Page 1

Includes Caribbean Spotlights Feature I S S U E 19

AU T U M N 2 0 1 9

USA, Canada, Portugal, Greece, Turkey, UK, Caribbean Spotlight and more...



Next Stop

+44 (0) 207 241 1589


For the latest information visit: www.giisummit.org

CONTENTS Autumn 2019 City focus Bengaluru


Features The Pace of South African Migration Continues to Rise: Where Are They Going?

35 Years of CBI: The Recipe for Success Has Three Ingredients

10 Reasons Indian HNWIs Have Been Slow to Embrace Investment Migration

India is Forecast to See The Greatest Rise in Wealth Populations Over The Next Five Years

Latvia’s Golden Visa Back from The Doldrums, Courtesy of Vietnamese Investors

Coming from All Over to Down Under: Australia is the Number One Destination for HNWI Migration

Europe Remains Prime Destination for Alternative Residence and Real Estate

The Rush is On: New Rule Nearly Doubles EB-5 Minimum Investment As of November 21



Country Spotlights Section Index Caribbean Section


Antigua and Barbuda






St. Kitts and Nevis


Saint Lucia


European Section



















North American Section







BLS Media are contract publishers of high quality media for prestigious organisations, event organisers, governments and trade organisations both in the United Kingdom and internationally.

Published by BLS Media Ltd, info@blsmedia.co.uk www.blsmedia.co.uk Unit 5, Hiltongrove N1’, 14 Southgate Road London N1 3LY

Our experienced publishing team will develop your publication from initial concept through to completion. Our services include creative design, PR, advertising sales, sales training, editorial and distribution. Whilst every care has been taken in compiling this publication and the statements contained herein are believed to be correct, the publishers and the promoters will not accept responsibility for any inaccuracies. Reproduction of any part of this publication without permission is strictly forbidden. BLS Media make no recommendation in respect of any of the advertisers and no recommendation may be implied by way of the presence of their advertisements. Advertising: For advertising enquiries in future editions of this magazine contact Sam Hussain: info@blsmedia.co.uk I www.blsmedia.co.uk

FEATURES: INTRODUCTION Welcome to the Autumn 2019 issue of Citizenship by Investment, your one-stop resource for what’s new and topical in residency and investment migration around the globe. This is the 19th edition of our magazine, available both online and in print. We are launching this issue at the Global Investment Immigration Summit 2019 in Bengaluru, so if you are reading this in the Shangri-La Hotel in Bengaluru, we are pleased to welcome you to the event. We have included a City Focus on Bengaluru on pages 8-9 followed by a review of our successful GIIS event in Johannesburg held in June. This year marks the 35th anniversary of the launch of the first programme to grant citizenship through donation or investment in real estate. On pages 14-15, CS Global look back at why the St. Kitts and Nevis CIP is still the standard bearer for investment migration schemes and what the key ingredients are for future growth. Compared with China and Russia, India has been relatively slow in embracing investment migration, although this has changed dramatically since 2017 to become the second largest EB-5 investor market. Inside, respected lawyer and global immigration attorney Prashant Ajmera provides some insights on the Indian HNWI market that RCBI agents would be well-advised to be aware of. India is faring much better economically than most developing markets and The Wealth Report 2019 confidently predicts that Asia will see the greatest growth in millionaire populations over the next four years, with India leading the way (see page 19). The same report says that 36% of ultrahigh-net-worth individuals (UHNWIs) already have a second passport and a record 24% are actively planning to emigrate permanently (up from 34% and 21%

4 Citizenship By Investment

respectively last year). This begs the question: where are they planning to migrate? Tony Le Nevez, Director and Country Head of Henley & Partners Australia, gives us some insights and advice on the migration market ‘down under’, while Dominic Volek, Managing Partner and Head of Southeast Asia for Henley & Partners, looks at why more Asians are looking at second passports and residency in Europe. We also have an article from Christian Henrik Nesheim, the Founder of Investment Migration Insider, who shares with us the reasons why Latvia’s CIP has seen a relatively sudden uplift in applicants. Meanwhile, the big news from North America is that the minimum investment level to apply for the EB-5 program is nearly doubling in price from 21 November. We are pleased to include an article from Robert Divine, the Vice-President Emeritus of IIUSA, explaining how the changes may play out (pages 85-87). New CBI entrants This year sees the likely introduction of the Montenegro CBI programme and so we have included a first Country Spotlight on Montenegro. We have also added a first Country Spotlight on Turkey, which has seen a big uplift in interest since the Turkish government reviewed its Citizenship Act requirements in September 2018. This issue also includes a full Caribbean Spotlight and updates on many of the European residency and citizenship by investment programmes. As always, you will also be able to find these articles, and much more besides, on our website www.citizenshipinvestment.org where you can register for free regular updates. You can also follow us on social media. BOB WITTENBACH, Editor, 11 September 2019

www.citizenshipinvestment.org www.bit.ly/blsmedia www.bit.ly/bls-giis www.bit.ly/blstweet

Purveyors of Publishing Excellence BLS Media is an innovative, progressive and creative media company with traditional attention to detail, led by experienced professionals.

BLS Media Unit 5, Hiltongrove N1


+44 (0) 20 7241 1589

14 Southgate Rd


+44 (0) 871 314 0213

London N1 3LY





Citizenships Still Issued After Moldova’s Citizenship-by-Investment (MCBI) Suspension Following Moldova’s four-month moratorium on their Citizenship-by-Investment programme for government review on 19 July 2019, applications that were submitted before July are still being processed. From the date of suspension of the programme, two applicants (including their dependants) have received citizenship in Moldova.

USA EB-5 Program Changes and Increase of Minimum Investment Costs There are new rule changes that will be brought to the EB-5 program, which are going to officially come into effect on 21st November 2019. These changes include priority date retention to certain EB-5 investors, increase to the required minimum investment amounts, reforms targeted employment area (TEA) designations and clarification for the USCIS procedures for the removal of conditions on permanent residence. However there may be challenges to the proposed changes and there may be other technical revisions to be made.

UK Migration Advisory Committee to Review Points-based System The new UK Prime Minister Boris Johnson confirmed to parliament that he will commission a further review of the points-based (PBS) immigration system. The Home Secretary has written to the Migration Advisory Committee (MAC) to review how an Australian PBS immigration system could be introduced in the UK and the MAC is expecting to report back by January 2020.

Greece rumoured to be planning a Citizenship by Investment Programme It has been reported that the new Greek Government are considering launching a CBI programme in 2020 which, if confirmed, would provide direct competition to the successful Cypriot citizenship programme. Currently Greece has a residency by investment programme - see page 57 for our Country Spotlight on Greece.

New Investment Opportunity in Egypt Parliament in Egypt had approved a bill that amended their law to introduce the grant of Egyptian Nationality to foreign investors for the price of 7 million Lei (approx. US$420,000) in September 2018. In early July 2019, the government had put forward amendments to the law in relation to obtaining Egyptian Nationality through investment.

6 Citizenship By Investment


EB-5 Retrogression Extends to Applicants in India India has – as expected – joined China (mainland born) and Vietnam on the EB-5 program retrogression list. The US Department of State – Bureau of Consular Affairs has just announced a final action date of 1 May 2017 for the EB-5 applicants from India for both regional center and non-regional center programs.

Saudi Arabia’s New and Approved Residency Programme for Foreigners The new ‘Premium Residency’ programme in Saudi Arabia was officially approved (in May 2019)’ and is now open. The programme was first proposed by the Crown Prince Mohammed Bin Salman as part of a plan to boost foreign direct investments and reduce their dependence on oil.

Chinese Start-up Visa Opportunities Entrepreneurship and Innovation is one of the most focused concepts in China as they grow. The Shanghai Municipal Public Security Bureau in May 2018 had introduced the ‘Start-Up visa’, officially known as the new ‘private affairs’ category of residency permit (entrepreneur).

Malaysia Residence Programme Suspension Lifted The Malaysia My Second Home (MM2H) residence programme had been running for over 16 years with over 40,000 applicants. The authorities suspended it last year due to some security matters over the regulations of the programme in line with the immigration law, but now, after several months’ suspension, the MM2H programme is back.

For further information on the news updates above and future news on the CBI programs please visit: www.citizenshipinvestment.org

Citizenship By Investment 7


C I T Y F O C U S:



engaluru – also known by its Anglicised name of Bangalore – is one of the fastest growing cities in the world. It is situated in southern India high on the Deccan Plateau at an altitude of over 900 meters above sea level. From its establishment as a hill-fort in 1537, the city has doubled its population in the past two decades to become a megacity and the IT capital of India. The earliest references to Bengaluru date back to the 9th century when the region was ruled by the Western Ganga Dynasty (c.350 – 1004 AD). An inscription carved into a commemorative stone found in Begur Fort marks Bengaluru as a place where a heroic battle was fought in the year 890. The Nageshvara temple complex dates back to the 9th and 10th centuries as one of many historic temples located within the Bengaluru urban area that have survived from the Western Ganga Dynasty and the succeeding Chola era. The modern city was founded in 1537 by the Vijayanagaran vassal Kempe Gowda I as a mud-brick fort and the town was further developed by his successor Kempe Gowda II. Over the next three centuries, the city changed hands several times and became an important commercial and military centre within the Kingdom of Mysore. In 1791, British armies captured and successfully defended the fort during the fourth and final conflict of the AngloMysore Wars. In 1799, the British returned

8 Citizenship By Investment

State: Karnataka Area (City): 709 km² Area (Metropolitan): 8,005 km² Location: 12.59°N, 77.35°E Altitude: 920 metres Average high °C: Apr 34°, Nov 27° Population: 13.958 million (2019 estimate) Languages: Kannada (official), Tamil, Telugu, Urdu, Hindi, English Religion: Hindu (79%), Muslim (14%) Main industries: IT, Biotechnology, Electronics City GDP: $83 billion (estimate) Time Zone: GMT +5.30 Telephone area code: +91 (0)80

the administration of Bangalore to the Maharaja of Mysore, but retook administrative control in 1831 following allegations of misrule. Bangalore became a major garrison within the British Raj and a town quickly grew around the garrison. In 1853, telegraph connections were made to all the major Indian cities and six years later the railways came to Bangalore. Under British rule, Bangalore flourished as a cosmopolitan cultural centre, with new and improved health facilities, the introduction of house building regulations to improve sanitation and – in 1906 – electricity from one of the first hydroelectric plants to be situated in India. The Garden City of India Many of Bangalore’s architecturally historic buildings date from this period, including the Attara Kacheri (built in 1864) which today houses the Karnataka High Court, the State Archaeological Museum (1876)

and the Bangalore Palace (1887), which was built in a Tudor architectural style. In 1864, the British engineer Sir Richard Sankey designed and created what is now called Cubbon Park, a public area of landscaped gardens, natural groves, exotic flora and tree-lined avenues with marble statues. Originally around 100 acres in size, the park has since expanded to around 300 acres and has been called the ‘lungs’ of the city. Cubbon Park also played a major part in the Silver Jubilee celebrations of the Maharaja of Mysore Krishna Raja Wadiyar IV, giving rise to Bangalore’s reputation as the Garden City of India. India gained its independence from the UK on 15 August 1947 (celebrated annually as Independence Day), after which Bangalore was confirmed as part of the new Mysore state. In 1949, the two urban municipal boards (city and cantonment) were merged to form the Corporation of the City of Bangalore. The population began to increase rapidly, from 406,760 as at the 1941 census to 778,977

at the 1951 census, as many migrants from other parts of the state moved to Bangalore because of the public sector manufacturing employment opportunities and its education facilities. The State of Mysore was enlarged in 1956 to encompass other areas where Kannada was widely spoken as part of the reorganisation of India’s states based on linguistic and cultural criteria. Bangalore was selected as the state capital and the state was renamed Karnataka in 1973. Today, Karnataka is the sixth largest state in India with an area of 191,791 km² and a population of around 68 million, making it India’s 8th most populous state. Rise of the megacity By the time of the 1961 census, Bangalore’s population had exceeded one million and it continued to grow with the influx of many immigrants from Northern Karnataka. The city boundaries also grew as many public and private manufacturing companies opened plants and several national technological organisations including Hindustan Aeronautics Limited (HAL) and the Indian Space Research Organisation (ISRO) established their headquarters in Bangalore. During the 1970s, the

state government demarcated a large area of land outside Bangalore to create an electronic city. In 1984, Texas Instruments was the first multinational corporation to open a base in Bangalore and as more IT companies and scientific institutions developed, the city soon gained the reputation of being the ‘Silicon Valley of India’. Between the 2001 and 2011 censuses, Bangalore’s population mushroomed from 5.1 million to over 8.4 million and is still booming today, making it the 3rd most populous city in India and one of the fastest growing megacities in the world. Following the renaming of Bombay as Mumbai in 1995 and Calcutta becoming Kolkata in 2001, the local politicians and historians proposed in 2006 that the anglicised name Bangalore should be dropped; the federal government of India eventually agreed and on 1 November 2014, the city formally changed its name back to Bengaluru. Getting around Bengaluru Bengaluru’s international airport is situated approximately 40 kilometres to the north of the city near the village of Devanhalli. Original named Bangalore International

Airport when it opened on 24 May 2008, it was renamed Kempegowda International Airport in 2013 but is still known by the IATA code of BLR. It is India’s thirdbusiest airport by passenger numbers, handling 33.3 million passengers during the 2018/19 fiscal year. It is currently embarking on an expansion programme with the building of a second runway, second terminal and wider access roads being constructed. Currently there are no direct rail links to the city from the airport, although there are plans to extend the North-South line of the new Namma Metro rapid transit system to the airport by 2021. A fleet of luxury air-conditioned Volvo buses operated by BMTC provide shuttle services to and from various parts of the city and are an important and reliable means of public transportation for commuters. Taxis are generally fairly expensive and need to be booked in advance online or by telephone. A more popular form of transport are the three-wheeled autorickshaws, traditionally coloured yellow and green, which accommodate up to three passengers and are a great means for exploring and experiencing the vibrancy of the city.

