filers, four times if you live abroad. The IRS is explicit that **foreign real estate held directly is reportable on neither form**; held through a Greek company, the company becomes a reportable asset that includes the house's value. A non-wilful miss can cost up to $10,000 per form; a wilful FBAR violation far more.

## Renting it out: Greek tax first, then the IRS

Rent from a Crete house is taxed in Greece first: under the 2026 scale, 15% on the first €12,000 and 25% up to €24,000. Short-let rules are in [renting out your Crete home](https://honestcrete.com/buying/renting-out-your-crete-home/). The US then taxes the same rent, because citizens are taxed on worldwide income. The 1950 income tax treaty's saving clause (Article XIV(1)) lets each country tax its own citizens as if the treaty did not exist, but Article XIV(2) allows Greek tax as a credit against US tax, claimed on Form 1116. Only income taxes qualify, so ENFIA, the Greek property tax, is not creditable.

Property used predominantly outside the United States must be depreciated under the alternative depreciation system: **30 years** for residential rental property, not the 27.5 used at home. Your Greek accountant will not calculate this; your US preparer must.

## Selling and inheriting: two treaties from 1950

Greece's 15% capital-gains tax on property sales by individuals (article 41 of the Income Tax Code) is suspended until 31 December 2026 under ν. 5162/2024, with no guarantee of renewal. For an American the suspension helps less than it looks. The US taxes the gain regardless, in dollars at the exchange rates of purchase and sale, so a stronger euro alone can create a US gain — and with no Greek tax paid, there is no credit to set against it. The main-home exclusion ($250,000, or $500,000 joint) needs two of the last five years living there, which a holiday house rarely meets. The Greek side is in [selling a property in Crete](https://honestcrete.com/buying/selling-a-property-in-crete/).

Death falls under a separate US–Greece estate tax convention, signed the same day in 1950 and in force since 30 December 1953: the country of citizenship credits the other country's tax on property situated there. Greek inheritance tax still applies to the house; see [inheritance, gifts and wills](https://honestcrete.com/buying/inheritance-gifts-and-wills-crete-home/), and take the interaction to an estate specialist who knows both systems.

## The honest downside

You are signing up for two tax systems, every year, for a house you may use six weeks a summer: a Greek accountant for the Greek return and a US preparer who knows foreign rentals, FBAR and Form 1116 — and they will not coordinate unless you make them. The Greek tax breaks that make headlines, the suspended capital-gains tax above all, largely flow to the IRS when the seller is American. And the transfer tax is unsettled: rate and date are announced, but I could not find a published bill, and the exemptions are not law. Do not let a July 2027 deadline rush you past the checks that protect you.

*Disclosure:* Disclosure: Honest Crete does not sell or list property. Enquiries sent from this section go to a licensed estate agent, not to us; the full statement is below. Nothing in this article names a developer, a property, a lawyer, an accountant, a bank or any other professional, and it never will.

**The verdict.** **Worth it if** you want the house for itself, will hold it for years, and are happy to pay for clean filings on both sides of the Atlantic — ideally completing before July 2027. **Skip it if** your numbers depend on Greek tax breaks, or the thought of an FBAR, a Form 1116 and a Greek return every spring would make you resent the place.

## Quick answers

**Can a US citizen buy property in Crete?**

Yes. A US citizen can buy a house or apartment in Crete with a Greek tax number and a Greek bank account, on the same terms as other non-EU buyers. Crete is not on the list of Greek border areas where non-EU buyers need a prior permit from the Ministry of National Defence.

**Do I have to report my house in Greece to the IRS?**

A house in Greece that a US citizen owns directly, in their own name, is not reportable on FBAR or on Form 8938, according to the IRS comparison of the two forms. The Greek bank account used to buy and run the house is reportable, on FBAR once all foreign accounts together exceed $10,000 at any point in the year, and on Form 8938 above its higher thresholds. If the house is held through a Greek company, the company itself becomes a reportable foreign asset.

**Can an American stay in their Crete house as long as they want?**

No. Owning a house in Crete gives a US citizen no extra right to stay: the limit is 90 days in any 180-day period across the whole Schengen area, now recorded by the EU's Entry/Exit System. Staying longer needs a Greek national visa and residence permit, or the Golden Visa, which in Crete requires a single home of at least €800,000.

**Is rental income from a Crete property taxed in both Greece and the US?**

Rent from a Crete property is taxed in Greece first, at 15% on the first €12,000 and 25% up to €24,000 under the 2026 scale. A US citizen must also report the same rent on their US return, because the US taxes citizens on worldwide income. The Greek income tax is then claimed as a foreign tax credit on Form 1116, and US depreciation on the building runs over 30 years rather than the 27.5 used at home.

**Do Americans pay capital gains tax when selling a house in Crete?**

Greece's 15% capital-gains tax on property sales by individuals is suspended until 31 December 2026. The US taxes a citizen's gain on a Crete sale regardless, calculated in dollars using the exchange rates at purchase and at sale. With no Greek tax paid, there is no Greek credit to offset the US bill.

**Is there a new 15% tax for Americans buying property in Greece?**

The Greek government has announced that the property transfer tax for non-EU individuals buying residential property will rise from 3% to 15%, applying from 1 July 2027. Companies, EU citizens and long-term residents are reported to be excluded, and the treatment of converted buildings is still unclear. As of October 2026 the bill had not been published, so the final rules may differ.