# Reselling Units Under Greece's €250k Change-of-Use Route > How a buyer of the whole MVR 19 building could resell converted studios under Greece's €250,000 change-of-use route, and the rules that bind each sale. Canonical: https://b2b.mav19-goldenvisa.com/resale-route Offered by TPL S.A., developer of MVR 19 · TPL S.A. · Ethnomartyron 40, 263 33 Patras, Greece · VAT EL800864603 · GEMI 143336716000 · LEI 9845006C601CB29D1H76 Generated: 2026-09-28. A Markdown mirror of the page above; the HTML page is authoritative. --- ## Reselling the units under the €250,000 change-of-use route What Greek law allows a buyer of the whole MVR 19 building who completes the change of use and sells the studios one by one, and what binds every one of those sales. Taken from the primary texts, with their limits. By TPL S.A., the developer of MVR 19 · Sources last checked 28 September 2026 · General information, not legal advice [Request the information pack](https://b2b.mav19-goldenvisa.com/enquire) Under art. 100 §2(c) of Law 5038/2023, as replaced by art. 64 of Law 5100/2024, a non-EU national may qualify for a Greek investor residence permit by buying one property worth at least €250,000, anywhere in Greece and with no minimum size, whose main areas have been converted from another use to residence. The change of use may be carried out by the seller or by the buyer of the property. A buyer of the whole building would become the seller of each unit and could carry out the conversion itself. Eligibility of each unit is subject to the change of use being completed under a permitting act issued on or after 5 April 2024; completion before the buyer applies; and the full price being paid before the application, by bank transfer, crossed cheque or card into the seller's account at an institution operating in Greece, by the buyer, the spouse or relatives by blood or marriage to the 2nd degree. The Ministry decides each application. Where MVR 19 stands. The whole building is offered as it stands: a concept design for 19 studios is complete; the change-of-use permitting act has not been issued. The intended conversion is from non-residential to residential use. The building's legal use on 5 April 2024 is under verification and will be evidenced in the data room (building permit and cadastre record). If any part of the building was residential in legal use on 5 April 2024, that part cannot use the €250,000 route (Circular 1/2026, Clarification 5). The Ministry decides each application. TPL makes no representation that any unit will qualify. ## The legal basis Three texts govern the route, and the official procedure page applies them. Two more govern the money checks around each sale. The Greek texts govern; the English summaries on this page are ours. Texts read for this page, with what each does for a seller of converted units. Sources last checked 28 September 2026. Instrument | What it does Law 5038/2023 (Migration Code), art. 100, as replaced by art. 64 of Law 5100/2024 Gazette A' 49, 5 April 2024 | Sets the investment tiers, including the €250,000 change-of-use route (§2(c)); full payment before the application and the permitted payment methods and payers (§3, §5, §6); the letting ban (§7A); and the certificate a non-EU seller produces at every sale (§11). Joint Ministerial Decision 214926/2025 Gazette B' 6014, 11 November 2025 | Lists the applicant's documents. Art. 2 §2.6 fixes the change-of-use file, including the engineer's technical report per unit. Circular 1/2026, Ministry of Migration and Asylum Prot. 72019, 21 April 2026 | Interpretive guidance: several apartments from one conversion (§I.2); storage and parking (Clarification 2); timing and existing buildings (5); letting (7); once-only (9); completion (20); Russia and Belarus (22); misleading advertising and money transfers (23). mitos.gov.gr procedure | The official procedure page for the investor residence permit under the change-of-use route (initial issuance): documents and processing time. Law 4557/2018 | Anti-money-laundering duties of the banks, notaries, lawyers and estate agents involved in each sale. Regulation (EU) 2024/1624 | From 10 July 2027, covers investment migration operators and requires enhanced due diligence on every customer applying for residence by investment. ## The conditions, unit by unit Each end buyer's application is tested on its own unit, its own deed and its own file. All of these must hold when that buyer files. - A non-EU buyer. In its own name, or through a company seated in Greece