INDIA, QUICK FACTS Full name: Republic of India Capital city: New Delhi Population: 1,339,180,127 (2017) GDP in Current prices: USD $2,716.75 billion (2018) GDP real growth: 6.8% (2018) Area: 3,287,263 km² Government: Federal parliamentary republic President: Ram Nath Kovind Prime Minister: Narendra Modi Currency: Indian Rupee ₹ (INR) HDI: 130th (2018) Ease of doing business index: 77th (2018/19) Time Zone: GMT +5.30 Dialling code: 91

Citizenship By Investment 9



Sandton Convention Centre, Johannesburg, South Africa, 21 June The Global Investment Immigration Summit Johannesburg 2019 was the first event of its kind to be held in the city and proved to be a great success for speakers, exhibitors and delegates alike. With the rate of economic migration from South Africa increasing since 2017, this was a timely event for high net-worth individuals (HNWIs) and investors to meet and network with immigration investment experts, attorneys, wealth managers, government officials and business professionals. Following the welcome addresses, the conference commenced with a lively introduction and panel session on the American EB-5 Investor Program, moderated by Mark Davies of Davies & Associates LLC and joined by senior representatives from CMB Regional Centers, EB5 Capital and Fragomen. Next up were presentations on the Residency and Citizenship investment programmes in Malta and Cyprus. These were followed by the second panel discussion of the day, moderated by Batoulim Sebabe of the Integritas Group. The session finished with a presentation and panel discussion on Canada. The early evening session focused mainly on the Caribbean and included presentations by CS Global’s Alexander Bello and the Honourable E.P. Chet Greene, Minister of Foreign Affairs for the Government of Antigua and Barbuda. A packed day’s programme finished with an insightful panel discussion on why South Africans should consider applying for second passports.

10 Citizenship By Investment

“BLS Global did a great job carrying out this event in Johannesburg. It was planned well and we met several potential investors.”

“Thank you for the awesome event. It was a great opportunity to network and learn about new updates in the world of investment migration.”

Juline Kaleyias, Director, Investor Relations, EB5 Capital

Julia Dugina, Immigration Consultant

“Sam and his team on the ground and all round were stars, their people skills and welcoming was fantastic.” Rose Lopes, Quality Group SA CEO & International Director

“I would like to thank BLS team for the professional work.” Batoulim Sebabe, Integritas Swiss Consulting, Executive Director

“I have to commend you on the excellent program and speakers really well done. You have given me tons to think about.” Trevor Genis, Investor

Citizenship By Investment 11



The BLS Global Investment Immigration Summit held in Johannesburg proved to be a great success, capitalizing on what has been an increasing trend of migration away from South Africa. According to the latest AfrAsia New World Wealth Report, as many as 10% of South Africa’s high net-worth individuals (HNWIs – defined as those individuals having net assets of USD $1 million) left the country during 2018, including around 1,800 from Johannesburg alone. Reports coming out of South Africa during the past quarter suggest that the trend shows no sign of abating any time soon. Last issue (CBI Spring/Summer 2019 page 94) we reported that over 100,000 South Africans have emigrated since 2006 and that the number of house sales due to emigration has been increasing since 2017. During 2018, the rand was the fifth worst performing currency globally against the US dollar, falling by 14%. By definition, this will have had some effect on the overall numbers of dollar millionaires in local currency (see chart 1), but it also highlights the concern of many South African businessmen in protecting their wealth and their propensity to make investments in the weakening domestic economy (chart 2).

national economies. However, whilst China and especially India have continued to grow at impressive rates, South Africa has slipped from being the 29th largest economy globally in 2011 to the 34th in 2018, with economic growth dipping below 1% last year to rank a lowly 168th in terms of real growth. Whilst South Africa is still the second-largest economy in Africa (behind Nigeria), the country is plagued with a relatively high poverty rate and one of the consistently highest unemployment rates in the industrialised world. Having peaked at 31.2% in the first quarter of 2003, the rate reduced steadily to 21.5% in Q4 2008, but has since been climbing again, reaching 27.1% by the end of 2018 and 29.0% in Q2 2019. With so many adults feeling disenfranchised by the lack of working opportunities, the levels of crime have been rising again within the past few years, having previously

12 Citizenship By Investment

Effects of crime and corruption Historically, most emigrants from South Africa were citing crime as their main reason for leaving the country, but more recently it has been for economic and business reasons as much as family security that the number of enquiries for moving abroad have increased this year.

Chart. 1

SOUTH AFRICA’S HNWIS NUMBERS AT YEAR END Number of South Africa’s HNWIs compared with the depreciation of the Rand (ZAR) 50



46.8 43.6

45 38.5


Following the abolition of apartheid and the general election of 1994 – South Africa’s first elections with general suffrage – the economy expanded by an average annual rate of 3.5% over the next 15 years. From a nominal GDP figure of US $140 billion in 1994, the economy had practically tripled to US $417 billion in 2011, the year that South Africa officially joined with Brazil, Russia, India and China to create BRICS, an organization of the five leading emerging

receded during the post-apartheid period 1994-2009. South Africa has notoriously high rates of serious assaults, rapes, carjacking and murder. Last year, the government’s police minister reported that there were 57 murders a day on average during 2017, representing a 7% increase over the previous year. For a country with a population of 57 million, that equates to a staggering 35.8 murders per 100,000 people, which, according to the United Nations Office on Drugs and Crime (UNODC), gives South Africa the fifth highest murder rate in the world and the highest on the African continent.



35 30 25 20 15









YE 2015

YE 2016

YE 2017

YE 2018


5 0

YE 2012

YE 2013

HNWIs (‘000)

YE 2014

100 Rand / USD exchange rate


Source: New World Wealth/Xe.com

The NWW 2019 Global Wealth Migration Review found that South Africa has a high level of income inequality. As a benchmark, New World Wealth suggests that if HNWIs control over 40% of a country’s wealth, that leaves “very little space for a meaningful middle class.” South Africa’s HNWIs control 42%, which is higher than the global average of 36% and even higher than China’s 40%. Japan is considered the most equal country, where its HNWIs control just 24% of wealth, with just 3% held by billionaires. At the other end of the inequality scale, 54% of Russia’s wealth is controlled by its HNWIs with 21% held by billionaires. The 2019 General Election saw the ruling African National Congress (ANC) returned to power but with a reduced share of vote, 57.5% their lowest share since the end of apartheid. However, this was enough to win 230 of the 400 seats in the National Assembly and eight of the nine provincial legislatures. The ANC had campaigned on making economic growth and reducing unemployment with special emphasis on youth unemployment its main priorities.

Amid fears of a possible recession and economic policy uncertainty, one leading immigration specialist firm Sable International last month reported a 70% increase in enquiries about moving abroad. Several commentators have also expressed genuine concern about the numbers of skilled professionals leaving the country compared with much lower numbers of skilled professionals coming into South Africa. In addition, the new National Health Insurance (NHI) Bill that was approved by government in early August 2019 has been widely criticised for a lack of clarity on funding amid fears that many healthcare doctors and specialists may choose to leave the country if the bill succeeds in restricting private medical schemes.

Services shows that around 10,200 South Africans had obtained permanent resident status between 2015-2017 through various means including naturalisation, business visas and green card recipients.

Migration of wealth and skills

Henley & Partners has also reported a significant jump in the number of South Africans enquiring about golden visa programmes as a means to protecting themselves from political uncertainty at home. Both Henley & Partners and Sable International highlight Portugal as a new favoured destination for South Africans; official figures from SEF reveal that South Africans are now the fourth biggest group of Portugal’s golden visa recipients by nationality with 194 visas issued since 30 June 2016 (behind China, Brazil and Turkey but ahead of Russia).

Unofficial surveys estimate that over half a million South Africans left the country between 1989 and 2003 when the country had been going through a lot of political uncertainty and upheaval. Of these, around two-thirds went to the UK, Australia, New Zealand or the USA. A study conducted by Stats SA during 2016 estimated that 97,460 South Africans emigrated between 2006 and 2016. However, there are no official figures, as after 2003 it was no longer compulsory for emigrants to declare their departure at airports. But it is possible to look at the number of immigrants and their country of origin for most receiver countries. For example, the South African BusinessTech news website reported in July 2019 that data provided by the US Citizenship and Immigration

In addition, the residency-by-investment programmes Cyprus, Malta and Greece are also attracting a lot of interest for South Africans as they offer visa-free access to the Schengen area of Europe, something which the UK may not be able to do for much longer…

Chart. 2

GDP % Real Growth of BRICS Countries 2011










9.6 7.9




The main opposition party, the Democratic Alliance (DA), won 84 seats and retained the Western Cape province, which includes Cape Town. The DA had campaigned on anti-corruption issues within government and state-owned enterprises, highlighting the public utility company Eskom that was spiralling out of control and causing power shortages and widespread electrical blackouts during March 2019. Eskom was largely blamed for the 3.2% drop in economic growth in Q1 2019 following 1.4% growth in the previous quarter.

The UK had always been the preferred destination for South African emigrants, but since the Brexit referendum in 2016 and the ongoing resultant uncertainty, there has been a five-fold increase in the number of EB-5 applications for the USA. Between 2006 and 2016, a total of 236 EB-5 visas were issued to South Africans, but the number issued within each year has increased for six consecutive years, rising to 40 in 2016, 53 in 2017 and 91 in 2018.

5.4 4.3 4.0 3.3



7.2 6.9


7.1 6.6





6.0 4.0

3.0 2.5 1.8

2.2 1.9

1.8 0.7 0.5


0.6 0.3

1.6 1.3 1.1

-3.3 -3.5




1.1 0.8

2.0 0.0 -2.0





South Africa Source: IMF/World Bank

Citizenship By Investment 13

35 YEARS OF CBI: THE RECIPE FOR SUCCESS HAS THREE INGREDIENTS by CS GLOBAL PARTNERS The idea of obtaining second citizenship in return for an investment took shape in the Federation of St. Kitts and Nevis in 1984. 35 years later, the programme still runs successfully, with many other countries emulating its model. What is it that makes a Citizenship by Investment (CBI) programme stand out and remain competitive? We discuss three main factors: due diligence, longevity and local impact.

14 Citizenship By Investment

Due diligence First of all, due diligence is the very foundation of a citizenship – and residency – by investment (RCBI) programme. Proper due diligence checks ensure that dishonest applicants never fall through the cracks. The European Commission raised this concern with regards to EU member states RCBI programmes, agreeing that more needs to be done to make sure this does not happen. We fully endorse the fact that, above all other aspects, security, cooperation and effective due diligence are paramount to managing a CBI or RBI programme responsibly. Due diligence is closely link to reputation and thus lack

thereof leads to reputational damage, which, in the long run, results in less trust from investors, external partners and native citizens. This is a cost too high to ignore for any programme that wants to survive. Conversely, having flawless due diligence pays off as a protection policy for the programme’s future. Longevity Secondly, longevity matters. Lack of experience certainly puts new programmes at a disadvantage, as formed programmes such as St. Kitts and Nevis’ or Dominica’s straightaway have years of practice and knowledge that applicants and agents can

to rely on. Naturally, those with longevity on their side have an innate unique selling point (USP) as they have had decades to hone their processes and make them as streamlined and as reliable as possible, thus being more equipped to meet clients’ expectations. New programmes can learn from experienced programmes, but they would still need to find their own USPs. Local impact Last but not least, impact on native citizens is ultimately the purpose of a CBI Programme. CS Global Partners is the first legal advisory to focus on bringing benefit to the nations offering these programmes. There is no point offering citizenship by investment if the funds generated from it do not eventually benefit native citizens. St. Kitts and Nevis, for example, recently announced that CBI has enabled it to sponsor initiatives worth US$22.6m solely on the island of Nevis. This covered areas like education, healthcare, sporting facilities and infrastructure. Dominica is an eloquent example of CBI transparency and focus on impact. The

government often provides updates on how it is using CBI funds for the betterment of Dominicans lives on the island. We are seeing how the construction of clusters of public homes all across the island are regularly announced as part of Prime Minister Roosevelt Skerrit’s 5,000-home Housing Revolution, all fully sponsored by CBI. Dominica is also building a new geothermal plant that diversifies the island’s energy mix immensely. Importantly, Dominica is reducing unemployment sustainably by creating thousands of jobs thanks to the seven real estate options under the CBI progressing on schedule, whose construction and maintenance bring stable jobs to the local communities. Prioritising the three aspects above is the recipe for success of a CBI programme, and, to some extent, also applicable to residency programmes. We are proud to be the marketing promoters of choice for three governments whose success depends directly in the three elements above, albeit naturally with their own particularities. While promoting the St Kitts and Nevis’ and Dominica’s CBI programmes worldwide, and Saint Lucia in Far East Asia, CS

Global Partners has learnt that the right balance for any citizenship or residency by investment programmes ultimately lays in finding that win-win solution that both economic and native citizens need. As for the future of the CBI industry, we are certainly witnessing an unprecedented expansion. The pool of clients is experiencing a healthy growth as the supply side of the industry is reaching a new level of maturity. We believe cooperation amongst key CBI influencers is efficient in creating more awareness, tackling concerns and opportunities with a unified and therefore more persuasive voice, and standardising processes to respond to the ever-increasing demand from applicants.

‘‘As for the future of CBI industry, we are certainly witnessing an unprecedented expansion.’’

Citizenship By Investment 15


by PRASHANT AJMERA, Ajmera Law Group - Global Investment Advisors


n the surface, India’s market for investment migration has the same fundamental conditions as China: a population of some 1.3 billion, a passport with limited mobility, a large number of HNWIs, and plenty of push factors like pollution, restrictions on individual liberty, and lack of educational opportunities. But look closer and you’ll find that India has many more obstacles – mainly cultural – that have prevented the investment migration market from flourishing to the same degree that it has in China. We’ll look at each of these limiting factors in turn but, first, some background.

