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Immigrant investor programs are programs that allow individuals to more quickly obtain residence or citizenship of a country in return for making qualifying investments.
Broadly, the programs offer either citizenship by investment ("golden passport" or "cash-for-passports"), residence by investment ("golden visa"), or a hybrid with immediate residence followed by accelerated citizenship.
Program applicants must usually fulfill multiple qualification criteria. Investment can take a variety of forms including a contribution to government funds; purchase of qualifying real estate (for example, in specific government-sanctioned projects); investment in a qualifying business (for example, in a specific industry); or creation of a set number of jobs.
A growing number of countries offer immigrant investor programs, with approximately one quarter of all countries issuing such visas as of 2015.[1] As of 2023 about half went to Turkey.[2]
Citizenship by investment programs enable the applicant to rapidly obtain citizenship with no required residence period, or only a short nominal period measured in days or weeks. These are often known as "golden passports" or "cash-for-passport" programs, offering visa-free travel and possible tax advantages.
As of mid-2023, more than twenty countries had citizenship by investment programs.[3] These included five countries in the Caribbean (Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia), as well as Cambodia, Egypt, Jordan, Malta, North Macedonia, Turkey, and Vanuatu.
Countries that have historically offered citizenship by investment include Austria,[4] Cyprus (closed), Ireland (closed), Moldova (closed)[5][6] and Montenegro (closed 31 December 2022).[7]
Annually, an estimated 50,000 people, including family members of those who apply, obtain citizenship through investment programs, worldwide.[3]
Dominica
Dominica implemented its program in 1993 to provide investors the opportunity to gain Dominican citizenship via a contribution to its Economic Diversification Fund or the purchase of an alternatively approved project along with a fee.[8] As of 2022, Dominica requires a minimum donation of $100,000 in its Economic Diversification fund or a $200,000 minimum investment in a government approved real estate project.
Malta
The Malta Individual Investor Programme,[9] which Henley & Partners was contracted in 2014 by the Government of Malta to design and implement, is similarly capped at 1,800 applicants. The minimum investment for this program is $870,000 with a non-refundable contribution of $700,000.[10]
St Kitts and Nevis
St Kitts and Nevis was the first country to offer citizenship by investment, starting in 1984.[11] It requires a minimum of $250,000 as an economic contribution to the country or to invest at least $400,000 in an approved real estate development.[12]
Turkey
Turkey offers Turkish Citizenship by Investment (TCBI). Investors are required to purchase real estate worth at least US$400,000 and hold it for 3 years or deposit US$500,000 in a bank in Turkey for a period of 3 years. Upon investing as above and submitting citizenship application duly, a Turkish passport is granted typically within 6 months.
Former schemes
Montenegro
Citizenship of Montenegro could be obtained within a year through an investment of €250,000 into approved development projects and a €200,000 government fee,[13] until closed in 2022.
Moldova
Citizenship of Moldova could be obtained through a €130,000 donation, but the program has been suspended since 2022.
Residence by investment programs allow an applicant to obtain a permanent residency visa for a country by making an investment such as purchase of property or investment in a business. These programs are often known as "golden visas". The programs (on their own) do not allow the applicant to obtain citizenship (see "Citizenship by investment" and "Hybrid programs" below). However, the person may eventually be able to apply for citizenship using standard naturalization procedures after residing in the country for a required amount of time.
Many users of such programs are wealthy Chinese and Russian citizens seeking legal security and a better quality of life outside of their home country. Golden visas have been especially popular with Chinese nationals, over 100,000 of whom acquired them during the period from 2007 to 2016.[14] In 2015, the majority of golden visas were issued to Chinese nationals.[1]
Numerous governments offer these programs including in Abkhazia, Australia, Brazil, Greece,[15] Hong Kong, Malta,[15] Monaco, New Zealand,[16] Portugal,[15] Singapore, Spain,[15] Ukraine, the United Arab Emirates and the United States.
