Which country taxes a foreign pension least: France, Italy or Greece?

For a retiree who qualifies, Italy and Greece both offer a 7% flat tax on all foreign-source income — Italy for 10 years if you settle in a southern town of up to 30,000 people, Greece for 15 years anywhere in the country. France has no special regime, but under the US–France treaty a US pension and US Social Security are taxed only in the United States, so an American retiree in France pays no French income tax on them at all. For a UK or Canadian pension, France's standard scale on a couple's €52,000 comes to about 5% before social charges, against 7% under the Italian and Greek regimes.

Does Greece's 7% tax regime for foreign pensioners still exist in 2026?

Yes. Article 5B of the Greek Income Tax Code taxes all foreign-source income of qualifying foreign pensioners at a flat 7% for 15 years. You must not have been Greek tax resident in 5 of the previous 6 years, must move from a country with an administrative cooperation agreement, and must apply by 31 March of the tax year. The tax is paid in one instalment by the end of July.

What is Italy's 7% tax for foreign pensioners in 2026?

Article 24-ter of the Italian tax code lets a holder of a foreign pension who moves to a municipality of up to 30,000 inhabitants in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia (or up to 3,000 in listed earthquake-hit central municipalities) pay a 7% substitute tax on all foreign-source income for 10 years. The 30,000 threshold applies from 7 April 2026 under Law 34/2026; it was 20,000 before. You must not have been Italian tax resident in the previous 5 years. IVIE and IVAFE and foreign-asset reporting are waived.

Do French social charges apply to a foreign pension?

Only if you are covered by a compulsory French health scheme. In that case CSG at up to 8.3%, CRDS 0.5% and CASA 0.3% apply to pension income once your reference income exceeds thresholds — 8.3% CSG from €26,472 for one part or €40,604 for two parts in 2026. UK State Pensioners with an S1 form are covered by the UK scheme and pay no CSG, CRDS or CASA on their pensions; US and Canadian pensions exempt under treaty are not charged either.

Tax comparison · France · Italy · Greece

France vs Italy vs Greece: how each taxes a foreign pension in 2026.

Q: Are US pensions taxed in France?

No. Under Article 18 of the US–France treaty, pensions from past employment — periodic or lump sum — and US Social Security paid to a French resident are taxable only in the United States. France takes them into account for the rate on other income but gives a credit equal to the French tax, so nothing is payable. US government pensions are also US-only.

By Nick · Europe Unlocked · Every figure sourced to an official body and dated.

Last verified: 16 September 2026

Three Mediterranean countries, three completely different answers to the same question. Italy and Greece will take 7% of a foreign pension for a decade or more if you qualify. France takes nothing at all from an American's pension — and a fair amount from a Briton's or a Canadian's, plus social charges if you join the health system. This is the 2026 comparison: the standard scales, the special regimes, the treaty rules for each passport, the lump-sum rules, and one worked example run three ways.

The key numbers · 2026

Italy: 7% flat on all foreign income for 10 years — southern towns up to 30,000 people since 7 April 2026 (Law 34/2026)
Greece: 7% flat on all foreign income for 15 years, anywhere in Greece — apply by 31 March
France: no pensioner regime; standard scale 0/11/30/41/45% per part, 10% pension deduction capped at €4,439; optional 7.5% on lump sums
US pensions in France: 0% French tax under the treaty; in Italy and Greece, taxed there (the IRS collects the difference from US citizens)
French social charges on pensions: CSG up to 8.3% + CRDS 0.5% + CASA 0.3% — only if you are in the French health scheme; S1 holders exempt
Italy standard IRPEF 2026: 23% to €28,000 · 33% to €50,000 · 43% above, plus regional and municipal add-ons
Greece standard scale 2026: 9/20/26/34/39/44% — cut 2 points across most bands from 1 January 2026
Worked example, couple on €52,000 (US$60,000): France ≈ 5% (≈14% with social charges) · Italy 7% or ≈ 24–27% · Greece 7% or ≈ 15.2%