A brief history of Indian emigration Migration from India to other countries around the world started in earnest more than 100 years ago. Back then, the migrants were mostly labourers recruited to work on sugar plantations in the Caribbean islands and Mauritius, railroads in Canada, and as industrial and domestic workers in South Africa, Malaysia, and Indonesia. During this period, only people with meagre means thought of migrating abroad in order to sustain their families. After India’s independence from British rule in 1947, however, this labour migration decreased dramatically. The post-independence period saw Indians leaving the country for a very different reason; that of obtaining higher education and, thereafter, settling abroad. During this period, foreign migration became a symbol of social status, and obtaining a foreign education and living abroad become aspirations that most Indians nurtured, but which very few of them could afford. The most favoured destinations were the USA and the UK. Qualified Indians

16 Citizenship By Investment

pursued higher studies in these countries and then settled into lucrative jobs. Doctors, engineers, and architects from India settled in these countries during this time. In the mid-seventies, the Gulf countries – notably the UAE, Oman, and Kuwait – were growing exponentially thanks to petrodollars. Need for advanced infrastructure development, high-tech facilities and world-class standards of living generated demand for a huge labour force; qualified professionals as well as labourers. This unprecedented growth prompted a second wave of workforce migration from India to the Middle Eastern countries. Presently the Indian diaspora is the most populous expat community in the Middle East. This era was fraught with recruitment scams and fraudsters cheating ignorant workers with false promises of a highly-paid job and a better life in exchange for huge amounts of money. Because of this, in the year 1983, the Indian government passed the Emigration Act to regulate agents recruiting manpower from India mainly to Middle Eastern countries.

In 1993, Canada introduced skilled migration. It was a highly streamlined process, paving the way for systematic skilled worker migration from India to Canada. Eventually, Australia, New Zealand, and some European countries also joined the fray. During the late ‘80s and all throughout the ‘90s, the growing IT industries and start-ups in Western countries and the Y2K problem attracted a large pool of IT professionals from India. These professionals, who received mediocre salaries in India, were highly-paid by foreign companies. Good money, cushy jobs and a high standard of living eventually prompted them to settle down with their families in these countries. This was a period of ‘brain-drain’ for India. These professionals, who received mediocre salaries in India, were highly-paid by foreign companies. Good money, cushy jobs and a high standard of living eventually prompted them to settle down with their families in these countries.

This was a period of ‘brain-drain’ for India. All this migration created a very deep stigma in the upper echelons of Indian society, who began to regard migration as something undertaken by economically deprived people only. According to them, migration was for people with lesser means so that they could earn more abroad. Interestingly, many of these wealthy people who looked down on migration had themselves migrated from villages to cities within India in search of wealth and a better life during their youth. This gives us a brief background as to how migration evolved in India. Though we are at the threshold of the year 2020, Indian HNWIs are quite slow in making a decision to immigrate abroad. Residency and citizenship by investment is a concept that still hasn’t struck a chord with many Indians.


As mentioned, not only HNWIs but a majority of Indians harbour a deeplyrooted belief that immigration is only for the economically deprived. In my 27 years of practice, I have come across a great number of people who come to consult me and start the conversation with these lines: “We are very well-to-do and not interested in moving abroad. But I am doing this (immigrating) for the sake of my children’s education and future”. Most of these people are senior executives of multinationals, owners of SMEs, or wealthy businesspersons. They enjoy a high standard of living and their net worth is in the millions of dollars.

‘‘in the next few years, India will be a significant player in the global investment migration market.’’ 2. STABLE DEMOCRACY AND GOOD STANDARD OF LIVING

India became independent in 1947, and today it is the world’s largest democracy. Though home to several religions, languages, and classes of people, it is a relatively safe country in which to live. The law and order situation is reasonably good and, though there may be unrest in a few pockets across the nation from time to time, there is peace and safety most of the time. Additionally, the Indian economy is getting stronger by the day. These factors discourage many Indian HNWIs from moving abroad unlike their counterparts in countries such as China and Russia.


In the past three or four years, we have seen a growing interest among HNWIs in various residency and citizenship programs. Unfortunately, their usual financial advisors like chartered accountants, wealth managers, and lawyers have little-to-no knowledge about any of these programs. Many HNWIs are even skeptical about the existence and authenticity of these programs and wonder if it’s an international scam. I recently met the senior partner of large and reputed client advisory firm who had no clue about investment migration and was surprised that it can be a highly beneficial investment opportunity for HNWIs.


Until recently, Indian banks and concerned government agencies had very strict and conservative rules in place that deterred Indian professionals and businesspersons from remitting money outside of India. Hence, the entire concept of investing abroad is quite novel for most Indian HNWIs. Now, with more favourable regulations, HNWIs are showing a willingness to venture into the unknown RCBI territory.


Lack of basic knowledge about RCBI and its benefits makes HNWIs less trusting of such programs. With no one to assist them and clear their doubts, they are confused regarding the value of investment migration programs as a safe and rewarding investment.


With the exception of large metros, most real estate and large financial transactions in India are carried out in a split manner to avoid taxation – around 30-35% of the real estate price is paid through bank transfer whereas 65-70% of the transaction is by cash. This creates a perennial liquidity issue for Indians who often have to struggle to show that they have the necessary financial capacity to invest abroad through official banking channels.


India does not have a nationwide social security system. Additionally, there is no credit rating system for individuals and corporates. Business is commonly conducted based on personal references. Drawing up detailed agreements and legal documents and hiring professionals to guide through the entire process is still not a common practice. In contrast, RCBI programs involve a plethora of legal documents and other formalities that can be completed only with the help of qualified and knowledgeable professionals. Many Indian HNWIs are flummoxed when they realize how many supporting documents they need to submit with their application and the other legalities they need to complete. Gathering and compiling relevant documents is an uphill task for most of them.

Citizenship By Investment 17


Indians often assume that if a wealthy person has applied for immigration, he/ she must be doing so for all the wrong reasons. In recent times, several UHNWIs have fled the country in order to escape prosecution and possible jail time and taken refuge in foreign jurisdictions through investment migration programs. The Indian media has exploited these stories extensively to generate negativity about RCBI programs, highlighting how HNWIs are taking undue advantage of these programs to avoid persecution at home and live a comfortable life elsewhere. All this undue attention has made many high profile HNWIs very cautious and secretive when they seek immigration through such schemes.


Non-payment of invoices and private investment is widespread in India. HNWIs, as a consequence, generally don’t trust foreign developers and their projects. This lack of trust – combined with the Indian mentality of investing in a foreign project where other Indians,

18 Citizenship By Investment

preferably friends or relatives, are involved – has proved to be a great disadvantage for foreign developers and their projects. There are several examples wherein many Indian-origin investors from the USA have been successful in raising millions of dollars for their debut EB-5 projects whereas some highly reputed EB-5 regional centres are still struggling to establish their presence in India.


FEMA and the regulations therein make it difficult for Indians to transfer or remit payment outside of India. Violating the law was a criminal offence in bygone years, but is now just a civil offence that can result in up to 300% penalty if money is remitted without duly following the law. The need of the hour is to work hard collectively to educate Indian HNWIs and the professionals serving them about how RCBI programs are not only about immigrating to a foreign country but much more. Though the Indian market is slow to pick up, it is my firm belief that in the next few years, India will be a significant player in the global investment migration market.

PRASHANT AJMERA Immigration Lawyer, Ajmera Law Group Global Investment Advisors Mr. Prashant Ajmera is an Indian immigration attorney (Gujarat Bar Association) with more than 25 years of experience in residency and citizenship by investment (RCBI). A Canadian citizen and an NRI since 1988, his expertise in the EB-5 investor visa of US, the Canada investor program and other such investor programmes, have gained him recognition as one of the leading lawyers in India in the field of investment-based immigration.

INDIA IS FORECAST TO SEE GREATEST RISE IN WEALTH POPULATIONS OVER THE NEXT FIVE YEARS Despite the current global economic uncertainties, The Wealth Report 2019 forecasts that the number of HNWIs (people with at least US$1 million in net assets) will exceed 20 million this year for the first time, having grown from 17.3 million in 2013 to 19.6 million in 2018. Of these, around 6.6 million will be from North America, 5.9 million from Europe and 5.8 million from Asia. By 2023, the number of dollar millionaires is forecast to reach 23.4 million – a rise of 19% from 2018. The 13th edition of the Knight Frank Research annual Wealth Report was launched in June 2019 and includes research data-led insights into global wealth distribution, prime real estate and property markets, investment outlooks and luxury spending choices. Using data from the UK-based specialist market intelligence provider GlobalData, The Wealth Report 2019 also focuses on the attitudes and concerns of the ultra-rich in the face of ever-tightening financial controls, leaving those living in countries with the greatest inequalities and more restrictive regimes to ask ‘what can I do to protect my family?’ The number of ultra-high net-worth investors (UHNWIs) in the world is expected to exceed 200,000 this year and potentially grow by 22% to reach 241,000 by 2023, compared with 167,000 in 2013 and 198,000 in 2018. Defined as individuals who have net assets of more than US$30 million, Asia is home to over

24% of UHNWIs (excluding the Middle East which accounts for a further 4%). India – which has already seen a 30% rise in the number of dollar millionaires over the past five years – is expected to lead the wealth population growth over the next five years, with a 35% increase in the number of dollar millionaires and a 39% rise in the number of UHNWIs. In UHNWI percentage growth terms, India is followed by Philippines (38%), China (35%), Indonesia (32%) and Vietnam (31%), with eight of the top ten forecast growth markets being in Asia. India’s investment preferences The Attitudes Survey found that 24% of India’s UHNWIs have property investments outside India compared with 21% last year. Indian investors are increasingly looking to invest overseas and are particularly attracted to markets that offer the highest standards of education for their children. Meanwhile, a new study released by Hurun Report India in August 2019 found that real estate is the most favoured asset for personal investment ahead of equity markets. 29% of Indian HNWIs currently invest in real estate, with 31% saying that they think their investment in real estate will grow over the next two years. The Hurun Indian Luxury Consumer Survey also revealed that the UK is the most popular overseas investment destination ahead of Singapore, Canada and the US. Under the Liberalised Remittance Scheme (LRS), India restricts the amount of money that its nationals may spend or invest overseas in certain qualified countries in any given financial year, with the Reserve


Bank currently setting the limit at US $250,000. There are no formal restrictions on how the funds may be used, but the government is reportedly concerned that some wealthy citizens are using the LRS as a means for tax avoidance. As India does not allow or recognize dual nationality, India saw a net migration of around 5,000 HNWIs last year (source: AfrAsia Bank 2019 Global Wealth Migration Review) and this is likely to continue during 2019. However, India continues to lead the BRICS nations in terms of economic growth (see page 13 chart 2), and even though year-on-year growth has slowed during Q2 2019 to 5%, confidence remains high in the Indian economy’s prospects over the next three years. From London to Bengaluru The Knight Frank City Wealth Index 2019 concluded that, despite the ongoing uncertainties regarding Brexit, London has retaken its position as the leading global wealth centre, pushing New York back into second place. The report also considered which cities would potentially come to the fore in attracting investors over the next few years. Bengaluru, India, is the clear winner, with Oxford Economics predicting that the city’s real GDP will grow by almost 60% by 2023. Flora Harley, senior analyst at Knight Frank Research, observed “the city’s broad ecosystem of innovation offers multiple opportunities for future growth, reflected in the rise of new age technology companies across sectors including artificial intelligence, food tech, fintech and robotics.”

Citizenship By Investment 19


Chart 1. Latvia Investor Visa: Total Visas Issued by CHRISTIAN HENRIK NESHEIM IMCM

Founding editor

Main Applicants


Investment Migration Insider www.imidaily.com 5,000

If Latvia’s golden visa performs as well in the second half of 2019 as it did in the first, the program will see its application volume grow by nearly 50% on the year. While Latvia issued 124 golden visas to main applicants in all of 2018, that figure for this year had reached 91 already by the end of June.

4,000 3,208

3,000 2,256


The revival’s improbable protagonists, the Vietnamese, appear to have taken a shine to Latvia, or at least to its golden visa program. In its first-half 2019 report, the country’s Office of Citizenship and Migration Affairs revealed that no less than 37% of approved investors so far this year came from Vietnam. That’s up from 0% two years ago.

20 Citizenship By Investment


2,395 1,647 541










187 91





2019 (H1)

Chart: Investment Migration Insider - Source: Latvian Ministry of the Interior

H1 2019 marks the first period in which a nationality other than Russian obtained the most golden visas. Out of the 278 visas issued to investors and their family members during the first six months of 2019, 103 went to Vietnamese nationals. Russians, traditionally the largest applicant

group by a country mile, came in second with 98 visas, while Chinese received 13.

In 2018, out of nowhere, Vietnamese main applicants and dependents received 75 residence permits. Already by the end of June this year, that number was exceeded by some 35%. Before the year is over, Vietnam may well see a 300% year-on-year increase in Latvian golden visas.

The rapid ascent of Vietnam’s presence in Latvia is remarkable. In the years between 2012 and 2017, the country accounted for exactly one golden visa in the country.

Chart 2. Latvia Investor Visa: Nationality distribution Russia


2019 (H1)




















3% 37%



5% 4%



5% < 1% 43% 8%


29% 9%






6% 3%


13% 15% 14%

Chart: Investment Migration Insider - Source: Latvian Ministry of the Interior

What explains Vietnamese investors’ sudden penchant for Latvia? One possibility is that it offers the decidedly cheapest route to Schengen-based residence permits; a €50,000 business investment is a price point well-suited to the mass affluent. Indeed, the figures for H1 2019 show that 29 out of the 30 Vietnamese main applicants chose the business investment option over the real estate and capital transfer alternatives, both of which cost €400,000.

Another impetus is no doubt Vietnam’s entering into retrogression territory for the US EB-5 program, a phenomenon that started in late 2017, coinciding with the sudden spike in interest in Latvia. One of Europe’s oldest – dating back to 2010 – Latvia’s golden visa had its heyday in the years between 2012 and 2014. Interest peaked five years ago, when Latvia approved golden visas for 2,400 main applicants and 3,200 dependents, raking in almost €900 million during the year.

Since then, however, the story of the Baltic golden visa has been one of decline, as competing programs in warmer climes – notably Portugal, Spain, and Greece – entered the fray with perhaps more interesting property markets and certainly more recognizable national brands. But it now appears as though Latvia’s luck may be turning. Reaching a nadir of a mere 119 approved investments in 2017, the program saw a cautious uptick in 2018 and is this year poised to deliver its best results since 2016.