In operation
Belize
Belize offers a investor residency program with a real estate investment of $250,000 and after 5 years an individual is eligible for Belizean citizenship which offers a CARICOM passport for travel.
Greece
Introduced in 2013, the Greek Golden Visa program offers residency to non-EEA nationals in exchange for specific direct investments in real estate or financial instruments, as an incentive to attract international capital flows. The program originally requires a minimum investment of €250,000 in real estate or €400,000 in securities or a bank deposit in Greece.[17] The investors' close family members also receive a residence permit without further investment requirements, including their spouse, children up to 21 years old, parents and parents-in-law.
By February 2023, the country had issued 10,105 residence permits to investors and 18,154 to their family members.[18] On 23 December 2022, the golden visa program was changed, setting the 5 year visa at a minimum of €500,000 for real estate investments in specific areas of the country, coming into effect on 1 August 2023.
From September 2024, the minimum threshold rises to 800.000€ for all areas except islands with populations below 3.100 people, where the minimum threshold is 400.000€. Furthermore, the "golden visa" buyer can buy only one house or apartment, with a minimum of 120 square meters, and is forbidden from short term rentals thereafter, such as through platforms like Airbnb. The penalty for failure to obey this law shall be a 50.000€ fine and cancelation of the residence visa.
Applicants should note that the golden visa is only for residence in Greece and no other jurisdiction, as this competence is reserved to individual member states of the European Union. It also does not permit employment in Greece. Furthermore it does not guarantee citizenship, which has separate statutory requirements, including a minimum 7 years filed tax residency of at least 183 days per year, and an examination on knowledge of Greek language and culture. Males may also be required to fulfill their compulsory military service.
https://www.ekathimerini.com/economy/1234609/greece-tightens-golden-visa-rules/
For comparison, ordinary residence visas are available, such as for Financially Independent Persons, or Freelance remote workers, that have a minimum income requirement with private medical insurance, and do not involve investment.
Hungary
Investing €155,000 in any completed residential property in Hungary or creating a local company to provide services, or to trade in goods, will give the investor a temporary residence permit for themselves and their family. Residential investment can give a permit lasting 5 years and the company route, 3 years. these visas are renewable. 3 years of continuous residence allows a permanent residence permit to be applied for. Seven years residency and passing a language exam will open the opportunity to acquire citizenship and a Hungarian passport.[19]
Italy
A two year residence permit achieved with buying a house, investing or donating €1,000,000. Investments being €250,000 in a start up, €500,000 in an Italian company or €2,000,000 in government bonds. Extendable for three years periods and after 10 years may be eligible for citizenship.[20]
Latvia
An investment of €50,000 into a Latvian company, provided the company pays at least €40,000 per annum in tax will gain the investor a five-year residency after paying a one-off €10,000 fee to the government. The residency is renewable or it can be converted to permanent residency after four years of residency. Citizenship is obtainable after 10 years.[21]
Portugal
Portugal introduced a golden visa during the Great Recession to help attract investment into the country's housing market. The programme was launched in 2012.[22]
By 2023, the country had issued more than 10,000 golden visas (not including the investors' family members), of which close to 50% had been issued to Chinese nationals. All visa holders bought properties, lived in them for 2 weeks before leaving them empty or renting them out to holidaymakers, resulting in rising property prices and long-term rentals became unaffordable for locals. €7 billion has come into the country, 90% being used to buy property. Only 2 visas a year were issued for job creation reasons.[23]
On 16 February 2023 the Government announced that it would close the programme as soon as possible.[24] However, on 7 October 2023, the Government announced that the Golden Visa will continue albeit without the real estate option.[25][26] This change was brought about to address housing affordability issues in Portugal, while also redirecting foreign investments towards other sectors.[27]
Russia
Russia opened its Investor Visa program on December 31, 2022.[citation needed] It provides the opportunity to gain permanent residency in Russia for the applicant and their direct family.[citation needed] To apply, one has to either sponsor a social project, purchase real estate, invest in a business, or start their own company.[citation needed] The residency can be converted to citizenship after 5 years.[citation needed]
Spain
In 2013, Spain introduced a Golden Visa for residency with an investment of €500,000 in unmortgaged real estate, €1,000,000 in Spanish companies, or €2,000,000 in Spanish government bonds. This visa is also available to people with a business project that will make a "significant" contribution to the Spanish economy.[28] The Golden Visa also allows holders to travel freely to and from Spain without taking up (tax) residency, as long as they visit the country once per year to renew the visa.[29] However, because the visa itself is considered equivalent to a residency card, holders also have the right to travel within the Schengen area on visa-waiver conditions, which is a considerable advantage to citizens of certain countries who might otherwise have difficulties obtaining Schengen visitor visas.
