DAC7 and FATCA: Cross-Border Tax Reporting for UK and US Owners with Greek Airbnb

DAC7 and FATCA: Cross-Border Tax Reporting for UK and US Owners with Greek Airbnb

Airbnb reports your Greek rental income to ΑΑΔΕ automatically under DAC7. ΑΑΔΕ then sends that data to HMRC (UK) and the IRS (US). This guide explains the full reporting chain, your dual-filing obligations, the 1953 UK-Greece double tax treaty credit mechanism, and FATCA Form 8938 for US owners.

If you own a property in Greece and rent it via Airbnb or Booking.com, the platform is legally required to report your income to the Greek tax authority (ΑΑΔΕ) under DAC7 (EU Directive 2021/514, transposed in Greece via Law 4987/2022 art. 15C). ΑΑΔΕ then exchanges that data with HMRC under the UK-EU information exchange framework and with the IRS under FATCA (Foreign Account Tax Compliance Act, 26 U.S.C. 1471-1474). This means your Greek rental income reaches your home-country tax authority whether you declare it or not. Understanding the chain matters: mismatches between your Greek Ε1/Ε2 return and what HMRC or the IRS received from ΑΑΔΕ are a high-probability audit trigger.

How DAC7 works in Greece

DAC7 (Council Directive EU 2021/514, Greek implementation Law 4987/2022) requires digital platforms facilitating property rental to collect, verify and report seller data to the competent tax authority. For Greece, the competent authority is ΑΑΔΕ (Ανεξάρτητη Αρχή Δημοσίων Εσόδων). Reporting covers:

• All rental transactions regardless of amount (no de minimis threshold for Greek property)
• Gross rental revenue (including cleaning fees and other platform charges collected)
• Number of rental days
• Property address and ΑΜΑ registration number
• Host ΑΦΜ (Greek tax ID) and home-country tax identification number

Airbnb, Booking.com, VRBO and all other in-scope platforms submitted their first DAC7 reports to ΑΑΔΕ covering calendar year 2023 by 31 January 2024. Reports for 2024 were submitted by 31 January 2025. The deadline follows the EU standard: last day of January following the calendar year.

ΑΑΔΕ cross-references the platform data against your Ε2 supplementary schedule (rental income declaration attached to your Ε1 annual return, due by 30 June). If the amounts mismatch by more than 10%, ΑΑΔΕ issues a preliminary assessment notice. Penalties under the Greek Tax Procedure Code (Law 4174/2013 art. 58) start at 10% of the assessed tax and rise to 100% for tax evasion classification.

The automatic exchange chain: ΑΑΔΕ to HMRC and the IRS

Once ΑΑΔΕ receives DAC7 data from platforms, it participates in two separate automatic exchange frameworks:

For UK residents: The UK withdrew from the EU DAC7 framework after Brexit but signed the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAC). Under the MAC and bilateral information exchange agreements, ΑΑΔΕ routinely shares tax residency data with HMRC. Additionally, the UK enacted its own domestic platform reporting rules (UK DPMR, effective from 1 January 2024) and HMRC and ΑΑΔΕ exchange data bilaterally. In practice, HMRC receives a data file from ΑΑΔΕ containing your Greek Airbnb income no later than September of the year following the tax year.

For US residents: Greece and the US operate under a FATCA Inter-Governmental Agreement (IGA Model 1). ΑΑΔΕ sends US persons' account information to the IRS annually via the IGA channel. Separately, Airbnb itself (as a US-headquartered company) files Form 1099-K if you receive more than $600 in US-processed payments (threshold reduced by the IRS from $20,000 starting tax year 2023). The combined effect: the IRS typically has your Greek rental data from two separate channels.

UK owner obligations: Ε1/Ε2 plus SA106

As a UK tax resident owning rental property in Greece you must file in both jurisdictions:

In Greece: File Ε1 (annual personal tax return) and attach Ε2 (rental income schedule) by 30 June each year. You pay Greek tax on rental income at progressive rates: 15% on the first 12,000 EUR, 35% on 12,001-35,000 EUR, 45% above 35,000 EUR. Deductible expenses are limited: you may deduct 40% of gross rental income as a flat allowance (no itemised deductions for repairs, management fees or mortgage interest). Net income after the flat deduction is the taxable base.

In UK: Report Greek rental income on HMRC Self Assessment (SA100 main return + SA106 foreign income supplement). The SA106 requires: gross rental income in EUR converted to GBP at the HMRC average rate, less allowable UK expenses (UK rules allow more deductions than Greece), and the Greek tax credit claimed under the 1953 UK-Greece Convention.

The 1953 UK-Greece Double Tax Treaty

The Convention between the UK and Greece for the avoidance of double taxation (signed 25 June 1953, in force 25 October 1954) remains the operative treaty. It was never replaced by a modern OECD-style convention. Article 3 covers immovable property income: Greece has primary taxing rights on rental income from property situated in Greece. The UK gives credit for Greek tax paid against the UK tax liability on the same income.

Practical calculation for a UK resident earning 20,000 EUR (approx. 17,000 GBP) Greek Airbnb income:

Step	Greece	UK
Gross income	20,000 EUR	17,000 GBP (converted)
Deductions	8,000 EUR (40% flat)	Actual expenses e.g. 4,000 GBP
Taxable income	12,000 EUR	13,000 GBP
Tax rate	15%	40% (higher rate band)
Tax charged	1,800 EUR	5,200 GBP
Treaty credit	N/A	Credit: Greek tax paid approx. 1,530 GBP
Net UK liability	N/A	approx. 3,670 GBP

The credit is limited to the lower of the Greek tax actually paid or the UK tax attributable to the same income. Unused credit cannot be carried forward. File HMRC form SA106 page F3 (Foreign Tax Credit Relief) with the Greek tax assessment (φορολογική ενημερότητα) as supporting documentation.