Chart 3. Latvia Investor Visa: Total Visas Issued by Investment Type Real estate Business investment Bank deposit





2019 (H1) Total investment: €22m

2018 Total investment: €34m

2017 Total investment: €39m

2016 Total investment: €61m




2015 Total investment: €167m

2014 Total investment: €898m

2013 Total investment: €579m

Chart: Investment Migration Insider - Source: Latvian Ministry of the Interior

Citizenship By Investment 21


Director and Country Head, Henley & Partners Australia


s the distribution of global wealth undergoes its yearly ebb and flow, consistency is to be found in the places that high-net-worth individuals (HNWIs) choose to relocate and move their money to. To be sure, there are a number of global hotspots for wealth migration: Dubai, London, and New York all routinely attract thousands of migrating HNWIs every year. Even New Zealand, with its famed ‘billionaire bolt-holes’ receives ample attention for its appeal to the world’s wealthy. However, the destination that tops the charts for wealth migration over recent years is none of the above — rather, it is Australia that is pulling in the millions when it comes to mobile wealth. Of the 108,000 millionaires who migrated around the world in 2018 (up from 95,000 in 2017), 12,000 opted to relocate to Australia — representing the greatest net gain of migrating HNWIs for any country in that year — and 2,000 more than the United States, which received the next greatest gain in expat millionaires. In 2016 and 2017, Australia also topped the world charts, with a net inflow of 11,000 and 10,000 HNWIs for those years, respectively. Interest in Australia’s real estate market has mainly come from Asia, where Knight Frank has reported that 25% of ultrahigh-net worth individuals (UHNWIs) are looking to purchase property abroad in the coming year, with almost 50% of those individuals looking to buy property

22 Citizenship By Investment

in Australia. These potential buyers mostly come from China, Hong Kong, India, Malaysia, and South Korea and will inevitably have their sights trained on the country’s most popular cities: Brisbane, Melbourne, Perth, and Sydney. Part of Australia’s appeal for Asian UHNWIs is that its location makes it an ideal base for doing business in powerful Asian economies such as China, Hong Kong, Japan, South Korea, Singapore, and Vietnam. However, Australia’s desirability for the world’s wealthy is certainly not limited to its location. Understanding Australia’s massive appeal According to the AfrAsia Bank Global Wealth Migration Review, which was published in April 2019, Australia’s major appeal lies in the fact that it has a steadily

growing developed economy, a first-class healthcare system, and world-renowned scenery and beaches. Furthermore, Australia has no inheritance tax, features a skilled English-speaking population, and boasts an impeccable reputation for personal safety. In fact, the country has ranked number one in the world for women’s safety for the past two years in a row and is considered an especially safe country in which to raise children. Australia might not be home to one of the top five wealthiest cities in the world (although its wealthiest city, Sydney, does come in at number nine), but the population of HNWIs in Australia is forecast to rise by 18% over the next five years, and even among ordinary Australians, prosperity is on the rise. Over the past 10 years, Australia’s total wealth has increased by 83% (compared to just 20% growth in the US). Put differently, the average Australian is now significantly wealthier than the average US citizen. Lastly, in addition to being one of the top financial centers in the region, having a robust economy, and possessing a reputation for being one of the safest places in which to raise a family, Australia has also managed to entice the world’s wealthy by establishing the hugely successful Significant Investor Visa (SIV) for affluent individuals.

Game-changer: The Significant Investor Visa The Federal Government of Australia introduced the SIV in 2012, with the dual purpose of boosting the national economy and driving innovation. The programme essentially offers residence in exchange for an investment of AUD 5 million (approximately USD 3.5 million) over a four-year period. With this visa, successful applicants are able to carry out investment activity in Australia, travel to, enter and remain in Australia for up to four and a quarter years, bring eligible members of their family with them, and apply for a permanent Business Innovation and Investment visa (a permanent residence visa), if certain requirements are met. The distribution of investment funds is highly circumscribed by the Australian government, with at least AUD 500,000 (approximately USD 350,000) required for investment in venture capital and private equity funds, for the sake of supporting start-ups and small private companies. A further minimum of AUD 1.5 million (approximately USD 1 million) is earmarked for approved managed funds that must be invested in emerging companies listed on the Australian stock exchange, and a final ‘balancing investment’ of at least AUD 3 million (approximately USD 2.1 million) can be invested in a range of assets, including companies listed on the Australian stock exchange, Australian corporate bonds or notes, annuities, and commercial real estate. It should be noted that direct investment in residential real estate is prohibited, and even indirect investment in residential property through managed funds is tightly managed. To qualify for the SIV, prospective applicants must be nominated by an Australian state or territory government agency or the CEO of the Australian Trade and Investment Commission (Austrade). As with other residence- and citizenship-by-investment programs, applicants are required to pass

rigorous due diligence screening and have no history of involvement in business or investment activities that are of a nature not generally acceptable in Australia. Furthermore, all main applicants must be aged 18 or over at the time of application and must either be proficient in functional English or pay a second instalment of the visa application charge. Clearing up a common misunderstanding Within the highly structured suite of investment requirements for the SIV, there is some confusion about the safety of the AUD 500,000 investment in venture capital and private equity funds. Both private equity and venture capital rely on firms that invest in companies and exit through selling their investments via trade sales and initial public offerings. However, the major differences lie in the way that private equity and venture capital firms conduct business. In a nutshell, venture capital denotes the financing given to start-up companies and small businesses that have the potential to break out. The funding for this financing is usually reserved for technology, biotech, and clean energy and usually comes from wealthy investors, investment banks, and other financial institutions. The ‘venture’ aspect of this type of investment lies in the fact that three out of four start-ups fail and that the investment term is normally between 10–12 years. Private equity firms, on the other hand, buy companies from any industry. The top sectors for private equity in Australia in 2018 included: wellness and aesthetic medicine, premium food and beverages, fintech and regtech, and both industrial and B2B services. While SIV investments need to be made into mature, established companies in need of expansion capital, most such companies are already revenuegenerating. Any proceeds emanating from private equity fund investments do not

have to be re-invested into the venture capital and private equity component of the SIV, but they can be reinvested into complying funds in the balancing portion of the SIV framework. This strategy is potentially a great way to de-risk your SIV investments over the course of the provisional visa period. The bottom line is that the investment portfolio for SIV investors can be relatively controlled but advantageous. In light of this, the SIV should not be looked at simply as a requirement for residence in Australia but as a profoundly sensible overall investment strategy.

Tony Le Nevez, Director and Country Head, Henley & Partners Australia

Tony Le Nevez is Director and Country Head for Henley & Partners Australia, where he established the firm’s first office in Melbourne in January 2019. He has over 35 years’ experience in the migration services industry. Before joining Henley & Partners, Le Nevez worked for the Australian Department of Immigration in Athens, Bangkok, Canberra, and Vienna, where he was a senior policy advisor and principal migration officer. He moved to the private sector in 2006 and was Managing Director of Hamilton Watts International Migration Services and Newland Chase Australia until 2018. Le Nevez holds a Graduate Certificate in Migration Law and Practice from the University of Victoria, is a member of the Investment Migration Council and the Migration Institute of Australia, and is a registered Australian Migration Agent.

Citizenship By Investment 23



Managing Partner and Head of Southeast Asia, Henley & Partners


ore and more individuals today are identifying themselves as global citizens. They might be born in one country, raised in another, and work in yet another. For the truly wealthy, the world is their oyster and it is not uncommon for them to own real estate across the world. According to the Attitudes Survey in Knight Frank’s Wealth Report, 25% of Asian ultra-high-net-worth -individuals (UHNWIs) — defined as those with net assets of USD 30 million or more — plan to buy a home outside their country of residence by 2020, just a little higher than the global average of 22%.

In light of recent global events, all signs point to a very strong need to have a ‘Plan B’ when it concerns the safety and security of one’s family. An additional home abroad could prove to be a lifeline in the event of political and economic turmoil. It is one of

24 Citizenship By Investment

the reasons why residence- and citizenshipby-investment programmes have been steadily gaining traction in Asia. Not only do they afford wealthy individuals the opportunity to enjoy a higher quality of life, but they also provide the possibility of better education options for their children.

and the University of Coimbra is the oldest university in Portugal and one of the oldest in Europe, offering education and research programmes in nearly all fields. The university has joint programmes with some of the world’s best institutions including Harvard and MIT.

Residence-by-investment generally involves investing in a country, obtaining a residence visa for usually four to five years, and then – if the client spends enough time there, keeps their investment, and learns the local language – they can apply for citizenship if they meet the eligibility requirements.

It is no surprise that the Portugal Golden Residence Permit Programme is one of Europe’s most popular residence programmes. The programme gives successful applicants the right to live, work, and study in Portugal, as well as travel visa-free throughout Europe’s Schengen Area.

European countries are among the most popular options for alternative residence. Many of them offer residence-by-investment programmes that include compelling real estate opportunities.

The investment options include, among others: • Capital transfer of EUR 1 million into a Portuguese bank account or specifically approved investment fund

Live, work, and study in Portugal Offering old-world charm and a rich culture, Portugal enjoys good weather all year round, with warm summers and mild winters. In addition to beautiful beaches, Portugal boasts idyllic countryside vistas and delicious cuisine. It offers internationalquality healthcare and excellent schools,

• Real estate purchase with a minimum value of EUR 350,000 for the refurbishment of properties older than 30 years or in an area of urban regeneration, including the cost of renovations • Creation of a minimum of 10 new jobs in Portugal.

Travel freely across Europe with Greek residence With ancient ruins and stunning architecture, Greece’s landscape ranges from rugged mountainous peaks to postcard-perfect coastlines and sun-kissed islands, making it an attractive destination for wealthy individuals seeking alternative residence. The cost of living in Greece is relatively low and is estimated to be approximately 30% less than many other European countries. Whether soaking up the rich culture and history of Athens, exploring the stunning blue domes of Santorini, walking down the cobblestone alleyways of Mykonos, or savouring the delicious cuisine of Crete, Greece’s warm Mediterranean climate and even warmer hospitality has persuaded many global citizens to make this their second home.

Access global markets and first-class education with Cyprus residence Located at the crossroads of Europe, Asia, and Africa, the beautiful island nation of Cyprus is the third largest island in the Mediterranean and has a rich and diverse culture, with a history spanning over 9,000 years. More commonly known as the birthplace of Aphrodite, the ‘island of love’ has much to offer, from romantic ancient ruins and idyllic beaches to a vibrant and cosmopolitan lifestyle. Cyprus, with its warm, stable climate and strategic

As a member state of the EU, Greece offers its residents a number of benefits, including high levels of safety and security, excellent education opportunities, robust healthcare options, and a dependable rule of law.

The applicant’s spouse, parents, and child dependents (under 21 years of age) are also included in the residence programme for the same investment amount. The programme also offers a pathway to citizenship after seven years of residence.

For individuals looking to avoid the hassle of onerous visa applications, the Greece Golden Visa Programme is considered one of the most affordable residence-byinvestment programmes that provides not just fast-tracked residence in the country but also access to Europe. Successful applicants are able to benefit from visa-free access to Europe’s Schengen Area within two months of applying, with relatively straightforward requirements:

Additionally, there is no minimum stay requirement in the country to maintain the visa, making it easy to travel freely in and out of Greece. With the tourism boom, acquiring real estate in Greece is one of the most profitable types of investments and there are many opportunities for capital appreciation in a depressed real estate market. Like anywhere else in the world, real estate is fundamentally about location, and Greece is no different. There are several up-andcoming prime locations in Athens that are especially interesting for investors who either want to reside there themselves or to profit from holidaymakers who would pay a premium for quality accommodation in the city centre.

• Real estate purchase with a minimum value of EUR 250,000 • Proof of health insurance coverage that is valid in Greece.

geographical position, is considered an attractive place for both business and residence. It has an investor-friendly tax regime, high-quality but relatively low cost of living coupled with top medical facilities, and a low crime rate.

...a brilliant destination for education, with a wide range of private English schools and universities, giving access to Canadian, European, and American universities.

Furthermore, with an effective and transparent regulatory and legal framework, Cyprus offers international investors and businesses the confidence to invest, grow, and prosper. The country was ranked number 53 out of 190 countries on the World Bank’s Ease of Doing Business Index 2018. In line with the Cypriot government’s intention to increase foreign direct investment and to help its economic development, newly simplified regulations now enable residence permits to be issued

Citizenship By Investment 25

to applicants from non-European countries, provided that the following requirements are all met: • Real estate purchase with a minimum value of EUR 300,000 • An annual income* of a minimum of EUR 30,000 derived from abroad • Deposit of a minimum capital of EUR 30,000 from abroad into a Cyprus bank account. * Income may include salaries from employment outside of Cyprus, rents, pensions, and dividends from shares. Residence applies to the whole family including the applicant’s spouse, parents and child dependents (under 25 years of age). The whole process is highly efficient, with residence permits being issued within

two months, and can be arranged without being present in the country. However, a visit is required for biometric capturing and to obtain the actual permit upon approval. In order to maintain residence status, all that is required is a visit to Cyprus once every two years. Individuals can also apply for Cypriot citizenship through naturalization after seven years, provided that they’ve resided in Cyprus for five out of those seven years. Real estate investment is a key component of a diversified investment, and despite market fluctuations, it often proves to be a reliable option. No matter how global a citizen one might be, conducting due diligence and accessing expert advice from trusted and established firms, as well as considering all of one’s options, is key to making a sound investment decision.


Managing Partner and Head of Southeast Asia, Henley & Partners

Dominic Volek is the Managing Partner of Henley & Partners Singapore, Head Southeast Asia and a member of the Investment Migration Council. Originally from South Africa, Dominic is now based in Singapore and is responsible for the company’s operations across South and Southeast Asia, including offices in Australia, Malaysia, the Philippines, Singapore, Thailand and Vietnam. Dominic is a private client specialist in residence and citizenship planning and provides advice to high-net-worth individuals, their families, and their advisors across Asia, targeting countries that are deemed most attractive in terms of mobility, security, privacy, personal tax and estate planning, as well as lifestyle. He is also a member of the firm’s government advisory business providing strategic advice to governments on the design, implementation and promotion of investment migration programs. Dominic is a certified Chartered Accountant CA (SA), holding both a Bachelor of Commerce in Accounting with Honours and Bachelor of Arts in Corporate Communication. Prior to joining Henley & Partners, Dominic had a successful career as part of the Senior Management team in one of the big four accounting and advisory firms in Singapore, South Africa, and the US.

