Comparison of Citizenship by Investment Schemes Christos Vezouvios Table of contents • What are citizenship schemes? • Incentives to apply for a citizenship scheme • Common provisions • Countries to be examined – – – – – – – Cyprus Portugal Malta United Kingdom Bulgaria Thailand Belize • Why choose Cyprus? What are citizenship schemes? Citizenship • Refers to the status of an individual (the citizen) that is recognized under the law of the state concerned. • It allows the citizen to exercise the rights and privileges of citizenship (eg to vote or to enjoy social benefits); and obliges the citizen to adhere to and carry out particular duties (eg military service). Naturalization • Refers to the legal process by which a non-citizen acquires the citizenship of another country Citizenship schemes • There are a variety of reasons why particular individuals would want to obtain a citizenship of another country; • Similarly, many countries would like to attract particular individuals (especially high net worth individuals) • This has led to countries, such as Cyprus, Malta, Thailand, Bulgaria and Portugal to come up with citizenship by investment schemes Incentives to apply for a citizenship scheme • Personal factors – Family reunification – Medical and educational reasons – Higher quality of life – Lower crime levels • Financial factors – Tax planning benefits – Opportunities for business expansion – New markets or exploration of new business ventures • Opportunities for movement – Unrestricted movement or reduced visa formalities in various countries Alternatives to citizenship schemes Resident visa • Allows individuals the privilege of residing within a country of which the person is not a citizen Permanent resident visa • Allows the privilege of residing indefinitely within a country of which the person is not a citizen Both offer only limited rights compared to citizenship schemes Common provisions for the application of citizenship schemes The provisions for citizenship schemes are different in each country, however they usually entail: Conditions such as: • Residency in the country for a certain number of years • Language proficiency of the host country • Clean criminal record • Economic criteria such as: – Investment in government activities of the country; – Investment in financial assets of companies or organizations of the country; or – Investment in real estate. Cyprus The Scheme for Naturalization of Investors in Cyprus by Exception • 2011: Cyprus introduces a fast-track option allowing qualifying individuals to obtain Cypriot citizenship by naturalization • 19 March 2014: Council of Ministers introduces the revised Scheme for Naturalization of Investors in Cyprus by Exception Cyprus Criteria : • Investments of at least €5 million in the following: • Acquisition of state bonds; or • Acquisition of financial assets; or • Acquisition of real estate, land development and infrastructure projects; or • Acquisition or creation or participation in Cypriot businesses or companies; or • Deposits in Cyprus banks; or • Combination of the aforementioned amounting to at least €5 million • Losses incurred due to the impairment of deposits following the measures implemented in Laiki Bank and Bank of Cyprus after March 15, 2013 • The applicant must have suffered impairment on his deposit amounting to a total of at least 3 million Euros. • In the scenario where the applicant has suffered an impairment less than € 3 million Euros he can still file an application if he invests further through other types of investments to reach the amount of € 3 million. • • • • Maintain investment for 3 years At least 30 years of age Clean criminal record Residency in Cyprus Cyprus • • • • • • • • • Advantages Disadvantages Enables non-EEA citizens to obtain a • High passport and citizenship of an EU demands/requirements member state Physical presence in Cyprus is not required for approval of the application Spouse of applicant and children under the age of 18 (and subject to additional terms children between the age of 1828) may also obtain the citizenship Visa free travel to over 180 countries ‘Fast track’ process Passport within 3-4 months Efficient taxation system Good infrastructure Language competence not required Cyprus Alternative Immigration Permit Criteria • Deposit a minimum of €30,000 in a Cyprus bank; • Acquire a property costing a minimum of €300,000 (plus VAT) in Cyprus; • Annual income of at least €30,000 (additional €5,000 for every dependent person). Portugal Golden Resident Permit Program • Permit is originally issued for one year and then renewed for successive periods of two years, as long as requirements of the investment activities and minimum duration of stay are maintained • Differs from citizenship programs • Major disadvantage as you still have to invest but do not gain any advantages of actual citizenship – particularly EU passport Portugal Criteria: • Acquisition of real estate with value of minimum €500,000; or • Transfer of capital worth minimum €1,000,000 to any type of Portuguese company; or • Creation of at least 10 permanent jobs • Residency in Portugal (consecutively or non consecutively) – 7 days during the first year – 14 days in the following two years Portugal Advantages Disadvantages • Short residency period • No citizenship, • Criteria not too therefore no EU demanding passport • Freedom of movement • Corruption in Schengen Area for • Crime 90 days every half year Malta Malta Individual Investor Program (MIIP) Criteria: • Contribution of €650,000 to the National Development Fund; or • Purchase and ownership of property valued €350,000+; or • Rent a property with a minimum