1. Comparison of Citizenship by Investment Schemes
Christos Vezouvios 1

2. 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? 2 2

3. What are citizenship schemes?
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 3 3

4. 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 4 4

5. 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 5 5

6. 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. 6 6

7. 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

8. 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

9. Cyprus Advantages Disadvantages
Enables non-EEA citizens to obtain a passport and citizenship of an EU 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 18-28) 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
High demands/requirements

10. 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).

11. 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

12. 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

13. Portugal Advantages Disadvantages Short residency period
Criteria not too demanding
Freedom of movement in Schengen Area for 90 days every half year
No citizenship, therefore no EU passport
Corruption
Crime

14. 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

15. Malta Advantages Disadvantages EU citizenship Commonwealth citizenship
No minimum stay in the country necessary
Fast track process 3-4 months
Passport after 12 months
Visa free travel to over 180 countries
Lenient
Low standards of scrutiny
Heavily criticized from EU for setting low requirements

16. 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;

17. United Kingdom Advantages Disadvantages UK Tier 1 Entrepreneur Visa
Set up or take over the running of 1 business or more
Work for your business, including being self-employed
UK Tier 1 Investor Visa
Work and/or study in the UK
International business centre
You can apply to settle
after 2 years if £10 million is invested
after 3 years if £5 million is invested
Cannot work outside your business, e.g. work where you’re employed by another business
Not granted public funds
Not granted citizenship
Cannot Invest in companies mainly engaged in property investment, property management or property development
Cannot work as a professional sportsperson or sports coach; and doctor or dentist in training

18. Bulgaria Investor Program for Residence and Citizenship in Bulgaria
Founded in 2009 to attract foreign investment and business interest in the country

19. 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.

20. Bulgaria Advantages Disadvantages EU citizenship Dual citizenship
Favorable taxes
Language competence not required
Government support for priority investment projects
Competitively priced healthcare and education
Relinquishment of current nationality not required
Leniency might affect quality of accepted applications
Less developed country

21. 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)

22. 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

23. Thailand Advantages Disadvantages Visa free entry to over 80 countries
Tax status
Exempted from 3 year residence requirements
Ineligibility for those with major health problems or diseases

24. Belize
Investor Citizenship Program terminated in 2002

25. Belize Advantages Disadvantages 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 non-governmental organizations)
Heavily criticized
Crime and corruption
FAILED

26. Summary Country Leniency / flexibility
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
Malta
Portugal
Bulgaria
Thailand
United Kingdom

27. Why choose Cyprus? Transparent and trustworthy High quality of life
One of the few countries to have passed the Henley & Partners country due diligence (the global leader in citizenship planning and citizenship programs)
High quality of life
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
EU citizenship for all the members of the family of the applicant (spouse, children under the age of 18 and children between 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
Schengen Area and various other countries
Advantageous tax regime
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
Low operational costs compared to other EU jurisdictions
English
Widely used in businesses
Legal system based upon English Common Law
Strategic geographic location
East meets west
Excellent air and sea connections and telecommunications