26 Citizenship By Investment

COUNTRY SP OTLIGHTS Discover the benefits of the various countries that offer Residency and Citizenship by Investment programmes in our Country Spotlights section. Caribbean Section: Antigua and Barbuda Dominica Grenada St. Kitts and Nevis Saint Lucia

28 31 38 41 48

European Section: Cyprus Greece Malta Montenegro Portugal Turkey UK

54 57 62 65 69 74 78

North American Section: Canada USA

80 82

Citizenship By Investment 27

Country Spotlight




ntigua and Barbuda is an island nation situated in the West Indies between the Caribbean Sea and the Atlantic Ocean, in the middle of the Leeward Islands chain. The country consists of two major islands and a small number of mostly uninhabited islands. Antigua is the largest island land, with a total land area of 281 km² and a coastline of 87 kilometres. Barbuda – land area 160 km² – lies just 25 nautical miles (40km) north of Antigua and is easily reached by the Barbuda Express catamaran service (journey time of 90 minutes in nearly all weather conditions) or a 20 minutes helicopter flight. Antigua and Barbuda’s ideal geographic positioning 17°N of the equator makes the tropical twin-island jewel a regional travel hub, with excellent air links to North America and Europe. Home to over 100,000 people and blessed with 365 powder-white sand beaches, the country is revered as one of the most beautiful places in the world. Both islands are mostly low-lying islands with natural harbours, lagoons and sandy beaches along their coastlines and rimmed by reefs and shoals. Antigua was first explored by Christopher Columbus in 1493. However, the Spanish never colonised the island due to its lack of fresh water and it wasn’t until 1632 that the British started to colonise Antigua, with Barbuda first colonised from 1678. In 1958, Antigua and Barbuda joined the short-lived Federation of the West Indies and in 1967 became one of the selfgoverning West Indies Associated States, before being granted Independence from the UK on 1 November 1981. The

28 Citizenship By Investment

country also joined the Commonwealth on that date and was granted admission to the United Nations on 11 November 1981. Antigua and Barbuda, along with seven other states, is a member of the Eastern Caribbean Currency Union (ECCU), a development of the Organization of Eastern Caribbean States (OECS), which uses the Eastern Caribbean dollar (XCD) as its currency. This has been pegged at 2.7 XCD to one United States dollar since 1976, contributing to long-term financial stability. Antigua and Barbuda’s political system is based on the British parliamentary system, with general parliamentary elections required to be held at least every five years. The House of Representatives has 19 members which comprise the President, the Speaker and 17 members elected in single-member constituencies using the first-past-the-post electoral system.

Capital city: St. John’s Population: 102,012 (2017) GDP in Current prices: USD $1.63 billion (2018) GDP growth: 5.3% (2018) Area: 440 km² Government: Unitary parliamentary constitutional monarchy Monarch: Queen Elizabeth II Governor-General: Sir Rodney Williams Prime Minister: Gaston Browne Currency: East Caribbean dollar (XCD) HDI: 70th (2018) Ease of doing business index: 112th (2018/19) Time Zone: GMT -4 Dialling code: 1 268 English is the official language, although Antiguan Creole is also spoken. Economy The economy of Antigua and Barbuda is service-based and relies heavily on tourism. Its real GDP growth has tended to fluctuate over the past three decades as the country is more vulnerable than most markets to external economic downturns and natural disasters such as hurricanes. The country suffered badly from the global recession of 2008 which brought about the collapse of its largest private sector employer, steep declines in tourism and a rise in debt. As a consequence, the government has been diversifying its economy, with financial services, communications and transportation becoming more important. Bolstered by generous government incentives for businesses and entrepreneurs, foreign investment has contributed to the recovery of the economy, especially with regard to construction and real estate. In addition, Antigua and Barbuda launched its citizenship by investment program (CIP) in October 2013, raising $33 million in its first year alone. Since 2013, the economy has enjoyed a steady return to real GDP growth, with 2017 up by 3.6% and 2018 up by 5.3% to a nominal figure of $1.626 billion (source: IMF).

Currently, Antigua and Barbuda’s economy ranks a lowly 174th in the world, but 50th in terms of GDP per capita. The Caribbean Development Bank (CDB) forecasts a more modest economic growth of 3% for 2019. Services represented 77.5% of 2017 GDP, with Industry accounting for 20.2% and Agriculture – which includes farming, fishing and forestry – contributing just 2.3%. The total contribution of Travel and Tourism to GDP in 2017 was equal to almost 52% share of GDP in 2017, of which 13% was a direct contribution. Tourism and trade After falling from 265,187 in 2016 to 247,320 in 2017 (having previously shown steady growth since 2010), the number of stayover international tourist arrivals coming in to V. C. Bird International Airport on Antigua’s northern coast rose by 8.75% to 268,949. Two-thirds of all

tourists come from the United States or the UK – 39% and 26% respectively of all visitors in 2018 – with Canada next (14%) and showing the highest year-onyear increase. Emphasizing how important the US is to Antigua and Barbuda, the net figures from 2015 to 2018 show that arrival numbers from the US grew by 10.0% while numbers from the UK declined by 9.4%. Additional figures from the Ministry of Tourism showed that a record 813,459 visitors came by sea (794,604 by cruise ship and 18,855 by yacht) during 2018, helping to raise the overall number of visitors to Antigua and Barbuda to 1,081,365 compared with 1,059,924 in 2017 and 891,427 in 2016. In each of the past few years, the country has been registering a significant trade deficit, which in 2017 was $534 million. Antigua and Barbuda imports most of its products from the United States (34.5%

share by value of 2017 imports), followed in 2017 by Poland (21.6%), China (4%) and the UK (3.7%). Most of Antigua and Barbuda’s agricultural production is focused on the domestic market and its exports are currently led by ships and boats (51% by value in 2017), iron products and refined petroleum. The country’s economy was also knocked by Hurricane Irma in September 2017, which battered Barbuda with 185 mph winds and destroyed 95% of the island’s buildings. The entire population of Barbuda was evacuated to Antigua, which fortuitously was spared by the worst of the hurricane, and it was estimated that over $200 million worth of damage had been done to homes, buildings and infrastructure. Several countries including China provided international aid to repair homes and healthcare facilities, and the foreign direct investment funds raised by the CIP since its inception have been a vital contributor to helping the country recover.

Citizenship By Investment 29

CITIZENSHIP BY INVESTMENT The ABCIP Act allows for anyone aged 18 years and above, in good health and with no criminal record, to apply for citizenship through one of historically three options. The application process is fairly rigorous and has to be done through an authorised agent licensed by the Citizenship by Investment Unit (CIU). Because of the due diligence process and depending on the complexity of the application, timelines can vary and be difficult to predict. But the benefits of acquiring citizenship in Antigua and Barbuda include low taxation, low residency requirements, no interview requirement, the opportunity to maintain dual citizenship, and visa-free access to over 125 countries. Investment options 1. National Development Fund (NDF) This is the simplest and most popular option, whereby the applicant pays a non-refundable minimum contribution of $100,000 to the NDF, which is a non-profit fund audited by an internationally recognised accounting firm and subject to parliamentary reporting every six months to allow for transparency and accountability. The main applicant can also include spouse and up to two other family members (dependent children and/or dependent parents over 58 years of age) for no extra money, other than the processing and due diligence fees which apply to every named person on the application. For a family of five or more, the minimum of required contribution is $125,000. NOTE: It should be pointed out that these prices are limited time offers in the aftermath of 2017’s Hurricane Irma and may be subject to increase after 31 October 2019.

2. Real Estate Applicants may make an investment of at least $400,000 in officially approved real estate projects. The real estate purchased must be held for at least five years unless purchasing an alternate real estate property of equal or higher value. 3. Business Investment A single applicant may make a minimum investment of $1,500,000 in a business, whether existing or proposed, that has been approved by the Antigua and Barbuda Investment Authority (ABIA). Alternatively, two or more persons may propose to make a joint investment in an approved business, in which case the total investment must be at least $5,000,000 with each individual applicant contributing at least $400,000 to qualify for applying for citizenship through an agent. 4. University of West Indies This is a new option which Prime Minister Gaston Browne announced in September 2018, intending to raise funds to finance the new campus of the University of West Indies. This requires a minimum contribution of $150,000 rather than the $100,000 NDF option, but is specifically for families of six or more members and will include one year’s tuition-free scholarship at the university for one member of the family. The processing fees and due diligence fees will be in line with the current NDF fees as below.

The National Development Fund (NDF) * Other fees payable include passport fees. These fees are subject to change. Processing fees


$25,000 for a family of up to 4 persons

$25,000 for a family of up to 4 persons with incremental payments of $15,000 for each additional dependent.






$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

Due Diligence

The Real Estate and Business Investment options

Processing fees

Contribution Due Diligence


$50,000 for a family of up to 4 persons

$50,000 for a family of up to 4 persons with incremental payments of $15,000 for each additional dependent.





$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

30 Citizenship By Investment

* All fees quoted are in US dollars (USD).

Due Diligence and passport fees *USD


Principal applicant






Dependent child aged 0-11



Dependent child aged 12-17



Dependent aged 18-25



Dependent parent aged 65 and over



Passport fee – each person



* Standard due diligence and passport fees apply ** Note: ECD = Eastern Caribbean Dollars

Country Spotlight



Full name: Commonwealth of Dominica Capital city: Roseau Population: 73,925 (2017) GDP in Current prices: USD $485 million (2018) GDP growth: -12.0% (2018) Area: 750 km² Government: Unitary parliamentary republic President: Charles Savarin Prime Minister: Roosevelt Skerrit Currency: East Caribbean dollar (XCD) HDI: 103rd (2018) Ease of doing business index: 103rd (2018/19) Time Zone: GMT -4 Dialling code: 1 767


ominica is an island nation situated in the Lesser Antilles archipelago in the eastern end of the Caribbean Sea, just a few miles from Martinique to the south and Guadeloupe to the North. The island is about 29 miles (47 km) long and 16 miles (26 km) wide. Dominica’s official name is the ‘Commonwealth of Dominica,’ which is mostly referenced in official communications and to further distinguish the island from the Dominican Republic, its northerly Caribbean sister. An inclusive island with a rich cultural makeup, Dominica offers a vibrant mix of European and African cultures and serves as the home to the Caribbean’s only remaining population of pre-Columbian Carib Indians. Dominica was also the location for filming much of the 2006 blockbuster movie ‘Pirates of the Caribbean: Dead Man’s Chest’. History Dominica was given its name by Christopher Columbus in November 1493, the name derived by the Latin for ‘Sunday’ on which day he is said to have sighted the island. However, very few Spanish settlers stayed on Dominica and it wasn’t until well into the 17th century that French settlements began to grow, attracted by the island’s natural forestry resources. Dominica formally became a French colony in 1727, but was ceded to the British by treaty after the Seven Years’ War of 1756-1763.

By 1805, the British had established a small trading colony with cotton, sugar and coffee plantations. Following the Slavery Abolition Act of 1831, Dominica became the first colony within the British West Indies to have an elected legislature assembly controlled by ethnic majority. In 1871, Dominica joined the Federal Colony of the Leeward Islands but was transferred to the British Windward islands in 1940 and later joined the West Indies Federation. However, internal politics on how the intended Caribbean state should be governed led to its dissolution on 31 May 1962 and Dominica formally became an associated state of the UK in 1967. Dominica gained its national independence as a republic on 3rd November 1978 and joined the Commonwealth of Nations on the same day. Dominica has since flourished as a democracy which is patterned after the British parliamentary system.

The president is the head of state, elected by the House of Assembly for a five-year term. The president appoints the prime minister, an elected member of the House of Assembly who commands the support of the majority of its elected members. Although English is Dominica’s official language and widely used, Dominica has been a member of the International Organisation of the Francophonie since 1979, as the majority of locals speak Dominican Creole which is based on French. Dominica is a beneficiary of the Caribbean Basin Initiative that grants duty-free entry for many goods into the USA, and is also a member of CARICOM and the Organisation of Eastern Caribbean States (OECS). An eco-tourism paradise The climate is tropical and the terrain spectacular. Its breathtaking landscape reveals rainforests, waterfalls and over 360 rivers. The Morne Trois Pitons Natural Park (meaning ‘Mountain of three peaks’) is in the southern central highlands of the island and encompasses five volcanoes, three freshwater lakes and several fumaroles and hot springs, including the world’s second-largest hot spring at Boiling Lake, where its renowned healing properties are considered legendary. The park was

Citizenship By Investment 31

designated a UNESCO Heritage site in 1997, being the first in the Eastern Caribbean. Dominica is affectionately known as “The Nature Island of the Caribbean” as citizens of Dominica share their home with many rare species of exotic flora and fauna. The rugged terrain offers adventurous visitors the chance to canyon, bike or swing from new heights. For those with a love of nature, Dominica is the perfect birdwatching destination. Additionally, the botanical gardens are home to the Sisserou Parrot, which is the country’s national bird and is featured on the national flag. Looking out onto the Caribbean Sea, the mountainous green slopes are dotted with exotic tropical flowers, banana plantations and coconut trees. Dominica is also known for its spectacular reefs which visitors can explore while diving or snorkelling. Keen divers should certainly visit the signature Champagne Reef. For the less active visitor, there is the always the option to join a boating tour. From a catamaran, visitors can enjoy whale and dolphin watching. Economy and trade Historically, Dominica’s economy had been dependent on agriculture but increasingly it has turned towards offshore financial services and eco-tourism. Services currently account for approximately 71% of GDP compared with 16% by agriculture and 13% by industry. Dominica’s main exports are agricultural and include coffee, cocoa, bananas, citrus fruits, and tropical fruits. Its main exported manufactured products are rum, timber, and soap. However, the economy is highly vulnerable to weather conditions and the last two years have seen a significant decline in real GDP after Hurricane Maria struck the island in September 2017 and wreaked over $900 million worth of havoc. Citizenship by Investment The government launched its Citizenship by Investment programme in 1993 – one of the first countries to do so – and has raised over $300 million in revenue, becoming the main source of foreign direct investment (FDI) into Dominica. The investment funds have helped Dominica to rebuild its infrastructure and build climate resilient housing to help its local communities better manage and overcome adverse weather conditions.