or another EU member state that it owns 100%. - One property, at least €250,000. Anywhere in Greece, with no minimum size. Two apartments cannot be combined to reach €250,000. - A conversion of an existing building. The main areas change from another use to residence. A property that was residential in legal use on 5 April 2024 cannot use the route. - A permitting act issued on or after 5 April 2024. A building permit, small-scale works approval, file update or permit revision. An act issued earlier counts only if updated or revised on or after that date. - Completion before the buyer applies. The change of use must be completed before the application is filed. - Full payment before the application. By bank transfer, crossed cheque or card, into the seller's account at an institution operating in Greece, by the buyer, the spouse or relatives by blood or marriage to the 2nd degree. - Industrial buildings. If any part was industrial, proof of no industrial operation in the last five years. - Residential use. Long-term letting only; the unit may not be a company's seat or branch. - The Ministry decides. The Ministry of Migration and Asylum decides each application. ## Who carries out the conversion The change of use may be carried out by the seller or by the buyer of the property. A buyer of the whole building would become the seller of each unit and could carry out the conversion itself. Each unit's eligibility is decided by the Ministry on that unit's own sale and file. ### What it means for a buyer of the whole building The whole building is offered as it stands: a concept design for 19 studios is complete; the change-of-use permitting act has not been issued. A buyer would therefore take the building before the conversion and, as seller of each unit, could carry out the conversion itself and produce for every end buyer the documents listed under the end buyer's file. Offers are invited for the building as it stands. No guide price is published. Other structures can be discussed. Subject to contract, due diligence and a notarial deed. How the route would apply to any other structure is a question for your counsel; the process is on [acquisition and due diligence](https://b2b.mav19-goldenvisa.com/acquisition). Studios are also offered individually; a whole-building agreement covers the studios not reserved or sold when it is signed. Offered by TPL S.A., the developer of MVR 19. Title documents (deed, KAEK, cadastre extract, encumbrance certificates) will be provided in the data room. More on [who is selling](https://b2b.mav19-goldenvisa.com/seller). MVR 19 is the conversion of an existing building, not a new build. This photograph shows it as it stands on Mavromataion Street, before works. ## Several apartments from one conversion Where one conversion produces several apartments, each apartment is a separate property and can qualify on its own at €250,000 or more. Eligibility of each is subject to the conditions above, and the Ministry decides each application. Two apartments cannot be combined to reach €250,000. A parking space or storage room in the same building, in the same notarial deed and used as ancillary space, counts toward the value, not toward the area. MVR 19's storage rooms are under verification: the project brief provides for 9 storage rooms; they are not shown on the concept drawings; their existence, sizes and cadastral codes are under verification. ### Keeping a unit for your own permit If a non-EU investor who carried out the conversion keeps one of the resulting apartments for its own permit, it must prove, with a report from a certified valuer (register under Law 4152/2013), that the retained apartment alone is worth at least €250,000. This page makes no statement on whether any MVR 19 studio would meet that test. No registered valuer's report has been commissioned. ## Timing The permitting act (building permit, small-scale works approval, file update or permit revision) must be issued on or after 5 April 2024; an act issued earlier counts only if updated or revised on or after that date. The change of use must be completed before the buyer applies. The route applies to the conversion of an existing building. A property that was residential in legal use on 5 April 2024 cannot use it. A new building permit for a non-residential use, issued on or after 5 April 2024 and later revised to residential, does not qualify. No unit may be marketed as eligible before its change of use is completed, and no end buyer may apply before