On 8 April 2024 Spanish Prime Minister Pedro Sánchez announced that his government would terminate the Golden Visa, but without specifying an exact end date.[30]
United Arab Emirates (Golden Visa)
The UAE introduced the 10 year Golden Visa system in 2019.[31][32] It allows qualifying individuals to live, study and work in UAE without the need of a national sponsor. The residence visa program, offers various possibility to become a resident in the UAE for certain category of professionals, such as PhD holders, scientists, outstanding professional in a specific field or industry and/or to doctors and their families.[33] Other skilled professionals included are senior scholars, elite specialists in industry and fourth industrial revolution, specialists in health industry and education.[34]
Golden visa holders are allowed to sponsor their family members which includes spouse, children and support staff. The visa can be renewed if the required criteria is met. Unlike some other golden visa programs which requires the visa holder to maintain a duration of stay in the country, the UAE golden visa has no restriction on the maximum duration of stay outside the UAE to maintain validity of the visa.[35]
United States
The United States has two main investor visa programs: the E-2 and EB-5 visas.
- EB-5 Visa (green card)
The EB-5 visa program is administered by the U.S. Citizenship and Immigration Services (USCIS). Successful applicants and their family can apply for a green card.
The EB-5 visa program, which is also called as the Golden Visa program, requires applicants to invest between US$900,000 and US$1.8 million, depending on the location of the project, and requires at least 10 jobs to be either created or preserved.[38][39]
There is an annual cap of 10,000 applications under the EB-5 program.[40] The program is designed to encourage foreign investment in infrastructure projects, particularly in Targeted Employment Areas (TEA) with high unemployment. Funds are channeled through businesses known as regional centers, now designated only by the U.S. Department of Homeland Security. An example of a project is a US$200 million development by the Pennsylvania Turnpike Commission.
In March 2022, the EB-5 program was overhauled with the passage of new legislation called the EB-5 Reform and Integrity Act (RIA). Positive changes were introduced by RIA to enhance the appeal of the program. RIA allows concurrent filing which permits investors to live and work in the USA while waiting for the adjudication of their EB-5 applications.[41]
- E-2 (non-immigrant)
The E-2 visa investor program allows foreign nationals of specific treaty countries to invest in a start up, buy a business or a franchise to reside legally in the U.S.[42][43]
The initial visa term varies from three months to five years depending on the U.S. reciprocity schedule with the applicant's country of citizenship. The E-2 visa can be renewed indefinitely and it is possible for the investor to change their legal status to a green card (e.g. EB-1A, EB-2, EB-3 or EB-5). The E-2 visa investor must commit to investing a substantial amount (generally US$100,000) and create American jobs (usually 2+). Most investments under US$200,000 will require the investor to work 40+ hours a week in the business at least for the first 12 to 18 months.