32 Citizenship By Investment

Benefits Dominica’s is one of the most affordable citizenship programmes and has fast processing times of between four to six months, with no interview requirement to visit the country. A Dominican passport allows visa-free travel to over 130 countries including Singapore, Hong Kong, the UK and the European Schengen countries. Dominica allows dual nationality and citizenship is for life and may be passed on to future generations by descent. Citizenship also comes with free movement of capital, dividends and profits made outside of the island, and no tax on wealth, gifts, inheritance, foreign income, or capital gains tax, and no personal income tax for residents. Applicants must be at least 18 years of age, with good health and a clean criminal record. Family members may be included and applications must be made through an authorised agent rather than directly with the Citizenship by Investment Unit (CBIU). Investment options

financing under the Programme include the building of schools, a national sports stadium, renovation of the hospital, and promotion of the offshore sector. With respect to private sector projects, government emphasis is on the tourism, information technology and agricultural sectors. Since 2016, the Citizenship by Investment programme has been described as an economic and fiscal lifeline, particularly following Hurricane Marie.

• US$50,000 for a family up to 6 persons, including the main applicant

To qualify for citizenship under this investment option, there are four investment categories with different minimum contribution amounts, based on the number of dependents included in the application, which are as follows:

Given that the application procedure under this option entails the purchase of real estate, this may extend the processing time, which is subject to the chosen property.

• Single applicant: a non-refundable contribution of US$100,000 is required

The following fees are also payable on application:

• Main applicant and spouse: a nonrefundable contribution of US$175,000 is required • Additional qualifying dependants US$25,000

Dominica offers two options for applying for citizenship in return for a qualifying investment, which can be either a donation to Dominica’s Economic Diversification Fund, or the purchase of pre-approved real estate.

2. Real estate

1. Economic Diversification Fund

Following approval of a real estate investment application, the following government fees are payable:

The Economic Diversification Fund (EDF) was established through the Citizenship by Investment Programme as one component of a national capital mobilisation portfolio towards an ultimate goal of national development for Dominica. Generated funds are utilised for public and private sector projects where a need is identified. Public sector projects identified for

To qualify for citizenship of Dominica under the real estate option, an applicant must purchase authorised real estate to the minimum value of US$200,000.

• US$25,000 for a single applicant • US$35,000 for a main applicant and spouse • US$35,000 for a family up to 4 persons, including the main applicant

• US$70,000 for a family of 7 or more. In order to qualify for citizenship, you must hold authorised real estate for three years from the grant of citizenship. You may only re-sell that real estate under the Citizenship by Investment Programme after five years.

Applicable Fees

Processing fees US$1,000 per application Due diligence fees Main applicant – US$7,500 Spouse – US$4,000 Dependant aged 16 years or above – US$4,000 (In some cases, an enhanced due diligence may be required, depending on the citizenship the applicant holds and other personal circumstances.) Other fees Certificate of Naturalisation Fee – US$250 per person Expedited Passport Issuance Fee – US$1,200 per person

Citizenship By Investment 33

CARIBBEAN SPOTLIGHT: DOMINICA CBI REAL ESTATE IS SELLING OUT FAST by CS GLOBAL PARTNERS Dominica’s real estate market has been enjoying an ecotourism boom and the island’s commitment to environmentally sensitive developments has not gone unnoticed by potential investors. With a growing list of eco-friendly resorts debuting on the island, the real estate

route under Dominica’s Citizenship by Investment (CBI) Programme continues to prosper, leaving investors spoilt for choice when it comes to reliable opportunities. There are currently seven real estate options available under the Dominican Programme, with some already sold out.

Anichi Resort & Spa (Marriott) – Opens in 2019

Cabrits Resort (Kempinski) – Opens in 2019

Anichi Resort & Spa is backed by the largest hotel company in the world, Marriott International, and will operate under its exclusive Autograph Collection. It is currently under construction with progress being made swiftly by developers. With 128 rooms anticipated on completion, the resort is already being praised for its modern architecture and its commitment to showcasing the Dominican culture. Investors can buy redeemable shares of freehold suites that qualify under Dominica’s CBI Programme.

Part of Europe’s oldest hotel group, Cabrits Resort Kempinski Dominica is one of the first big-branded projects to debut on the island. It is opening its doors on October 14th and already taking bookings. However, the resort’s shares under the CBI Programme have already completely sold out, demonstrating the trust that investors have in Dominica’s real estate. The hotel will comprise 151 rooms with world-class amenities, including a full-service spa, modern fitness facilities, tennis courts and spaces for meetings and weddings.

Bois Cotlette - Open

Jungle Bay - Open

A revamped and repurposed estate from the 1700s, Bois Cotlette is different from the other properties on this list. It is one of the oldest surviving estates in Dominica and thus presents a unique experience that investors are not likely to find elsewhere on the island. The property is also completely self-sufficient, with food, water and energy sourced from the premises. Those interested in the estate must sign a reservation agreement and pay a deposit of $11,000, deductible from the purchase price.

Jungle Bay is a veteran in Dominica’s hospitality offering after operating for over a decade and receiving global recognition. The resort went under renovation and expansion following Hurricane Maria. It has also relocated to another coast and has officially opened in June. Its exceptional wellness services are to be envied and its VIP list of visitors even more so. The villas offer private ownership under Dominica’s CBI Programme.

34 Citizenship By Investment

Sanctuary Rainforest Eco Resort and Spa - Newest

Secret Bay - Open

The latest addition to Dominica’s hotel roster, the Sanctuary Rainforest Eco Resort and Spa is situated within the rainforest of Providence Estate, located closely to Dominica’s popular Morne Trois Pitons National Park – a UNESCO World Heritage Site. Investors can buy shares and receive annual dividends according to the resort’s profits. After five years, the holder can resell preferred shares and still retain citizenship. The 72 luxury villa units will accentuate its natural surroundings while offering visitors a luxury experience.

Secret Bay is one of Dominica’s most prized resorts and has enjoyed international popularity for several years. Similar to Jungle Bay, the resort closed after Hurricane Maria and decided to expand, reopening its doors in late 2018. Secret Bay is one of the developments that offer CBI applicants completed villas available for investment. It has a demonstrated rental demand and a competitive exit strategy. Besides the six villas that are already in operation, The Residences at Secret Bay will comprise a total of 42 units well-hidden across 33 acres of coastal rainforest.

Tranquility Beach (Hilton) – Opens in 2021 Tranquility Beach is amongst Dominica’s growing list of branded developments with the world-renowned Hilton adding the resort to its Curio Collection. Offering 73 rooms in total, the fully serviced premium vacation villas and residences are custom-designed and offer simplicity and luxury at their best. Like other upcoming resorts, Tranquility Beach is committed to its eco-conscious ethos, its breathtaking villas hanging off dramatic cliff edges overlooking the Caribbean Sea. Investors can purchase undivided shares within the development. Owned by native Dominican Ian Edwards, the resort is expected to be completed in 2021.

Since 1993, the Commonwealth of Dominica has been successfully operating one of the world’s oldest CBI programmes. With over 25 years of experience within the industry, Dominica has been internationally hailed as offering the best CBI programme in the world for the last two years running. Experts at the Financial Times’ Professional Wealth Management magazine have particularly highlighted the programme’s affordability, efficiency and its exemplary due diligence procedures. Dominica’s CBI Programme has stood the test of time as a reliable investment into one’s future, as its reputation and integrity speak for themselves. There are two channels of investment available under

Dominica’s Programme. The first route involves buying into any of the aforementioned real estate options, worth at least US$200,000. The second path is through a contribution to the government’s Economic Diversification Fund (EDF). This requires a minimum investment of US$100,000, representing one of the most affordable options on the market. The EDF contributes substantially to Dominica’s socio-economic advancement, with the government taking a very transparent approach as to its CBI fund usage. Whichever option applicants chose under Dominica’s CBI Programme, they can rest assured that their investment is going towards the real betterment of their adoptive nation.

Citizenship By Investment 35


w w w.remax -g re na da . co m 36 Citizenship By Investment

After 25 years of loyal, dedicated and unyielding service to the nation of Grenada, RE/MAX has become not only a staple, but also a household name. RE/MAX Grenada was founded by Hyacinth McBarnette; one of the most experienced and decorated real estate agents in the Caribbean. Her many achievements and awards include the coveted RE/MAX Hall of Fame, as well as the Lifetime Achievement Award. Mrs. McBarnette is a longstanding member of the Royal Institute of Chartered Surveyors (RICS) and also holds a B.Sc. (Hons) degree in Building Surveying from the University of Reading, England. We at RE/MAX Grenada would like to use this opportunity to thank you all: our clients, colleagues, friends and the many RE/MAX Brokerages that assist us. You have all touched our lives in a special way. Without your trust and confidence; you - the person with an inquiry and you - the one taking the time to read this, we would not be here today. We cannot express enough gratitude for your relentless support.

Being the founder of RE/MAX Grenada must be a huge undertaking; can you share a bit about yourself outside of the office? I believe that the people who know me consider me to be trustworthy, responsible, principled, and dedicated to achieving excellence in what I do. My hobbies include plant collecting, landscaping, travelling and I enjoy a good game of chess. It is an arduous and perpetual journey trying to find a way to get everything done, while maintaining some kind of balance in my life. I enjoy walking and practicing yoga for that clarity. Photography is another passion of mine. I have been developing my work with 360 cameras and droning, some of which you may see on www.remax-grenada.com The Caribbean is a beautiful place. Why invest in Grenada? From an economic viewpoint, over the past few decades, Grenada has proven

to possess the ability to remain relatively stable, with a tendency toward growth in the more recent years. We have had low inflation, low crime rates, low tax rates on labour and the minimum wage is competitive, compared to our regional counterparts. The political climate is stable and our exchange rate has been consistent. You can see the progress and potential in various sectors including construction, agriculture and (as we commonly say) “Tourism is everybody’s business”. The infrastructures in most places are prepared for development and the country is well equipped for the import of any material not readily available. What about Grenada makes it the ideal destination for citizenship? The list is endless. The peaceful lifestyle enjoyed here, with such natural exotic fauna and vistas, is only the beginning. Grenada is the kind of country where you can arrive alone and leave with an entirely new, warm and loving family, regardless of where you are in the island. It’s a great location for vacation, while falling in love with our culture (as many of our friends here have before joining us as locals). Enjoy various excursions on a cruise, to settle down, retire, or even simply own a vacation property, all in the gorgeous safety and comfort of paradise. Have you heard of Grand Anse Beach? You never experience it the same way twice. Truly one of the wonders of the world! The isle of spice demonstrates its namesake essentially in everything that we do. Especially through our food (it’s hard to resist a well-prepared Oil Down) and our

music. You can even smell the spice in the air when you land as you first step off of the plane. Why should investors choose RE/MAX Grenada? First, it would be the knowledge and experience of our team. In the real estate market, we are unmatched! We are well qualified in terms of capability and skill to undertake the services we offer. Through the RE/MAX University’s annual Conventions and routine Training Seminars, we thrive on keeping ourselves up-to-date, all in the interest of offering the highest quality of marketing skills and services to our clients. In addition to our general real estate services, we are able to offer specialist features such as: • Assisting our clients in buying property with their retirement money. This service benefits citizens of the USA through the IRA Program • We have been certified to market luxury, commercial and residential properties • The RE/MAX Network has made available a number of exclusive marketing websites, such as the RE/MAX Global website and REMAX-CaribbeanIslands. com. This is in addition to the reserve positions for the marketing of exclusives listings on media like the Wall Street Journal, DuPont Registry and Unique Homes to name a few • The acquisition and promotion of CBI (Citizenship by Investment) property listings.

Can you tell us more about Grenada’s CBI programme? Gladly! The reference numbers RG 4014 and CG 4011 on our remax-grenada.com website are two great examples of resort projects through which any clients may obtain citizenship. It is meant to be effectively as straightforward as it sounds. Launched in 2013, by the Government of Grenada, the Grenada CBI program allows eligible participants to invest in either approved real estate developments or into a government infrastructure fund. Both investment programs are designed to improve the country’s economy, create opportunities for Grenadian citizens, expand and revitalize the tourism, manufacturing and agriculture sectors. The extra-incentive for the qualified investors and their family members is receiving Grenadian citizenship and passports within three months from submission of accurate and complete applications. The minimum investment amount (excluding legal, due diligence, government and processing fees) is US$350,000. With an investment in the National Transformation Fund (Section 10) approved, applicants can obtain permanent residency and citizenship within three months from submission of accurate and complete applications. The donation amount (excluding legal, due diligence, government and processing fees) is US$200,000.

Citizenship By Investment 37

Country Spotlight




renada is located in the West Indies at the southern end of the Grenadines group of islands in the Caribbean Sea. The country consists of the main island of Grenada plus the two smaller islands of Carriacou and Petite Martinique, which became a dependency of Grenada in February 1974. The picturesque tropical islands offer the perfect getaway destination for both adventure lovers and those seeking rest and relaxation or a romantic break with a partner.

The islands are of volcanic origin with extremely rich soil. Their natural beauty remains largely untouched by industrialisation. With its lush, fertile landscapes and award-winning white sandy beaches and invitingly clear waters, Grenada has the perfect balance, and visitors may find themselves wishing that they could extend their stay. Before the arrival of Europeans, Grenada was inhabited by the indigenous Arawaks and the Island Caribs. Christopher Columbus sighted Grenada in 1498 on his third voyage of discovery to the Americas, but there is no evidence to suggest the Spanish ever settled there. Grenada became a French colony from 1649 until it was formally ceded to the British in 1763. The country achieved its full independence from the UK on 7 February 1974 but has remained a member of the Commonwealth. Its official language is English.