then. ### MVR 19 today **Concept design** Complete **Change-of-use permitting act** Not issued, in preparation **Works** Follow the permitting act; in a sale as it stands, they are the buyer's **Completion** No date set As of 28 September 2026. No timetable is published. In a sale of the building as it stands, the buyer obtains the permitting act and carries out the works; what preparatory work done so far passes with the building is agreed in writing. Applicants are not asked for proof of utility connections: the one-stop services examine only the documents in JMD 214926/2025. That is not a reason to treat the works as optional. The conservative course is to hold the permitting act and complete the works before any end buyer files. Whether end buyers may sign their deeds or pay before the change of use is completed, and how any money paid early could be protected within the payment rules, are questions for independent counsel. This page takes no position on them. ## What binds any reseller of the units These rules follow every unit to its end buyer, whoever sells it. Counsel's written sign-off on this block is pending. - Each unit's full price, at least €250,000, is written in its notarial deed and paid in full before the buyer applies, by bank transfer, crossed cheque or card, into the seller's account at an institution operating in Greece, by the buyer, the buyer's spouse or relatives by blood or marriage to the 2nd degree. The payment details are declared before the notary and recorded in the deed. - No rebates, cash-back, credits, side payments, commissions shared with the buyer, buy-backs, or payment of the buyer's taxes, fees or furnishings, before or after the sale. Extras such as furniture or management are sold separately at arm's length, paid on top and never netted against the price. - No rent guarantee by the seller, and none funded out of the price. - No unit may be marketed as eligible before its change of use is completed, and no end buyer may apply before then. - Long-term letting only; a unit may not be a company's seat or branch. - Every buyer is told the once-only rule and the announced 15% transfer tax (announced September 2026, from 1 July 2027, not yet law; treatment of converted property unknown). - New applications by Russian and Belarusian nationals are suspended. - Circular 1/2026 (Clarification 23) covers misleading advertising in Greece or in the buyers' countries of origin about the price, the payment method, the rights granted or the letting ban, and undocumented transfers of money before or after the investment. The Ministry refers such cases to the tax and law-enforcement authorities and the Hellenic Anti-Money Laundering Authority; where established, the permits granted are revoked. - The banks, notaries, lawyers and estate agents involved must identify every party and check where the money comes from (Law 4557/2018). From 10 July 2027, EU Regulation 2024/1624 also covers investment migration operators and requires enhanced due diligence on every customer applying for residence by investment; cash payments above €10,000 for goods or services are prohibited. - Any sale agreement will carry a compliance clause: approved claim sheets per language, no side payments, cooperation with the notary's and banks' checks, and termination rights for breach. ## Payment rules for every end buyer, and a seller abroad The payment rules of art. 100 §3, §5 and §6 bind every end buyer who applies. They therefore bind how a reseller prices each unit and collects the price. - One price per unit. The full price, at least €250,000, is written in the notarial deed. - Paid in full before the application. Nothing is left to be paid after the buyer files. - Three methods only. Bank transfer, crossed cheque or card, into the seller's account at a credit or payment institution operating in Greece. - Permitted payers only. The buyer, the buyer's spouse, or relatives by blood or marriage to the 2nd degree. Not the reseller, its agent or sub-agent, an employer or an unrelated company. - Declared before the notary. The payment details are declared by the parties and recorded in the deed, and the notary certifies them for the buyer's file. ### What this means for a seller marketing abroad The rule we apply, and ask any reseller to apply, is that the price of every unit is paid by the end buyer, in full, into the seller's own account at an institution operating in Greece. A seller based abroad therefore needs such an account in its own name before the first