
10-01-2023
You must have seen the advertisements on social media as well as on websites, from emigration consultants offering permanent residency (PR) or Golden Visa programs, based on investment, donations or real estate investments. If you are someone who has explored much in this context, then we hope you find our research and insights useful. And, if you are someone who has been wondering but not gotten around asking, this should serve as your 101 primer (at least we believe so!)
A resounding NO.
Permanent Residency is a right to reside in a country or jurisdiction, under certain conditions and considerations, but is not a citizenship. You will not get that countries Passport. Much is available on the net on this, and much more has been written, so we will try to keep it focused on what are the key features, and how can you benefit from each one, given that we talk of “yields, returns and the upside”; here at Afinue.com
Many countries provide PR or Golden Visa, which gives long term Visa free entry, in most cases linked to real estate or business investments, with a lock-in period for your investments. Currently there are a handful of countries that have some form of PR or Golden Visa Programs, linked to Real Estate or Business investments; and then there are others, mostly in the Caribbean and Pacific islands who offer citizenship based on similar investments.
In short, many and with Covid-19 wreaking havoc on many economies, this might get busier, with many other countries looking to raise quick finances using this route. Let’s look at them, one at time, starting with the holy grail of them all.
You need to invest around 1 Million USD in a major city, or 0.5 Mn USD in designated rural area through the regional centre route (there has been some changes in this, so you will need bit of digging on this to be done). The investments must create jobs, so its not a passive investment; and for real estate, the projects approved are likely to be all in development stage. Simply put;
There are EB5 approved real estate projects, which are advertised by developers or emigration agents, which can qualify for this program. However, you must understand that there are possible risks, if the underlying investments that are made in the areas, do not create jobs, then all applicants are at risk of losing the conditional PR. Further, the rural area properties may not appreciate much or may not give yields.
We are sure that most of you who has ever thought of emigrating to Canada has come across the point-based PR system. You may also have come across the citizenship by investment option. This is one of the simplest investment options leading to a citizenship, over time. This doesn’t need you to invest in real estate or anything similar to that. In short:
While we did pick Canada here, which isn’t really a Real Estate investment backed citizenship program, we are not detailing any other ones, which have similar programs; viz:
So that leaves us with those that allows real estate (read real assets backed) investment options, and where we think there can be an upside to your investments for getting a PR. Lets start with the smaller islands.
The Caribbean islands provide citizenship by investment, including well established real estate linked investments, where you do get a passport right up. Let us look at them in more detail.
Going into the balmy waters, a very known option is with A&G. This citizenship by investment program (CIP or CBI) grants you a passport upfront and the options have increased over the years, though the cost of real estate option is a bit high.
The passport comes with a 5 year validity and there seems to be a 5 day residency requirement over total of 5 years.
Overall, a good option if you just want another passport, but not much upside from the investments in the near to medium term. While the passport is quite strong, as it allows Visa free entry to about 165 countries (as per various web resources as of August 2021); the benefits A&G is actually for those who want to retire with a significant corpus or those who want to live a “global” lifestyle.
Lets look at the real estate. Projects that are pre-approved, are generally under construction stage. Current list of pre-approved projects, can be found at
Approved Development Projects | The Citizenship by Investment Programme (gov.ag)
Its quite evident from the above real data, that its generally more expensive to buy into pre-approved CIP projects, than into an existing re-sale project, however that will not give you a Passport. Further, a ready property allows for early rental income, while the under-construction project is some time away from generating any yield for you. In essence, pre-approved projects will probably not provide any upside for a long while, as all projects are fairly large (example quoted above is a 33 acre, 3 phase project, that will be built over time).
Another option is to invest in pre-approved hotel projects. Here the cost of the villas or rooms can differ, but you will have the choice to buy into say 5 hotel units, as against one Villa unit, and increase your potential rental yield. In some cases, the hotels are already operating, which gives you options to earn yields pretty quickly, on your investments
Not far from A&G and loudly famous due to a recent fracas involving an infamous Indian origin personality, this island nation has an evolved and long running program. As with A&G, you invest to get the Passport.
One of the most exciting programs on offer in the Caribbean, given that you can get the real estate cheaper than the neighbours, the holding period is less and there are no taxes (read capital gains tax); though there are some questions on whether you will make a capital gain or not!