The comparison at a glance

	France	Italy	Greece
Tax resident when	Main home, principal stay (183+ days), main activity or centre of economic interests in France (Art. 4B CGI)	Physical presence, residence or domicile (centre of personal and family life) for more than 183 days; registration is only a presumption since 2024	Permanent home, habitual abode or centre of vital interests in Greece, or presence over 183 days in any 12 months (Art. 4 L.4172/2013)
Standard scale 2026	0% to €11,600 · 11% to €29,579 · 30% to €84,577 · 41% to €181,917 · 45% above — per part; a couple is 2 parts	23% to €28,000 · 33% to €50,000 · 43% above; plus regional add-on ~1.23–3.33% and municipal 0–0.9%; individual, no splitting	9% to €10,000 · 20% to €20,000 · 26% to €30,000 · 34% to €40,000 · 39% to €60,000 · 44% above; individual; €777 basic credit, tapering above €12,000
Pension-specific relief	10% deduction, floor €454 per pensioner, ceiling €4,439 per household (2025 income)	Pension tax credit (detrazione) on income up to €50,000	None beyond the basic credit
Special regime for incoming pensioners	None	7% substitute tax, 10 years, all foreign-source income; southern municipality ≤30,000 (≤3,000 in listed central earthquake zones); non-resident 5 prior years; cooperation-agreement country; waives IVIE/IVAFE and foreign-asset reporting	7% flat, 15 years, all foreign-source income; non-resident 5 of previous 6 years; cooperation-agreement country; apply by 31 March; paid in one instalment by end-July; cannot be offset against other Greek liabilities
Social charges on pensions	CSG 0/3.8/6.6/8.3% by income band + CRDS 0.5% + CASA 0.3% — only if covered by a compulsory French health scheme; S1 holders and treaty-exempt pensions: none	None on pensions; regional and municipal add-ons only	None; the solidarity contribution was abolished from 1 January 2023
Lump sums	Optional irrevocable 7.5% flat after the 10% deduction, if not paid in instalments and contributions were deductible (Art. 163 bis CGI)	Inside the 7% regime. Outside it, practitioners apply separate taxation (Art. 17 TUIR) — no ruling on a US/UK lump sum found; get one	Inside the 7% regime. Standard treatment of a foreign lump sum: not settled in official guidance
Wealth & reporting	IFI on net real estate above €1.3M; foreign accounts declared on form 3916	IVIE 1.06% on foreign property, IVAFE 0.2% on foreign financial assets, quadro RW — all waived under the 7%	No wealth tax; ENFIA annual property tax
Healthcare cost linked to income	PUMa contribution (6.5% on capital income above €24,030) — pension recipients are exempt	Voluntary SSN enrolment: 7.5% of income to €20,658, then 4% to €51,646; minimum €2,000 a year	FIP permit requires full private insurance; €3,500/month income

Who taxes your pension: the treaty layer

Before any of the scales above apply, the treaty between your home country and your new one decides which of them may tax the pension at all. This is where the three countries diverge most sharply, and where your passport matters more than your postcode.

Pension from	France	Italy	Greece
US private pension / IRA / 401(k)	US only — periodic or lump sum (Art. 18, 1994 treaty as amended 2009). France exempts with a credit equal to French tax.	Italy (Art. 18, 1999 treaty); US citizens still file with the IRS under the saving clause and credit the Italian tax	Greece (Art. XI(2), 1950 treaty); "pension" means periodic payments, so a lump sum is arguably outside the article; US citizens file and credit
US Social Security	US only (Art. 18)	Italy only (Art. 18(1), as extended to social security by Protocol para. 14); US citizens remain taxable by the IRS under the saving clause, with credit	No Social Security article in the 1950 treaty — taxable in both; Greece credits US tax up to the Greek tax
US government pension	US only (Art. 19)	US only (Art. 19)	US only (Art. XI(1))
Canadian pension / CPP / OAS	Canada only for past-employment pensions, CPP/QPP and OAS (Art. 18); Part XIII withholding 25%, 15% on periodic RRIF, with the s.217 election	Both; Canada exempts the first CAD 12,000 of periodic pensions and caps its tax at 15% above; OAS Canada-only with up to 25% withholding; RRSP lump sums up to 25% (2002 treaty, effective 2011)	Both; Canada exempts the first CAD 15,000 of total pensions and caps periodic pensions at 15% above; no government-pension carve-out, so public-service pensions follow the same rule; Greece credits Canadian tax (2009 treaty)
UK State & private pension	France only (Art. 18, 2008 treaty)	Italy only (Art. 18, 1988 treaty)	Greece — UK exempts if the pension is "subject to Greek tax" (Art. X, 1953 treaty); the 7% regime is Greek tax, so the exemption should hold
UK government-service pension	UK only, unless resident and French national and not a UK national (Art. 19)	UK only, unless resident and Italian national (Art. 19)	UK only, unless Greek national and not a UK national (Art. VIII); local-authority, teachers' and police pensions count as non-government under this old treaty