sale; if it sells through a Greek or EU company, that company is the seller in each deed and the account must be in that company's name. Collecting the price, a deposit or any part of it in the buyer's country, through an agency or client account, or from anyone other than a permitted payer, does not meet this rule and cannot be truthfully declared before the notary. A reservation or service fee collected abroad and not shown in the deed should be treated as a side payment, which the rules above exclude. ## Marketing in the buyers' countries: Clarification 23 Circular 1/2026 (Clarification 23) covers misleading advertising in Greece or in the buyers' countries of origin about the price, the payment method, the rights granted or the letting ban, and undocumented transfers of money before or after the investment. It reaches a reseller's own adverts, its sub-agents' posts and its sales decks, in every language. Where such practices are established, the permits granted are revoked. For a reseller's price, payment and claims, that means: ### Do - Quote one price per unit, the full price written in the deed. - Describe the payment path exactly, as above, before the buyer commits. - Pair every eligibility statement with its conditions, in every language, using approved claim sheets. - State the rights exactly, as set out under the end buyer's view. - Tell every buyer the once-only rule, the letting ban and the announced 15% transfer tax with its status. - Sell furniture or management separately, at arm's length, paid on top of the price. ### Do not - No rebates, cash-back, credits or commissions shared with the buyer. - No payment of the buyer's taxes, fees or furnishings. - No buy-back, vendor loan or rent guarantee, and no guarantee funded out of the price. - No unit described as eligible before its change of use is completed. - No split of the price into a "permit" part and a "property" part. - No short-term letting presented as an option, and no unit offered as a company's seat or branch. - No "ticket" language, and no promise of a permit, of citizenship or of any right to live or work elsewhere in the EU. - No marketing to Russian or Belarusian nationals as eligible. ## The once-only rule The €250,000 route can be used once per property. A later non-EU buyer of the same unit needs €400,000 and 120 m² of main area in Patras; a buyer who does not need a permit pays local market value. The concept studios measure 16.29 to 27.64 m². Resale value outside the €250,000 route is not known; a registered valuer must establish it. TPL makes no representation on how this rule applies to a whole-building transaction; take independent legal advice. Each end buyer's file also shows whether the seller used the property for its own permit: see the end buyer's file. ## Letting rules Units bought under the route may be let long-term only: no short-term letting (under 60 days) in the sharing economy and no sub-letting. Breach means revocation of the permit and a €50,000 fine on the owners and/or holders. The unit may not be used as the seat or branch of any business. Long-term leases, such as an academic-year student lease, are allowed. Rent figures in Patras are dated market observations, not forecasts; they are on [market and demand](https://b2b.mav19-goldenvisa.com/market). The end-buyer guide to the [short-term rental ban](https://mav19-goldenvisa.com/guides/golden-visa-short-term-rental-ban) covers the detail. ## End buyers through a company An end buyer may hold the unit through a company seated in Greece or another EU member state that it owns 100%. The unit may not be used as the seat or branch of any business. The standard conditions apply in full: completion before the application, full payment by a permitted method and payer, and the Ministry's decision. ## Nationality The route is for non-EU nationals. New applications by Russian and Belarusian nationals, including family members, are suspended (Circular 1/2026, Clarification 22). Claim sheets prepared for each market must reflect it. ## Tax and timing risks The announced 15% transfer tax. Announced September 2026, from 1 July 2027, not yet law; treatment of converted property unknown. It is a 15% transfer tax for non-EU/EEA natural persons buying residential property; as announced, companies, ethnic Greeks and long-term residents are excluded. On €250,000 it would be about €37,500–38,600. Do not base a decision on a tax that is not yet law. VAT. VAT on the sale of new buildings is suspended until 31 December 