Let’s look at the real estate options for Dominica as well. Current list of pre-approved projects are available at:
Dominica Approved Real Estate Projects | DCBIU
The typical new project costs vs resale costs for similar locations at Dominica are as follows:
Even here it’s quite evident from the above real data, that its generally more expensive to buy into pre-approved CIP projects, than into an existing re-sale project. However, the quality of resale standalone projects may not be easily assessable and readily available. Resale of these ‘resale’ units maybe a drag in case you ever need to sell them and they won’t work if you want the CIP. Given the current market and supply, it seems appropriate to summarise that if you want a Caribbean country Passport, with 130+ country visa free access, and with a chance to make some yield on your investments, Dominica is probably the most affordable option, and the hotel units the preferred investment mode.
One of the oldest CIP programs in the Caribbean (started back in 1984), it provides 2 simple options. It’s been awarded the best Citizenship by Investment program in the world by “Professional Wealth Management” publication.
Simply put, it has the following options and benefits,
Given the early start with its CIP, St. Kitts and Nevis has one of the more expensive resale property markets, amongst all the Caribbean islands. It also has the best infrastructure for tourism, and by opening up the limited window of buying into existing resale properties, till October 2022, we believe St. Kitts has created unique options for investors. However, the high cost of properties, combined with higher lock in makes the location bit unattractive against the other options in the Caribbean. Its more suited for UHNI’s and HNI’s who have significant cash burn ability, as compared to those who are searching for an upside from these investments.
Grenada’s CIP program is one of the newest citizenship investment programs. It was introduced in 2013. However, Grenada is the only Caribbean program with no country restrictions; that makes the due diligence and background checks a little more stringent and time consuming.
Like with all others, there are fees and taxes additionally, which can be extensive and not hard coded, so needs some study. Background checks will be extensive and they are basically looking for HNI’s to settle or invest. Please refer to below link for a quick check of current list of pre-approved projects for CIP in Grenada.
List of Approved Projects (cbi.gov.gd)
The biggest clincher for Grenada is the E-2. The E-2 ‘Investor Visa’ accord signed between Grenada and USA allows citizens of Grenada to operate business in the U.S. and reside there. Grenada isn’t as cheap as A&G or Dominica. A typical 1 BR unit in a condominium can costs between 150-250K US$ and typical 2 BR costs upwards of 300K US$. This is the simplest choice, if you have business in the USA or wish to eventually end up there, look for the E-2 option.
This is the newest CIP programs in the Caribbean (started back in 2015), it provides multiple and simple options; most innovative of all the Caribbean options we have discussed thus far.
Now before we move to the next section, lets surmise on the key aspects of CIP’s in the Caribbean, beyond the rules and contours, and more into impact on your lives and lifestyle.
Remember that the programs have many underlying if’s and but’s (conditions and consequent costs); for example, the pre-approved list of projects are not easily available with a simple Google search, even in this day and post COVID age; and Things change from time to time, so you will need to study everything, again, every time you seek to make up your mind.
The other region, and arguably more sought after, for Asians (after the US, UK and Canada) has been the Schengen region. Let’s have a hard look at what are the choices across Europe, within and outside the EU countries.
Cyprus had one of the simplest programs to obtain a Citizenship in an EU member Country (by investing 2.2 Mn Euro) and thereby a passport, till 2020. Now that is suspended, the only option left is to acquire a Permanent Residency, and then wait for about 5-7 years to apply for full citizenship. The Cypriot PR can be obtained in the following manner:
Cyprus, though not a full continental European nation, is not part of Schengen yet. It however has one of the best healthcare systems in the region. The PR allows for stay or study opportunities across EU countries, and work opportunities for children, and gives a lot of flexibility to operate business in Cyprus, as well as the EU. It is one of the cheapest options to get a PR that allows relatively unhindered access to the EU zone. However, for citizenship through this route, there will be a minimum stay requirement, which our assessment shows to be about 7 years, with a PR.
Malta citizenship by investment, officially referred as the Malta Citizenship by Naturalisation for Exceptional Services by Direct Investment; is a unique citizenship by naturalization program. It grants citizenship through a certificate of naturalization to expats and their family’s basis their contribution to the nation’s economic growth. This happens following a 36-month (there is an option for a shorter 12-month exception method, by paying more) residency period.
We tried to understand these, but must confess, all the web resources were only confusing us. We then tried to make sense from the Maltese government’s own web resources, and here is what we have learnt. In Malta’s CIP, the citizenship can only be obtained if the applicant makes a combination of investments. These investments include a direct, non-refundable investment, a real estate investment, and a charitable donation. This process is a new one (started in November 2020) and replaces the earlier Maltese Citizenship program (you may have had heard of that). The Maltese Citizenship route has the following steps (we tried to make it as simple as possible and as best as we understood):
All in all, not the CIP - GOAT that some consultants make it to be, and very cumbersome to get your head around. Though there are a lot of benefits, being part of Schengen, and complete borderless access to rest of EU, including for health, education and work.