As per recent changes made to the US regulation, individuals holding a passport from a treaty country are required to be domiciled there for a period of three years before being eligible to apply for the E-2 investor visa. This amendment was introduced as investors who were not from the treaty countries would obtain citizenship in one of the treaty countries to become eligible for the E-2 visa program.[43]
Closed down
Canada
The country historically had a national-level Canadian Immigrant Investor Program since 1986, but it was suspended in 2014. Most of the applicants were Chinese, who preferred to settle on the Pacific coast. The program has been associated with the lack of housing affordability in Vancouver.[44]
Quebec maintains its own program, also established in 1986 – the Quebec Immigrant Investor Program – since the province has the right to set its own immigration policy due to a legal agreement with the federal government.[45] The program was suspended between 2019 and 2024 by the province, citing problems with the program's "integrity" and low retention rate.[46] In 2024, the government reopened the reformed program, which imposes more stringent financial requirements and requires the applicants to be fluent in French, barring the majority of potential investors.[47]
Ireland
Introduced in 2012 the "Immigrant Investor Program" (IIP) offered non-EEA nationals residence permission based on long-term investment into enterprises, investment funds, real-estate or non-profits in the Republic of Ireland.[48][49] It did not offer permanent residency in Ireland, but could be extended every few years for an indeterminate period.[50]
The IIP closed in early 2023. Since 2012 the program has brought €1.17 billion to Ireland. The majority of investments were made by Chinese nationals.[51]
United Kingdom
The UK had a program known as a Tier 1 (Investor) visa, which opened for applicants in 2008.[52] Applicants were required to invest £2 million or more in the UK and meet other eligibility criteria. Visa holders could reside in the UK for a maximum of 3 years and 4 months, with the ability to apply for an extension of 2 more years. The visa holder could apply to settle after 5 years or less; the greater the investment, the shorter the waiting period.[53] According to the Home Office, 255 visas of this type were granted in the first half of 2019.
The Tier 1 (Investor) visa scheme was closed to new applicants on 17 February 2022.[52]
Hybrid residence-citizenship programs allow applicants to first obtain residence and then, after an accelerated residence period (as short as 2 years), obtain citizenship.
This type of program was offered by a number of countries including Bulgaria, Hungary, Mauritius and Samoa.
- The Bulgaria scheme allows a company, or part of a company, to be brought to the country, or to create a new company that will employ at least 10 locals, or to invest in residential property, to apply for a D class visa and Bulgarian residence.[54]
- The Hungary program required a €300,000 purchase of interest free government bonds, repayable in 5 years, plus a €60,000 one off fee for the applicant, which covered all family members, the 5 year visa was renewable at no extra cost and citizenship could be applied for after 8 years. Opened in 2013, it closed in 2017.[55]
- In Mauritius an investor needs to buy a luxury residential property in a specific development, or a ten year investment into a choice of businesses.[56]
The sale of passports and "golden visas" has sparked controversy in several countries. Some of the criticisms include doubts about the economic benefits, as well as security concerns. A 2023 study found that citizenship-by-investment programs increase tax evasion.[57]
Golden visas have been criticized by members of the European Parliament for disfavouring the concept of citizenship[58] and in 2014 the European Parliament approved a non-binding resolution that an EU passport should not have a "price tag".[59][why?]
Money laundering scandals involving banks in Malta and Latvia have made citizenship schemes more contentious by drawing attention to the lack of controls on Russian funds entering EU countries.[60]
Following the 2022 Russian invasion of Ukraine, the Biden Administration in the US described golden passport programs as a loophole for wealthy Russians to get around sanctions.[61]
In 2023, the security problems caused the United Kingdom to withdraw visa-free travel from Dominica, Honduras, Namibia, Timor-Leste and Vanuatu, citing “clear and evident abuse of the scheme, including the granting of citizenship to individuals known to pose a risk to the UK”.[62]
In 2023, the European Commission proposed revising the rules on visa-free travel from countries with golden passport programs.[63] In 2024, the European Council agreed on a draft regulation that would update a mechanism to suspend visa-free access for "third countries", which include the operation of an investor citizenship scheme as a valid grounds for suspension of visa-free access.[64]
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