2026; an extension to 2027 is expected but not yet law. Whether VAT applies to the units after a change of use of this building is unresolved; a written AADE ruling is needed, and a ruling given to one seller does not cover another. Transfer tax today. Transfer tax on Greek property today is 3% plus a 3% municipal surcharge on the tax, i.e. 3.09% of the higher of price and objective value (€7,725 on €250,000). Whether a given sale bears transfer tax or VAT depends on the facts. The building itself. The tax treatment of the transfer of the building (transfer tax or VAT) is to be confirmed on the actual facts; take your own tax advice. See [acquisition and due diligence](https://b2b.mav19-goldenvisa.com/acquisition). Timing. No timetable is published for the permitting act, the works or completion, and no end buyer can apply before completion. The rules can change before an end buyer files: the thresholds were last raised in April 2024. ## What each end buyer's file needs from the seller The end buyer's file is fixed by JMD 214926/2025, art. 2 §2.6. For each unit the seller produces, or enables the notary and engineer to produce: - the permitting act (building permit, small-scale works approval, file update or permit revision), issued on or after 5 April 2024; - the notarial deed with the full price and every payment detail; - the notary's certificate, which also states whether the seller used the property for its own permit; - proof of registration with the Hellenic Cadastre; - a separate engineer's technical report per unit, based on the permitting act and naming the buyer and the deed; - if any part was industrial, proof of no industrial operation in the last five years; - each unit as a separate horizontal property with its own cadastral code (KAEK), so that it can be conveyed and registered. A seller who is a non-EU national, or a company wholly owned by one, must produce at every sale, at any price, a certificate from the Aliens and Migration service of the Decentralised Administration stating whether the property has been used for an investor permit. ### The engineer's report The decision sets the report's wording. In close translation: "The change of use is established, as shown by the review of the building permit or the small-scale works approval and/or the file update and/or the revision of the building permit (the act is specified), after the entry into force of art. 64 L.5100/2024, from use '…' to use 'residence' of the main areas of the property, on the basis of which an investment was made through acquisition of real property under case (c) of para. 2 of art. 100 L.5038/2023, which passed in full ownership and possession to [investor's name], under deed no. … of Notary …" Unofficial translation of JMD 214926/2025, art. 2 §2.6(e); the Greek text governs. Because the report names the buyer and the deed, it cannot exist before the conversion and each deed. For MVR 19 the change-of-use permitting act is not issued and the horizontal-property deed for the 19 units is not yet constituted. The status of every document is on [acquisition and due diligence](https://b2b.mav19-goldenvisa.com/acquisition). ## The end buyer's view What each end buyer receives: a Greek residence permit for 5 years, renewable while the property is held; no minimum stay; short stays of up to 90 days in any 180 in other Schengen states, not residence there; no right to work. What it costs the end buyer: €2,000 plus €16 for the card for the main applicant, and €2,000 at each renewal. mitos.gov.gr lists 50 days and the law two months; allow several months. End-buyer closing costs today: notary about 0.65–1% plus VAT; registry about 0.5%; lawyer about 0.5–1% plus VAT; about 5–7% in total including the 3.09% tax. The unit-sales site explains the route to end buyers in full: [the €250,000 change-of-use route](https://mav19-goldenvisa.com/golden-visa-250k) and [costs and taxes](https://mav19-goldenvisa.com/guides/golden-visa-costs-taxes). Selling individual studios to your clients rather than acquiring the building? Use the [agent enquiry on the unit-sales site](https://mav19-goldenvisa.com/enquire). ## Points for your own counsel Independent counsel's written opinion on the route and on the whole-building structure has not yet been obtained. This page takes no position on the following, and a buyer's own Greek counsel should answer them: - how the once-only rule applies to a purchase of the whole building by a buyer who does not apply for a permit, and whether the answer