The upside seems to be mostly the EU citizenship benefits, and not so much from the real estate or the investments. Though, after slowing in the first half of 2020, Malta’s housing market is gaining some momentum. The property price index rose by 5% during 2020, following rises of 2.5% in 2019, 11.9% in 2018, 8.8% in 2017, 13.8% in 2016, and 10% in 2015, according to the Central Bank of Malta (CBM). Given the rates, the upside can only be gained from better price negotiation of the real estate and hoping that property prices keep increase in the 8-9% range, till the 5-year lock-in is completed.
Well, if the above isn’t confounding enough for you, Malta also has a PR program, as against the Citizenship. Shall we look at that now?
In either case of Citizenship or PR, there is a need to invest in real estate, and in both cases the real estate can generate yield for you. Hence, while calculating the costs, its pertinent to consider the returns on the investments. The bond investment is also said to return about 3% annually, for the 5 years lock-in, under the citizenship option. So, unless you are good at building cash flow models and assess RoI, you will probably need some help figuring this one out.
Portugal offers a blend of options for the Golden Visa, which translates into Permanent Residency in 5 years, and thereafter right to obtain Citizenship, after an additional 5 years. During the Golden Visa period the conditions for living in country is quite relaxed, but during PR, it goes up, to give eligibility to Citizenship application after the 10th year.
You can opt for the following options to apply for your Golden Visa, and set the ball rolling:
Your investments are allowed to earn a yield but remain invested for the duration of your Golden Visa.
During the time of your Visa validity (typically 5 years), you need to stay in country for 7 days in the first year, and thereafter about 14 days for each year. Then, once you are granted a PR, you will need to maintain minimum stay, for being eligible to apply for the Citizenship (that 10 years down the line).
Now that sound and reads much simpler than what we saw for Malta. The options to club multiple applicants into one pool and then invest in either an approved fund or a business that then invests in a real estate development (that generates jobs); is an interesting proposition, which can enable higher upside from your investment if done with adequate diligence and proper structuring. However, one must be mindful that when the time comes, the citizenship application needs to be supported by test results for local language proficiency, something that wasn’t a must in Malta.
While there is no list of “approved projects” by any government agency; and the investment value is determined by the price of the property as shown in official documents, supporting your Golden Visa application; project price discovery becomes a significant area of diligence that you will need to do, should you choose to invest directly into the real estate.
We will keep this one short, as this is slowest Citizenship program. And it starts with a Permanent Residency. Applicant first needs to invest roughly about 560K US$ (1 Mn in local currency) into a government bond. This will be held for five years, then returned to investors without interest. Once done, you are issued the investor PR.
Thereafter, one year after the PR is issued; during which time no minimum in country residency is needed), you can apply for the Citizenship. This basically takes the overall time to near about 2 years, which is high compared to all other options out there.
You’ll then need to invest an additional 1 Mn in local currency into government bond or into a approved project by a Bulgarian company, that is pre-approved as an investment project, as per Bulgaria’s Investment Promotion Act. Interestingly, Bulgaria allows applicants to borrow the requisite investment amount through a loan from an European bank, should they be eligible and manage it on their own. The bank will take about 330K US$ in interest and charges to finance a 1Mn Local currency loan (that’s a sunk cost for the borrower)
Bulgaria’s passport allows visa-free travel to 150 countries, but not to the US. It also not an overtly English-speaking nation; and given that there is no real estate option, it makes the upside options near zero.
This one has been getting a lot of bytes on the social media, the consultants are heavily advertising this, and that begs the question, is it worth all the hoopla?
Its one of the newest options in Europe, started in 2019, refreshed and relaunched in 2020. You will need to do the following:
Like the Caribbean options for real estate, there are government-approved real estate projects, to choose form. Refer the below link for the approved projects (keep checking on it for changes, as its likely to add more).
Economic citizenship – MIA – Montenegrin Investments Agency
Montenegro isn’t part of the EU yet, but if it makes it in 2025 (when the new members are assessed), then this can become a pretty cheap option. That is precisely how and why this option is being marketed today by all the agents and consultants.