The American asymmetry. For a US retiree, France is the only one of the three where the pension escapes local income tax entirely — and that is a treaty rule, not a regime, so it has no time limit and no application. In Italy and Greece the 7% regimes look cheaper than the US scale, but the saving clause means the IRS taxes the same income and simply credits the 7%; the American's total bill is the higher of the two. The 7% regimes are a real saving for Canadians and Britons; for Americans they mostly move tax from one treasury to another.

France: no regime, but a treaty and a lump-sum rate

France does not court foreign pensioners with a special rate. What it offers is the quotient familial — a couple's income is halved before the scale is applied, and each half taxed separately, so a two-person household on €52,000 barely leaves the 11% band — and a 10% deduction on pension income, floored at €454 per pensioner and capped at €4,439 per household on 2025 income. The 2026 scale (on 2025 income) runs 0% to €11,600, 11% to €29,579, 30% to €84,577, 41% to €181,917 and 45% above, per part, indexed 0.9% by the 2026 Finance Law. A décote reduces small tax bills further; we have left it out of the example below, so the French figures are slightly conservative.

Social charges are the number that surprises people. If you are covered by a compulsory French health scheme — which, once resident, most people are through PUMa — your pension carries CSG at 0%, 3.8%, 6.6% or 8.3% depending on your reference income (the full 8.3% starts at €26,472 for one part or €40,604 for two in 2026), plus CRDS 0.5% and CASA 0.3%. Two groups escape it: UK State Pensioners holding an S1, who are affiliated to the UK scheme and pay none of it, and anyone whose pension is exempt under a treaty, which is every American. The PUMa contribution itself does not apply to anyone receiving a retirement pension.

The lump-sum option is France's quiet advantage for Britons: a pension paid as capital, not in instalments, from a scheme whose contributions were tax-deductible, can be taxed at an irrevocable flat 7.5% after the 10% deduction (Art. 163 bis II CGI), elected on the return in boxes 1AT/1BT. On a £200,000 UK pension lump sum that is a 6.75% effective French rate, against Spain's progressive scale. Social charges apply on top where you are affiliated. The full French picture is in the France tax guide.

Italy: 7% in the south, or a steep standard scale

Italy's Article 24-ter regime is the most location-specific offer in Europe: a 7% substitute tax on every category of foreign-source income — pension, dividends, rent, gains — for a holder of a foreign pension who transfers residence to a municipality of no more than 30,000 inhabitants in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia, or no more than 3,000 in the listed earthquake-hit municipalities of central Italy. The 30,000 ceiling came in on 7 April 2026 under Law 34/2026 (Art. 26); before that it was 20,000, which excluded most of the towns people actually wanted. You must not have been Italian tax resident in the five tax periods before the option and must move from a country with an administrative cooperation agreement — the US, Canada and UK all qualify. The option runs for the year it is exercised plus nine more, is elected in the return and paid in one instalment, replaces IRPEF and the regional and municipal add-ons, and waives IVIE, IVAFE and the foreign-asset reporting (quadro RW) that otherwise apply to every foreign account and property you own. The 7% flat-tax guide has the mechanics and the eligible regions.

Outside the regime, Italy is the most expensive of the three. The 2026 IRPEF scale is 23% to €28,000, 33% to €50,000 and 43% above (the 2026 Budget Law cut the middle band from 35%), plus a regional add-on of roughly 1.23% to 3.33% and a municipal add-on of up to 0.9% in Rome. There is no joint assessment and no 10% deduction; a pension tax credit applies on income up to €50,000. A couple on €52,000 split equally pays about €12,000 before that credit, around 24–27% with the add-ons; a single pensioner on the same income pays around 29–32%. Foreign property and financial assets carry IVIE at 1.06% and IVAFE at 0.2% a year. Voluntary enrolment in the health service for elective-residence permit holders costs 7.5% of worldwide income up to €20,658, then 4% up to €51,646, with a €2,000 minimum.