changes if the building is sold after the conversion; - whether the permitting and the works may be split between seller and buyer; - what "completed" requires beyond the permitting act and the engineer's report, and whether end buyers may sign and pay before completion; - how any money paid before completion can be protected while it is still paid by the buyer into the seller's account; - for a retained unit, which deed the engineer's report cites and how the valuer's €250,000 test is applied; - whether an operator's master lease with sub-lets is compatible with the letting ban; - whether the reseller and its sub-agents are investment migration operators under Regulation (EU) 2024/1624 from 10 July 2027; - what consumer law requires a reseller to disclose to its end buyers; - the VAT position of the unit sales, and whether the €250,000 is tested with or without VAT. ## Sources - [Law 5038/2023, art. 100, as replaced by art. 64 of Law 5100/2024 (Gazette A' 49/05.04.2024), codified text](https://migration.gov.gr/wp-content/uploads/2025/03/%CE%9D%CF%8C%CE%BC%CE%BF%CF%82-5100_2024-%CE%BA%CF%89%CE%B4%CE%B9%CE%BA%CE%BF%CF%80%CE%BF%CE%B9%CE%B7%CE%BC%CE%AD%CE%BD%CE%BF%CF%82-%CE%BC%CE%B5-%CF%84%CE%BF%CE%BD-5167_2024-%CE%A6%CE%95%CE%9A-%CE%91-49_5.4.2024.pdf), Ministry of Migration and Asylum: §1, §2(c), §3, §5, §6, §7A, §11. - [Joint Ministerial Decision 214926/2025 (Gazette B' 6014/11.11.2025)](https://www.taxheaven.gr/circulars/51471/214926-10-11-2025), art. 2 §2.6. - Circular 1/2026, Ministry of Migration and Asylum, Prot. 72019, 21 April 2026, §I.2 and Clarifications 2, 5, 7, 9, 20, 22, 23: [Ministry circulars listing](https://migration.gov.gr/en/egkyklioi-yma/); [full text (PDF)](https://www.newmoney.gr/wp-content/uploads/2026/04/%CE%95%CE%B3%CE%BA%CF%8D%CE%BA%CE%BB%CE%B9%CE%BF%CF%82-GOLDEN-VISA-FINAL.pdf). - [mitos.gov.gr: Permanent golden visa (change of use), initial issuance](https://en.mitos.gov.gr/index.php/%CE%94%CE%94:Permanent_golden_visa_(change_of_use)_%E2%80%93_Initial_issuance). - Law 4557/2018 on the prevention of money laundering, art. 5 and 13. - [Regulation (EU) 2024/1624 (anti-money laundering)](https://eur-lex.europa.eu/eli/reg/2024/1624), art. 3, 41, 80, 90. - Law 4152/2013, art. one §Γ, sub-para. Γ.4: register of certified valuers. - [Regulation (EU) 2016/399, Schengen Borders Code](https://eur-lex.europa.eu/eli/reg/2016/399/oj). - [Law 5246/2025, art. 12](https://www.taxheaven.gr/law/5246/2025/arthro/12): VAT suspension on new buildings to 31 December 2026; expected extension reported by [capital.gr, 8 July 2026](https://www.capital.gr/tax/4003408/akinita-pros-paratasi-kai-to-2027-i-anastoli-tou-fpa-sta-neodmita-kai-to-pagoma-tou-forou-uperaxias/) and [ot.gr, 16 August 2026](https://www.ot.gr/2026/08/16/oikonomia/akinita/akinita-pros-paratasi-kai-to-2027-i-anastoli-tou-fpa-sta-neodmita/). - The announced 15% transfer tax: [newmoney.gr](https://www.newmoney.gr/roh/palmos-oikonomias/oikonomia/akinita-se-pious-epivallete-o-foros-metavivasis-15-ti-allaxe-meta-tis-antidrasis/) and [protothema.gr](https://www.protothema.gr/economy/article/1875396/foros-metavivasis-15-gia-agorastes-apo-trites-hores-poioi-exairoudai-i-ekkremotita-me-tin-golden-visa/), 8 September 2026. Sources last checked 28 September 2026 · General information, not legal advice · Take independent Greek legal and tax advice ## The rest of the particulars ### The asset and the 19-studio concept The building today, the concept schedule, plans, and what is still unknown. ### Process and due diligence How a sale would run, and the document index with its current status. ### Patras market and demand Dated, sourced inputs for your own appraisal, with the counter-evidence beside them. ### Who is selling TPL S.A., its registry identifiers, and the official channels for payments. ### Questions developers ask Short, conditional answers on price, the route, payment, letting and tax. ### The route as end buyers see it The unit-sales site's guide to the €250,000 change-of-use route. ## Request the information pack Tell us who you are and where you would sell the units. We send the confidentiality agreement; the information pack, with the documents issued so far, follows our checks of your identity, beneficial owners and source of funds. We reply within one business day, in English or Greek. Offers are invited for the building as it stands. Subject to contract, due diligence and a notarial deed. The Ministry decides each application; TPL makes no representation that any unit will qualify.