However, as the investment is in real estate, and as the current projects are mostly in the hospitality sector, the overall impact of Covid on tourism may have a lingering effect on the rental upside from the investment (also we haven’t been able to clearly figure out from the law whether you can earn rentals from your investments); while its locked in. Also, the program is likely allow only 2000 applicants and is to end on 31st December 2021 (as per current web resources we checked); so there is an added FOMO being created for this. We haven’t been able to get clarity on period of lock in of the investment, whether yield / renting is allowed/ whether the hotel developer will share revenue or not. We will also need to consult someone as the information is really scarce; and that doesn’t give confidence.
A full EU member and part of Schengen, Latvia doesn’t have a CIP anymore. It does still have a Residency program, but without an option of Real Estate investment. The current program is a simple business investment, and requires the following:
Upon equity capital infusion in any one option, a temporary residence permit will be issued. Applicant can include dependents in the application, upto total 4 member in one application (1+3). The temporary residency permit will have a validity not exceeding 5 years. After that, you may renew your residence permit if you still fulfill the requirements, or you may apply for a permanent residence permit. Language skills proficiency needs to be demonstrated and significant physical residency in the country for 5 years may be required for permanent residency. The passport allows for visa free or visa on arrival access to more than 180 countries.
This is still a citizenship by investment program, as against the Residency plans buy other European nations (excluding Malta, North Macedonia and Montenegro). You need to do the following:
Other things to think about:
Key concerns:
It is definitely one of the alternate options, for someone looking at the Caribbean to access the US Citizenship. Costs for real estate is not through the roof, and some locations may afford reasonable rental yield. Turkey has earned almost 1.3 Bn US$ through its CIP program. It appears that 2020, as per news reports, 7300 foreigners from 93 different countries had obtained Turkish Citizenship by investment in property. Its very popular with Middle Eastern residents.
The country is up for EU membership between 2023 and 2025; and has been awaiting the same since 2005. The CIP is simple and doesn’t have an end date, like the one in Montenegro, at least as yet. What are the investment options:
This is one of the simplest ones, cheap, but doesn’t allow for real estate investments. In case you have a good business to build or to invest in the local market, this is really one of the cheapest options out there.
Of all the PR programs by continental European nations, this one is definitely the one that is designed to promote real estate. You have the following options when it comes to investments:
So it’s a no brainer that probably a combination of a real estate investment, clubbed with a Spanish company share investment, could actually turn out to be a high alpha option. One concern that always needs addressing is an additional 13-15% of costs and taxes on the investment value, that will come basis VAT, registration fees, bank charges etc.
You get an initial temporary residency within 2-3 months of initial application and investments, and thereafter need to renew it every 2 years. You will need to go there to renew the Visa. After about 10 years, you are eligible for citizenship application.
The program is simple and provides multiple options of combinations which makes it one of the most endearing one, if you are seeking an upside to your golden visa expenses, for a full EU Schengen country.
Simple and probably the cheapest in all of full EU and Schengen countries, the Greek Golden Visa can be acquired by investing in Real Estate.
Its one of our favourites, as it allows for rental yields from resale property, allows you to buy land, and not built units, and hence gives the maximum flexibility in case you have a large family or want to acquire the golden visa in a group, with other family members.
The only African nation that has something that makes sense and is also a great place to live. The Indian ocean island has a culture similar to India, has a strong local economy, has come out of Covid quite well and will look to grow its regional economic influence in the post COVID world. There are multiple options, but the simplest one that is linked to Real Estate, is an investment of 375K US$ in any of the 4 categories of projects: viz:
There are other options as well, including business investments, but since the alpha on those cannot be clubbed with the real estate investments, we have kept them out of the discussion here.
Well after having done a deep dive across all the options, and running across multiple agents, consultants and governmental web and knowledge resources, we have come to believe that the best options are those that afford you options for mixing various models, has an underlying real estate asset base; allows for rental yields and is generally a good country with strong economy, easily accessible from Asia and cost of living (should you need to live) won’t be prohibitive. So what does that leave us with?
Each of the above 4 countries checks on all the boxes (maybe a little less for Cyprus at this moment) which makes them the top tier candidates for Upside on your Golden Visa and Citizenship investments.
Afinue.com is building out potential opportunities in each of these regions and has strong local partnerships to find you reasonable real estate (we target ground floor entry prices though bulk booking); with the combinations of cheaper other costs, higher yields and locations that can provide high IRR by the time you are ready to resale.
To know more, Reach us on :Deals@afinue.com
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You must have seen the advertisements on social media as well as on websites, from emigration consultants offering permanent residency (PR) or Golden Visa programs, based on investment, donations or real estate investments.