Greece: 7% anywhere, for 15 years

Greece's Article 5B regime has no geographic condition and the longest run: 7% on aggregate foreign-source income for 15 tax years. Conditions: you receive a foreign pension, you were not Greek tax resident in five of the previous six years, you move from a country with an administrative cooperation agreement, and you apply to the Tax Office for Residents Abroad and Alternative Taxation by 31 March of the tax year. The tax is paid in a single instalment by the last working day of July and cannot be offset against other Greek liabilities or credit balances; miss a year's payment in full and the regime lapses. You can withdraw in any year. Whether foreign tax already paid can be credited against the 7% is answered yes in the law's explanatory memorandum, as summarised by KPMG, but we have not seen the primary text — treat it as an adviser question. Full detail in the Greece 7% guide.

The standard scale was cut from 1 January 2026 (Law 5246/2025): 9% to €10,000, 20% to €20,000, 26% to €30,000, 34% to €40,000, 39% to €60,000 and 44% above, with a basic tax credit of €777 that reduces by €20 for every €1,000 of income above €12,000. The cuts apply to pensioners; the extra reductions for under-30s and families with children do not touch a childless retiree. There are no social charges on a pension and no wealth tax; ENFIA, the annual property tax, applies to anything you own. The Financially Independent Person permit needs €3,500 a month of income and full private health insurance.

Worked example: a couple, €52,000 of private pension

Two retirees, non-government pensions of US$60,000 a year — €52,000 at the ECB reference rate of $1.1539 on 15 September 2026 — split equally. Pre-credit figures; the French décote and the Italian pension credit would each shave a little more off.

Scenario	France	Italy	Greece
Standard scale	€52,000 − €4,439 deduction = €47,561 ÷ 2 parts → 11% on the slice above €11,600 → €2,680 (5.2%); about €2,410 (4.6%) after the automatic décote	€26,000 each at 23% = €11,960, plus add-ons ≈ €640–2,200 → ≈ €12,600–14,200 (24–27%)	€26,000 each: €4,460 tax less €497 credit = €3,963 each → €7,926 (15.2%)
Special regime	None	7% → €3,640 (7.0%), no add-ons, no IVIE/IVAFE	7% → €3,640 (7.0%)
Social charges	If in the French health scheme: 9.1% on €52,000 = €4,732 → total ≈ €7,410 (14.3%). S1 holders: none	None	None
If the pensions are American	€0 French tax — US-only under the treaty; US tax as normal	7% to Italy; the IRS collects the difference between 7% and the US liability	7% to Greece; same IRS top-up
If the pensions are British, with S1	€2,680 (5.2%), no social charges	€3,640 (7%) in the south; ≈ €12,600+ elsewhere	€3,640 (7%)

Read across, not down. For a British couple with an S1, standard France at 5.2% beats both 7% regimes on this income — but the gap closes and reverses as income rises, because the French scale climbs to 30% at €29,579 per part while the 7% never moves. At €100,000 of pension income the Italian and Greek regimes win comfortably; at €52,000 they don't. For an American couple, France wins at every income level because the treaty removes French tax altogether. For a Canadian couple, the 15% source-country cap in Italy and Greece and the Canada-only rule in France mean Ottawa is often the larger creditor whichever country you pick.

What the numbers don't show

Regimes expire; treaties don't. Italy's 7% ends after 10 years and Greece's after 15, at which point the standard scale applies — 24–27% and 15%+ on this example. France's treaty exemption for US pensions has no end date.
Location is the price of Italy's regime. A 7% rate is available in Puglia's towns of under 30,000 people, not in Rome, Florence or Bologna. Greece's has no such condition.
Lump sums are a French strength and an Italian and Greek question mark. France's 7.5% rate is in the code. Italy and Greece bring a lump sum inside their 7% regimes, but outside them neither has settled official guidance on a US or UK pension lump sum. Timing the withdrawal before you move is usually the safer answer — see how the UK taxes you after you leave.
Reporting is a cost too. Italy's quadro RW and IVIE/IVAFE on every foreign account and property are waived only under the 7%; France wants form 3916 for every foreign account; Greece asks least.