38 Citizenship By Investment

Grenada’s islands feature some of the most diverse terrain in the Caribbean, from crater lakes and verdant rainforests to sun-kissed swaths of beach and unspoiled underwater ecosystems. Almost one quarter of Grenada is preserved as national parks or wildlife sanctuaries. Nature trails criss-cross the terrain, offering visitors and locals alike the chance to drink in the spectacular views of mangrove-fringed coastlines and experience the islands’ splendid array of fruits, spices, and tropical plant life. Economy and trade Grenada has a largely tourism-based, small, open economy, which has gradually shifted from agriculture to services. Since 2008, the Services sector has grown from 69% share of GDP to 77%, while Industry has dipped from 20% to 14% and Agriculture from 11% to 9%. The country was badly

Capital city: St. George’s Population: 107,825 (2017) GDP in Current prices: USD $1.19 billion (2018) GDP growth: 4.8% (2018) Area: 340 km² Government: Unitary parliamentary constitutional monarchy Monarch: Queen Elizabeth II Governor-General: Cécile La Grenade Prime Minister: Keith Mitchell Currency: East Caribbean dollar (XCD) HDI: 75th (2018) Ease of doing business index: 147th (2018/19) Time Zone: GMT -4 Dialling code: 1 473

hit by two devastating hurricanes in 2004 and 2005 and again in 2009 by the global recession, but since 2013 the economy has been growing at an average rate of 5% a year. With 5.1% real GDP growth in 2017 and an estimated 4.8% in 2018, Grenada is currently one of the fastest growing economies in the Caribbean. Manufacturing industries in Grenada operate mostly on a small scale, including production of beverages and other foodstuffs, textiles, and the assembly of electronic components for export. The Grenada Chocolate Company has pioneered the cultivation of organic cocoa, which is also processed into finished bars. Since 2014, Grenada has been hosting an annual Pure Chocolate Festival, which takes place around the end of May. The country’s principal export crops are nutmeg and mace, with nutmeg represented

on the national flag. Grenada is the world’s second largest producer of nutmeg and provides roughly 20% of the world supply. Grenada is known as the “Island of Spice” as it is reputed that travellers can taste a faint flavour in the air. Spices aren’t the only natural bounty that Grenada shares with its guests; cocoa beans, bananas, avocados, cloves and cinnamon are also grown in abundance throughout the islands. The Grenada Carnival, which takes place every summer, culminates in two official days of ‘Spicemas’ on the second Monday and Tuesday of August to the sound and pageantry of the local Jab Jab music. Tourism Large-scale tourism is a recent phenomenon, and Grenada is largely undiscovered, unspoilt and full of opportunity. 2018 saw a 12.9% increase in tourist arrivals with 528,077 visitors; of these, 160,790 (30.4%) were stayover visitors compared with 146,375 in 2017. Beach and watersports tourism is largely focused in the southwest region around St George’s, the airport and the coastal strip. The Grand Anse beach in St. George’s is regarded as one of the 10 most beautiful beaches in the world. Ecotourism is also growing in significance. Most small eco-friendly guesthouses are located in the Saint David and Saint John parishes. Well-preserved places of interest abound in Grenada. In the lovely capital of St. George’s, pastel buildings and red-tiled roofs show off the city’s strong Caribbean identity, while historic English and French architecture also hints at the culture’s

rich heritage of European influence. Fort George, a garrison that has overlooked the capital’s harbour for more than 300 years, is open to the public for tours. In addition, the Saturday market offers locals and tourists alike the opportunity to explore local produce, spices and crafts in a centuries-old tradition. The St. George’s University has expanded rapidly in recent years and specialises in medicine, veterinary medicine, public health sciences, nursing and business degrees. It has become one of the island’s biggest employers and attracts many international graduate and undergraduate students. The island’s airport, the Maurice Bishop International Airport, is situated at the most south-western point of the island, some 8 kilometres from St. George’s. From here you can get connecting flights to the USA, Toronto and London as well as to other Caribbean islands. There is also a fast ferry service between St. George’s and Hillsborough on the island of Carriacou, famous for its white sand beaches, natural harbours and coral reefs and home of the annual Carriacou Regatta Festival. Citizenship by Investment The Grenada Citizenship by Investment Committee (CIBC) is the main governmentappointed body responsible for overseeing the processing of applications for Grenadian citizenship by investment. The Committee assesses applications in accordance with the Grenada Citizenship by Investment Act, after which recommendations are made to the Minister, who makes the final decision to deny, approve or delay granting Grenadian citizenship. The Citizenship by Investment Programme came into being in

August 2013. Subject to strict due diligence procedures, applicants may choose between these two types of investments to obtain citizenship or permanent residence: 1. A payment into the National Transformation Fund; or 2. A payment towards an approved real estate project in Grenada. Benefits Individuals who obtain citizenship through Grenada’s Citizenship by Investment Programme are entitled to the same rights as any other Grenadian citizen. These include the right to live and work in Grenada at all times, and all the rights associated with membership of the Caribbean Community (CARICOM). There is no requirement to reside in Grenada before or after citizenship is granted. The application process is confidential, with no disclosure or exchange of information with other governments or bodies, except when due diligence checks are carried out as part of the application process by an authorised due diligence agency. Grenada allows individuals to hold dual citizenship, and citizenship may be extended to family members. Following changes announced in March 2019, dependent children are defined as up to the age of 30 (previously 26), and dependent parents or grandparents aged 55+ are also included. Children and young adults may obtain preferred access, and in some cases grants, to top schools and universities.

Citizenship By Investment 39

Grenada has no foreign income, wealth, gift, inheritance, or capital gains tax. There is no restriction on the repatriation of profits and imported capital. Generous incentive packages exist including corporate tax incentives, full exemption from import duties, tax relief benefits, and export allowance. Grenada’s currency, the East Caribbean dollar (XCD), is pegged to the US dollar (USD).

Grenada is one of very few nations whose citizens can travel to the People’s Republic of China without first obtaining a visa. Grenadian citizens also have the opportunity to apply for the USA E-2 visa. Grenada is one of the few countries to have an E-2 visa treaty of commerce arrangement with the United States.

Grenadian citizens can travel without visa restrictions to more than 115 countries. These include the UK and all other members of the EU, and important business hubs such as Singapore and Hong Kong.

1. The NFT option

Under the NTF route, applicants may either immediately apply for citizenship, or first apply for permanent residence and apply for citizenship at a later stage.

The National Transformation Fund (NTF) is a government fund responsible for financing projects that will benefit Grenada’s

Applicants opting for the NTF route must contribute at least USD $150,000 to the Fund, plus fees, as per the following table:

Options and costs

economy and help its diversification. Applicants who choose this route must make a one-time contribution to the NTF. It is important to note that applicants may not contribute to the NTF in person, but rather must use the services of an Authorised Local Agent.


Individual Application

Main Applicant + Spouse

Family of four members

Family of over four members

Required Contribution Amount

USD 150,000

USD 200,000

USD 200,000

USD 200,000 plus USD 25,000 per additional dependant after the third dependant

Application Fee

USD 1,500

USD 1,500 per person

USD 1,500 per person

USD 1,500 per person

Due Diligence Fee

USD 5,000

USD 5,000 per person

Dependant child 0-16 nil Dependant 17+ USD 5,000

Processing Fee

USD 1,500

USD 1,500 per person

USD 1,500 per person aged 17+ USD 500 for persons under 17

2. The Real Estate Project options Following the changes to the Grenada Citizenship by Investment Programme in March 2019, there are now two real estate options: 1. Joint investment in pre-approved tourism accommodation of USD $220,000

2. Independent investment in pre-approved real estate of USD $400,000 Applicants who choose to go the real estate route must make their investment through an authorised local agent. The CIBC reviews viable projects and recommends them to the Minister who then decides whether or not to approve

them. A list of approved projects for citizenship investment can be found on www.cbi.gov.gd and currently includes luxury hotels, resorts and villas. In both real estate options, the investments must be maintained for at least three years from the date on which citizenship is granted. The additional fees for the Real Estate options are currently as follows, subject to confirmation:


Individual Application

Minimum contribution

USD 220,000 (joint) or USD 220,000 USD 400,000 or USD 400,000

Government Fee

USD 50,000

Application Fee

USD 1,500

USD 1,500 per person

USD 1,500 per person

Due Diligence Fee

USD 5,000

USD 5,000 per person

Dependant child 0-16 nil Dependants age 17+ USD 5,000

Precessing Fee

USD 1,500

USD 1,500 per person

USD 1,500 per dependant aged 17+, USD 500 for persons under 17

40 Citizenship By Investment

Main Applicant + Spouse

USD 1,500 per person aged 17+ USD 500 for persons under 17

USD 50,000

Family of four members

Family of over four members

USD 220,000 or USD 400,000

USD 220,000 or USD 400,000

USD 50,000

USD 50,000 plus USD 25,000 per additional dependant after the third dependant USD 1,500 per person

USD 1,500 per dependant aged 17+ USD 500 for persons under 17



www.csglobalpartners.com LONDON â&#x20AC;¢ ZURICH â&#x20AC;¢ HONG KONG â&#x20AC;¢ BEIJING â&#x20AC;¢ DUBAI â&#x20AC;¢ NEW DELHI â&#x20AC;¢ WINDHOEK â&#x20AC;¢ ST KITTS & NEVIS â&#x20AC;¢ SINGAPORE

St Kitts and Nevis is the youngest nation in the Americas, and yet it is famed for its growing tourism industry and international business platforms. Where else can you find four worldclass golf courses overlooking the Caribbean Sea? PRIME MINIST ER OF THE FED ERATION OF ST KIT T S AND NEVIS

“As the pioneer of citizenship by investment, St Kitts and Nevis is committed to the highest level of due diligence and efficiency in the running of its Citizenship by Investment Programme. The reputation of our Programme is matched by the strength of our economic growth and the beauty of our country. In St Kitts and Nevis, we seek to invite only the discerning investor to come to our country.”


Citizenship within 3-4 months of application submission, or guaranteed processing in 60 days under the Accelerated Application Process

No interview, residence, education, or business experience requirement

Exciting business opportunities in a country with an impressive GDP growth

Visa-free and visa-on-arrival access to over 150 countries and territories worldwide Learn more on the offcial website:





The St Kitts and Nevis Programme is the most well-established in the world, as it has been running for 35 years. This ensures applicants feel certain of the programme: one that has awarded lifetime citizenship in return for an investment in the future of the nation. Today, St Kitts and Nevis offers the â&#x20AC;&#x2DC;Platinum Standardâ&#x20AC;&#x2122; of CBI, meaning responsiveness, effectiveness, and discretion in all processes. Applicants can benefit from the Accelerated Application Process, an exclusive service that accommodates applicants with fast-paced lifestyles by ensuring that their application, if successful, will be processed in 60 days or less.

SU STAIN A B L E G ROWTH F UND (S G F ) The SUSTAINABLE GROWTH FUND (SGF) is the most straightforward, streamlined and fastest path to second citizenship, with an investment threshold of USD 150,000 for a single applicant. The SGF channels resources to priority areas like education, healthcare, infrastructure and tourism in St Kitts and Nevis.

Dominica welcomes people around the world to join our global community. Those looking for strong investment opportunities in an international network that stretches well beyond this small Caribbean island are invited to apply for citizenship. A Dominican citizenship is the fast track to opportunity in a country that prides itself on being resilient, courageous and open to new P R IM E M IN ISTER OF T H E COMMO N W E A LT H OF D OMI NI CA

ideas that will tackle global issues, all the while embodying a strong sense of community as a global family.

“We are a nation deeply rooted in community values and a mindset of reciprocity. For this reason, we invite individuals and families from around the world to invest in our country, and in exchange we promise to provide you with citizenship of the Commonwealth of Dominica – a status that comes with a myriad of opportunities aimed to transcend borders in a continually globalising world.”


Untapped business opportunities in a growing economy and stable democracy

Seamless processing leading to citizenship in 3 months from submission of application

No interview, residence, education, or business experience requirement

Visa-free travel to approximately 140 countries and territories


Learn more on the offcial website: www.cbiu.gov.dm



When looking for a solution for second citizenship, Dominica ticks all the right boxes. It has a widely respected Citizenship by Investment Programme, with a reputation for integrity. The Programme is known for its efficiency, while continuing to ensure the highest standards of due diligence. For the second consecutive year, the programme has been ranked number one in the world in the CBI Index – a comprehensive study into economic citizenship, published by the Financial Times’ Professional Wealth Management magazine. Busy investors need not travel or reside in Dominica, as applications can be submitted abroad through an Authorised Agent. There are two paths to achieve economic citizenship in the Commonwealth of Dominica.

OPTION 1: The first option is a non-refundable contribution to the ECONOMIC DIVERSIFICATION FUND (EDF), starting from USD 100,000. This option allows an applicant to play a major role in Dominica’s promising future.

OPTION 2: The second option to obtain Dominican citizenship is to invest in PRE-APPROVED REAL ESTATE, starting from a minimum investment of USD 200,000. This option provides an investor with the opportunity to become a proud owner of prime real estate. There are a number of high quality projects available for investment with trusted global brands.


St Lucia

When opting to be a citizen of St Lucia, we are not just offering citizenship, but rather an identity - our people and our place in the world. It is one thing to have a beautiful country with picturesque landscape but it is also the people that inhabit this land that make the vital difference. St Lucia’s motto captures all of our combined treasures - the land, the people, the light.


Citizenship for life, including the right to work, reside and study in St Lucia

No interview or language proficiency requirements

Visa-free travel to approximately 140 countries and territories

St Lucia allows dual citizenship

Ability to include family members on the application

Option to invest in the St Lucia National Economic Fund, in a government approved real estate or enterprise project, or interest-free government bonds Learn more on the official website: www.cipsaintlucia.com



St Lucia is a strong player in the Caribbean’s tourism market and is among the region’s most famous destinations, particularly for honeymooners. The industry is bolstered by direct flights to Europe and the Americas, and numerous visa-free agreements to match demand for overnight stays. The island’s workforce – youthful, energetic and welleducated – has propelled St Lucia into new, less traditional industries, including technology and financial services. There are four paths to achieve economic citizenship in St Lucia.

OPTION 1: The first option is a non-refundable contribution to the NATIONAL ECONOMIC FUND (NEF), starting from USD 100,000. It is the most efficient option to obtain citizenship.

OPTION 2: The second option to obtain the St Lucia citizenship is to invest in an APPROVED REAL ESTATE PROJECT, starting from USD 300,000.

OPTION 3: Citizenship by investment may also be achieved through the purchase of non-interest-bearing GOVERNMENT BONDS for a minimum investment of USD 500,000. These bonds must be registered and remain in the name of the applicant for a five-year holding period.