US owner obligations: FATCA, Form 8938, Schedule E

US persons (citizens, green card holders, substantial presence residents) must report worldwide income regardless of where they live. For Greek STR income:

• Schedule E (Form 1040): Report net rental income. US rules allow more deductions than Greece: depreciation (39 years for foreign residential rental, IRS Rev. Proc. 87-56), management fees, repairs, insurance, mortgage interest, professional fees. Most foreign rental owners show a US Schedule E loss due to depreciation, which may suspend against passive income.
• Form 1116 (Foreign Tax Credit): Claim credit for Greek Ε1 tax paid against US federal income tax. The foreign tax credit is limited to the ratio of foreign income to total income times total US tax liability. Excess credit can be carried back 1 year and forward 10 years (26 U.S.C. 904(c)).
• Form 8938 (FATCA): If total foreign financial assets exceed $50,000 (single, end of year) or $75,000 (at any point during the year), file Form 8938. A Greek property itself is not a foreign financial account, but proceeds held in a Greek bank account above the threshold are reportable. Most rental owners with a Greek ΑΦΜ also hold a Greek Eurobank or Alpha Bank account for local payments.
• FinCEN Form 114 (FBAR): If aggregate foreign bank balances exceed $10,000 at any point during the year, file FBAR by 15 April (auto-extension to 15 October). A Greek rental account almost always crosses this threshold during peak season deposits.

Common mismatches and how to avoid them

ΑΑΔΕ's DAC7 reconciliation software flags discrepancies between platform reports and Ε2 declarations. Common triggers for foreign owners:

• Currency mismatch: Airbnb reports in EUR but your ΑΦΜ may have a foreign address. Ensure the Ε2 figure matches the platform-reported EUR amount exactly, not a converted figure.
• Cleaning fees excluded: ΑΑΔΕ treats platform-collected cleaning fees as part of rental income on Ε2. Some owners declare only the accommodation fee. Include all amounts Airbnb collected on your behalf.
• Blocked nights not deducted: You cannot deduct nights where you blocked the calendar for personal use unless you have documentation (ΑΑΔΕ does not allow a blanket personal-use deduction).
• ΑΜΑ not matching property: The ΑΜΑ on the platform listing must match the property registered with ΑΑΔΕ. A mismatch triggers a platform compliance flag under Νόμος 5170/2025 art. 8.

Frequently asked questions

Does DAC7 apply if I rent fewer than 30 days per year in Greece?

Yes. Greece chose not to implement the EU optional 2,000 EUR / 30 activity de minimis threshold. All Greek STR rental income is reportable under Law 4987/2022, regardless of how few nights you rent. Even a single booking is reported by the platform to ΑΑΔΕ.

What happens if ΑΑΔΕ and HMRC data do not match my self-assessment?

HMRC receives the ΑΑΔΕ DAC7 data and runs automated matching against SA106 returns. If the Greek income figure in HMRC's data file exceeds what you reported on SA106 by more than 10%, HMRC may open a compliance check under TMA 1970 s9A. You then have 30 days to explain the discrepancy or amend the return. Interest runs from the original filing date at the Bank of England rate plus 2.5%. Penalties for careless error start at 15% of the underpaid tax.

Can I claim both the Greek flat 40% deduction and UK actual expenses?

Yes, in different countries. Greece mandatorily applies the 40% flat deduction to gross rental income for Ε2 purposes. The UK does not recognise the Greek flat deduction: you declare gross Greek income on SA106 and deduct actual allowable UK expenses (agent fees, repairs, proportion of mortgage interest if applicable). The two calculations are independent. You do not need to use the same expense base in both countries.

What is the US-Greece tax treaty position?

The US and Greece do not have a modern income tax convention. The operative framework is the 1950 Greece-US Agreement on Friendship, Commerce and Navigation plus general US domestic law (26 U.S.C. 901 foreign tax credit). There is no specific property article. US owners claim a Form 1116 foreign tax credit for Greek Ε1 tax paid. The credit is limited to the US tax attributable to the same income (category limitation applies: rental income is passive category under 26 U.S.C. 904(d)(1)(A)).

How do I get a Greek tax clearance certificate to prove I paid Ε1 tax?

Log into myAADE (myaade.gov.gr) using Taxisnet credentials (set up via ΑΦΜ). Navigate to Tax Clearance (Φορολογική Ενημερότητα). You can generate a digital certificate valid for 30 days free of charge. This certificate is what you submit to HMRC as proof of foreign tax paid when filing SA106 FTCR (Foreign Tax Credit Relief). For US Form 1116, retain the Greek Ε1 assessment (Εκκαθαριστικό) showing tax charged and paid.

Read also

• Greece Airbnb Registration 2026: Complete Guide for UK and US Owners
• UK-Greece Double Tax Treaty for STR Rental Income 2026
• Greek Property Tax (ΕΝΦΙΑ) for Foreign Owners 2026
• ΑΦΜ for Foreign Property Owners 2026: 5-Step Setup from London or NYC

Informational, not legal or tax advice. DAC7 implementation details and ΑΑΔΕ guidance evolve. FATCA thresholds and Form 1116 limitation rules are subject to IRS rulemaking. Consult a licensed tax adviser in both jurisdictions before filing. Figures cited reflect 2026 status.