Questions retirees ask

Which country taxes a foreign pension least?

For a qualifying retiree, Italy and Greece at 7%. For an American, France at 0% under the treaty. For a British or Canadian couple on around €52,000, standard France at about 5% is cheaper than either 7% regime; above that, the regimes win.

Does Greece's 7% regime still exist in 2026?

Yes — Article 5B, 7% on all foreign income for 15 years, apply by 31 March, non-resident five of the previous six years.

What is Italy's 7% tax for foreign pensioners?

Article 24-ter: 7% on all foreign income for 10 years if you settle in a southern municipality of up to 30,000 people (since 7 April 2026), having been non-resident for the previous five years.

Are US pensions taxed in France?

No. Article 18 of the treaty makes US pensions and Social Security taxable only in the United States; France gives a full credit.

Do French social charges hit a foreign pension?

Only if you are in the French health scheme: CSG up to 8.3% plus 0.8% CRDS and CASA. S1 holders and treaty-exempt pensions pay none.

Sources

France — 2026 income-tax scale (2025 income): economie.gouv.fr · Pension deduction 10%, €454 floor, €4,439 ceiling: impots.gouv.fr · Lump sums, Art. 163 bis CGI: legifrance.gouv.fr and BOI-RSA-PENS-30-10-20: bofip.impots.gouv.fr (all checked 16 Sep 2026)
France — 2026 CSG/CRDS/CASA rates and thresholds on pensions: lassuranceretraite.fr (9 Jan 2026) · PUMa contribution conditions and pensioner exemption: urssaf.fr
Italy — IRPEF 2026 rates (23/33/43%, Budget Law 2026, L. 199/2025): MEF summary mef.gov.it and RGS Circular 4 of 21 April 2026, Table A: rgs.mef.gov.it · Tax residence from 2024, Circolare 20/E: agenziaentrate.gov.it
Italy — Art. 24-ter regime for foreign pensioners: agenziaentrate.gov.it · 30,000-inhabitant threshold, Law 34 of 11 March 2026, Art. 26(1), GU 23 Mar 2026, in force 7 Apr 2026: gazzettaufficiale.it · IVIE/IVAFE: PwC Worldwide Tax Summaries, Italy (23 Jul 2026) · Voluntary SSN enrolment: 7.5%/4% bands per Ministry of Health calculation note salute.gov.it; €2,000 minimum from Budget Law 2024 (L. 213/2023, art. 1 c. 240) · Separate taxation of a capitalised pension payout, Risposta 245/2025: agenziaentrate.gov.it
Greece — Tax residence, Art. 4: aade.gr · 2026 scale (Law 5246/2025): minfin.gov.gr, corroborated by KPMG Greece (20 Nov 2025) · Basic credit €777 and taper: OECD Taxing Wages 2026, Greece · Art. 5B regime, AADE guidance: aade.gr · Solidarity contribution abolished from 2023 (L. 4972/2022): KPMG Flash Alert 2022-173 (Big-4 corroboration; gazette text not fetched) · Foreign tax credit under 5B: KPMG Tax Breaking News, Aug 2020 (explanatory memorandum; primary not fetched)
US treaties — France (1994, 2009 protocol), Art. 18–19: irs.gov · Italy (1999), Art. 18–19: irs.gov · Greece (1950), Art. XI and XIV: irs.gov
Canada treaties — Italy (2002, effective 2011), CRA notice on pensions: canada.ca · Greece (2009), Art. 18–19, 23: canada.ca · France (1975 as amended), Art. 18: per our France tax guide (verified 8 Jul 2026)
UK treaties — Greece (1953), Art. VIII and X: gov.uk and HMRC DT8250 · France (2008) Art. 18–19 and Italy (1988) Art. 18–19: HMRC DT7264 and DT10154 · Government-service classification, INTM343040: gov.uk
Exchange rate — ECB euro reference rate, USD, 15 Sep 2026 ($1.1539): ecb.europa.eu

This comparison is general information, not tax advice. The worked example ignores credits, deductions and personal facts that can change the answer; several Italian and Greek points on lump sums and foreign tax credits rest on practitioner or Big-4 summaries rather than the tax authority's own text, as flagged above. Cross-border pension tax is specialist territory — confirm with a licensed adviser in your destination country before you elect anything.