annual rent of €16,000 per year for at least 5 years; • No criminal record; • Residency in the country for a minimum of year; • Global health insurance policy Malta Advantages Disadvantages • EU citizenship • Low standards of scrutiny • Commonwealth citizenship • Heavily criticized from EU • No minimum stay in the for setting low country necessary requirements • Fast track process 3-4 months • Passport after 12 months • Visa free travel to over 180 countries • Lenient United Kingdom Criteria: UK Tier 1 Entrepreneur Visa • Minimum of £50,000 invested in a regulated financial institution in the UK; • English language competency required; • Minimum age of 16 years old UK Tier 1 Investor Visa • Investments: • Minimum of £1,000,000 invested in a regulated financial institution in the UK; or • Contribution of £750,000 to the UK government; or • Purchasing property valued (~€350,000); or • Renting a property with a minimum annual rent of €16,000 for a minimum of 5 years; United Kingdom Advantages Disadvantages UK Tier 1 Entrepreneur Visa UK Tier 1 Entrepreneur Visa • Set up or take over the running of 1 • Cannot work outside your business, e.g. business or more work where you’re employed by another • Work for your business, including being business self-employed • Not granted public funds • Not granted citizenship UK Tier 1 Investor Visa • Work and/or study in the UK UK Tier 1 Investor Visa • International business centre • Cannot Invest in companies mainly • You can apply to settle engaged in property investment, property • after 2 years if £10 million is invested management or property development • after 3 years if £5 million is invested • Cannot work as a professional sportsperson or sports coach; and doctor or dentist in training • Not granted public funds • Not granted citizenship Bulgaria Investor Program for Residence and Citizenship in Bulgaria • Founded in 2009 to attract foreign investment and business interest in the country Bulgaria Criteria: • Investing at least €500,000 in the capital of a Bulgarian company which is carrying out a Priority Investment Project; • 1 year Permanent Resident status; • Upon receiving the citizenship, the applicant holds the investments for a period of two years. Bulgaria • • • • • • • Advantages Disadvantages EU citizenship • Leniency might affect Dual citizenship quality of accepted Favorable taxes applications Language competence not • Less developed country required Government support for priority investment projects Competitively priced healthcare and education Relinquishment of current nationality not required Thailand Thailand Investment Visa • 1997- Concept started as a means to help Thai developers sell their stock of condominiums units left over from the crisis to foreign investors • 2006- Visa discontinued once Thai economy picked up • 2014- Concept reintroduced increasing the minimum investment ceiling from 3 million Thai baht (~€71,864) to 10 million baht (~€240,000) Thailand Criteria: • Applicant must invest a minimum of: • 10 million Thai Baht (~€240,000) into a long term savings account with a Thai government bank; or • 10 million Baht (~€240,000) into government bonds or from stated business enterprise. • Clean criminal record Thailand Advantages • Visa free entry to over 80 countries • Tax status • Exempted from 3 year residence requirements Disadvantages • Ineligibility for those with major health problems or diseases Belize • Investor Citizenship Program terminated in 2002 Belize Advantages • • • • Low price Visa free entry to over 80 countries Tax benefits Funds go to Central Bank • 40% Ministry of Finance to service Governments external debt • 30%Economic development fund (used solely to finance capital projects in the country) • 30%Reconstruction and Development Corporation (used to provide low interest financing to entrepreneurs in Agriculture, Tourism, Construction and other sectors such as religious, charitable, benevolent and nongovernmental organizations) Disadvantages • Heavily criticized • Crime and corruption FAILED Summary There are various advantages and disadvantages associated with the different citizenship and visa schemes of the countries examined. Country Leniency / flexibility Efficiency in handling application Required quality of applicants Cyprus Low High High Malta High Low High Portugal High Low High Bulgaria High Low Low Thailand High Low Low United Kingdom Low High High Why choose Cyprus? • Transparent and trustworthy – • High quality of life – • – – Low operational costs compared to other EU jurisdictions English – – • Standard uniform corporate tax rate of 10% which is the lowest in Europe EU and OECD compliant tax system Investor friendly tax authorities Good infrastructure – • Schengen Area and various other countries Advantageous tax regime – – – • EU citizenship for all the members of the family of the applicant (spouse, children under the age of 18 and children between 18 -28 provided that they are full time students in a recognized academic institution) Therefore right to live, work and study in any other EU country with privileges of a citizen Multiple nationalities (passports) allowed under Cypriot Law Freedom of movement – • Prominently featured in surveys and research on the list of countries that are best to operate, live, work or retire in Access to EU member state status – • One of the few countries to have passed the Henley & Partners country due diligence (the global leader in citizenship planning and citizenship programs) Widely used in businesses Legal system based upon English Common Law Strategic geographic location – – East meets west Excellent air and sea connections and telecommunications