OPTION 4: The fourth option is to invest in an APPROVED ENTERPRISE PROJECT, starting from a minimum investment of USD 3,500,000.


www.csglobalpartners.com LONDON â&#x20AC;¢ ZURICH â&#x20AC;¢ HONG KONG â&#x20AC;¢ BEIJING â&#x20AC;¢ DUBAI â&#x20AC;¢ NEW DELHI â&#x20AC;¢ WINDHOEK â&#x20AC;¢ ST KITTS & NEVIS â&#x20AC;¢ SINGAPORE

Country Spotlight



Capital city: Basseterre Population: 55,345 (2017) GDP in Current prices: USD $1.02 billion (2018) GDP growth: 3.0% (2018) Area: 261 km² Government: Federal parliamentary constitutional monarchy Monarch: Queen Elizabeth II Governor-General: Sir S.W. Tapley Seaton Prime Minister: Timothy Harris Currency: East Caribbean dollar (XCD) HDI: 72nd (2018) Ease of doing business index: 140th (2018/19) Time Zone: GMT -4 Dialling code: 1 869


aint Kitts and Nevis, also known as the Federation of Saint Christopher and Nevis, is an island state in the West Indies and a member of the Commonwealth. Part of the Leeward Islands chain of the Lesser Antilles, it is the smallest sovereign state in the Western Hemisphere, in area and population. The capital city, Basseterre, is on the larger island of Saint Kitts. The smaller island of Nevis lies approximately 3km southeast of Saint Kitts across a shallow channel called “The Narrows”. English is the official language but Saint Kitts Creole is also widely spoken. St. Kitts was named “Liamuiga”, meaning “fertile land”, by its original native inhabitants the Kalinago Caribs. The name was preserved when the tallest peak on St. Kitts was renamed Mount Liamuiga on the day of gaining independence in 1983. Christopher Columbus sighted what is now Nevis in 1493 and gave that island the name San Martín. The current name “Nevis” is derived from a Spanish name Nuestra Señora de las Nieves, meaning Our Lady of the Snows, perhaps in reference to the white clouds which usually wreathe the top of Nevis Peak. Geography The islands are of volcanic origin, with large scenic central peaks covered in tropical rainforest. There are numerous rivers descending from the mountains to empty, white-sand beaches. Beds of offshore coral, teem with fish of every

stripe and colour. Although they are only 3km apart, St. Kitts is classified as having a tropical savanna climate whereas Nevis has a tropical monsoon climate. With the beautiful nature there is a lengthy and rich cultural history. Brimstone Hill Fortress National Park, dating from 1690, is a UNESCO world heritage site that has been dubbed the “Gibraltar of the West Indies”. Tourists can see where tobacco, indigo and then sugar were grown on the historic plantations, take sweaty rainforest hikes, or relax on the sandy, palm fringed beaches. The sugar industry survived until 2005, and a unique legacy of this is the St. Kitts Scenic Railway where passengers can ride for 29km along a narrow gauge line built to transport cane. Today the island lives by tourism, a transformation that appears to have been achieved with record speed. St. Kitts now

welcomes a steady stream of cruise ships and has a 394-room Marriott resort and casino. Major luxury property developments are taking shape and a private jet terminal and superyacht marina recently opened. It is also known for a number of celebrations including Carnival (December-January) and the St. Kitts Music Festival (June). Economy At the turn of the 18th century, St. Kitts was the richest British colony per capita in the Caribbean, a result of the sugar trade. The economy had traditionally almost exclusively depended on the growing and processing of sugar cane until the late 1970s, when the government backed a drive into small-scale, export-oriented industrialisation and off-shore banking sectors. On 19 September 1983, the country achieved independence from the UK. The economy of St. Kitts and Nevis experienced strong growth for most of the 1990s but a number of hurricanes contributed to a sharp slowdown, particularly in the agricultural, tourism and construction sectors. Latest estimates for 2017 show that Agriculture contributes just 1.1% of the economy, with Industry being 30.0% and Services accounting for 68.9%. Since 2010, tourism has been steadily rising

41 Citizenship By Investment

again to become the largest source of foreign exchange. In 2016, Travel & Tourism directly contributed 5.9% to GDP and in total, including employment, accounted for 25.1% of GDP, a figure forecast to reach 33% by 2027. According to the IMF, St. Kitts and Nevis attained the strongest growth and fiscal performance in the ECCU region in recent years, with public debt set to meet the ECCU’s 60% of GDP target in 2018. The strong performance owes much to Citizenship-by-Investment (CBI) inflows as well as overall prudent macroeconomic policies. GDP in St. Kitts and Nevis is projected to reach around $1.05bn in 2020. St. Kitts and Nevis is a member of the Eastern Caribbean Currency Union (ECCU). The Eastern Caribbean Central Bank (ECCB) issues a common currency (the East Caribbean dollar) for all its members, and regulates and manages monetary policy and banking. The US dollar is widely used as well. The United States is the main export and import partner for the country, accounting for 56% of the total exports and 31.7% of imports. Citizenship by Investment The Saint Kitts and Nevis passport is issued to citizens for international travel. The passport is a Caricom passport as Saint Kitts and Nevis is a member of the Caribbean Community. Interested parties can acquire citizenship if they pass the government’s background checks and make an investment into an approved real estate development. The St. Christopher (Kitts) and Nevis passport issued is valid for 10 years, which can be renewed thereafter. It takes about three to four months processing time. The Government has introduced extensive legislation to attract financial services businesses to the island. The Citizenship by Investment Programme has also been in operation since 1984, allowing foreign investors to acquire citizenship under certain conditions. This makes it the oldest existing citizenship programme in the world, as well as the most reputable citizenship programme in existence. St. Kitts and Nevis citizenship is highly regarded. As a result, St. Kitts and Nevis citizens enjoy a passport with an excellent reputation and very good visa-free travel,

42 Citizenship By Investment

including to all of the EU’s Schengen Area, Hong Kong, Switzerland, and other countries. Accordingly, the St. Kitts and Nevis Citizenship by Investment Programme is an attractive option if one is looking to acquire a second citizenship through investment without prior residence requirements.

You will not be taxed on foreign income, capital gains, gift, wealth, or inheritance tax so this may complement your current wealth protection and tax planning strategies. Citizens of St. Kitts and Nevis are allowed to hold dual citizenship, and the acquisition of citizenship is not reported to other countries.

When you acquire citizenship under the St. Kitts and Nevis Citizenship Programme, you and your family enjoy full citizenship for life, which can be passed on to future generations by descent. As a citizen of St. Kitts and Nevis, you have the right to take up residence in St. Kitts and Nevis at any time and for any length of time.

The regulations regarding citizenship by investment are contained in Part II, Section 3 (5) of the Citizenship Act, 1984. These provisions allow the government to operate a program under which citizenship is granted to persons who qualify under criteria set by cabinet decision.

REQUIREMENTS AND PROCEDURES Minimum Investment To qualify for citizenship of St. Kitts and Nevis under its citizenship by investment programme, there are two active options: 1. Sustainable Growth Fund (SGF) St. Kitts and Nevis launched a new Sustainable Growth fund, effective from 1 April 2018 after the expiry of Hurricane Relief Fund. The Sustainable Growth Fund for a single applicant requires a one-time non-refundable contribution of US$150,000, inclusive of Government fees. The contribution for a family of up to four will be US $195,000 following incremental steps. The fund will benefit St. Kitts and Nevis in sustainable areas such as healthcare, education, alternative energy, heritage, infrastructure, tourism and culture, climate change and resilience, and the promotion of indigenous entrepreneurship.

be resold after seven years. The government works with various approved real estate developers. You can buy villas or apartments or luxury condos, provided you satisfy the minimum investment. The real estate route is more expensive and takes longer to complete, but there is a chance to recoverable investment after five years. You can expect total costs of US$492,000 or more, with the real estate option for single applicant. Additional costs apply for accompanying family members. The SIDF is a much cheaper option for citizenship, compared to real estate investment. The average processing time is between four and six months, if property is purchased from a developer that meets all criteria for efficient processing of citizenship application. Fees and costs

The contribution requirements under SGF are:

Minimum investment: US$150,000 Sustainable Growth Fund (SGF) or US$400,000 (Real estate)

• Main Applicant: US $150,000

Government fee: US$50,000 per person

• Family of Four: US $195,000 (i.e. the main applicant, plus spouse US $25,000 and two children US $10,000 each)

Due diligence fee: US$7,500 main applicant US$4,000 for spouse and for each dependent aged 16 years or over

• Additional family dependents: US $25,000 Passport fee: US$500 per person The government also allows for parents and grandparents over the age of 55 to be included in the application as dependents, if they are living with and are fully supported by the main applicant. The contribution of US$10,000 is required for each additional dependent, regardless of age. 2. Real estate Designated recoverable real estate investment with a value of at least US$400,000 plus payment of various registration and other fees. Additional fees apply for any accompanying family members. The real estate can be sold after five years – it also qualifies the next buyer for citizenship. Effective from April 2018, two persons (jointly) can buy real estate, each contributing US$200,000 (plus the government fees) to meet the US$400,000 requirement but the property can only

Lawyer fee Accelerated Application Process Uniquely amongst citizenship by investment jurisdictions, St. Kitts and Nevis offers an Accelerated Application Process (AAP) for a fixed fee. Interested applicants still need to meet all the mandatory criteria for submitting documents, but if successful they would be guaranteed full processing including getting a registration certificate and passport within 60 days of submission. The AAP fees are inclusive of standard due diligence fees and cost US$25,000 for the main applicant and US$20,000 for dependents aged 16 or over. For any family members under the age of 16 the fee is just US$500 for the passport processing fee.

43 Citizenship By Investment

Are you looking for the right place to invest? St. Kitts provides a healthy climate for business and investment. Situated in the Eastern Caribbean, this exotic tropical island provides an array of investment opportunities in seven priority sectors, namely: Tourism, Financial Services, Information Technology, Agriculture, Light Manufacturing, International Education and Renewable Energy. St. Kitts is rapidly developing with modern infrastructure; roads, international air and sea ports and advanced telecommunication services. Located just three hours by air from the east coast of the United States of America, St. Kitts is perfectly located for doing business. The Government offers investment incentives; including tax holidays for certain qualified investment projects and businesses. There is No Personal Income Tax in St. Kitts or any restrictions on the repatriation of profits and imported capital. The countryâ&#x20AC;&#x2122;s Citizenship by Investment Programme is the oldest and most respected programme of its kind. Its passport provides instant visa-free access to over 150 countries. Citizenship by Investment is an ideal gateway to the world for individuals and families in search of secondary citizenship.

Priority Sectors Tourism Information Technology Agriculture Light Manufacturing Financial Services International Education Renewable Energy Tel: 869-465-1153 www.investstkitts.kn office@investstkitts.kn

ST. KITTS AND NEVIS CITIZENSHIP BY INVESTMENT PROGRAMME by the St. Kitts Investment Promotion Agency St. Kitts & Nevis ranked first in the Caribbean region for its citizenship by investment (CBI) programme, in the 2018 Passport Index, released by leading international CBI firm, Henley & Partners. This is a significant accomplishment for St. Kitts & Nevis as the small island state recently signed a historic Visa Waiver Agreement with Russia. St. Kitts and Nevis was also the only Caribbean island recognised in Bloomberg BusinessWeek’s travel list for 2018, positioning for CBI prohrammes. Currently, St. Kitts & Nevis residents enjoy visa free/entry permits to over 150 countries/territories including Germany, Italy and the United Kingdom, while citizens also enjoy ‘‘short stay’’ visa waivers to France. This is extremely beneficial to St. Kitts & Nevis’s CBI programme, which continues to maintain its high standards of conducting business, and St. Kitts and Nevis is working hard to ensure that its CBI programme remains a first-class brand.

Investors in the programme are given the option to invest in real estate or make a contribution to the Sustainable Growth Fund (SGF).

each dependant of the main application who is over the age of 16 years.


Applicants may qualify for citizenship through an investment in a pre-approved real estate project, which may include hotel shares, villas, and condominium units. The minimum real estate investment required by law is US$400,000 (resaleble after 5 years) for each main applicant.

Applicants may qualify for citizenship through a contribution to the Sustainable Growth Fund (SGF). • Single applicant: a non-refundable con tribution of US$150,000 is required • Main applicant with up to three dependants (for example a spouse and two children): a non-refundable contribution of US$195,000 is required • Additional dependants, regardless of age: US$10,000 Upon submission of an applicant due diligence and processing fees must be also paid. These fees amount to US$7,500 for each main applicant, and US$4,000 for


Upon submission of an application, non-refundable due diligence and processing fees must also be paid. These fees amount to US$7,500 for each main applicant who is over the age of 16 years. • Main applicant: US$35,047 • Spouse of the main applicant: US$20,047 • Any other qualified dependant of the main applicant regardless of age: US$10,047

45 Citizenship By Investment

In addition to those fees, real estate buyers should be aware of purchase costs (mainly compulsory insurance fund contributions and conveyance fees). The government has succeeded in creating an attractive investment climate through sound policies and careful planning. A new landscape of opportunities is now available to investors under defined, prioritesed sectors. These include tourism, offshore financial services, international education, renewable energy and manifacturing. The government offers tax incentives in the form of exemption from import duty and

tax holidays of up to 15 years for qualified investments. The Hotel Aids Act allows for the refurbishment or construction of a hotel and tax holidays of 10 years for 5 years for hotels with 10 to 29 bedrooms. St. Kitts offers numerous opportunities for wealth preservation through an attractive tax regime for doing business. There are no personal income tax and no capital gains or death tax. St. Kitts is attractive as an international financial centre because its services cater to small closely held companies with an easy applications process and reasonable rates. In addition, the Financial Services sector is equipped

Contact: St. Kitts Investment Promotion Agency 2nd Floor KOI Building, #1 Airport Road Golden Rock St. Kitts

46 Citizenship By Investment

with experience and knowledgeable staff and the jurisdiction boasts a regulatory body that meets international standards. Foundations, and Captive Insurance Companies, are identified as unique investment opportunities due to the nature and viability of the products. Companies registered in St. Kitts and Nevis can repatriate all capital, royalties, dividents and profits. There are no exchange controls in St. Kitts and Nevis and the invoicing of foreign trade transactions may be made in any currency.

Tel. (869) 465-1153 Fax. (869) 465-1154 www.investstkitts.kn office@investstkitts.kn

Tel: 869-465-1153 www.investstkitts.kn office@investstkitts.kn

Country Spotlight



Capital city: Castries Population: 179,667 (2018) GDP in Current prices: USD $1.87 billion (2018) GDP growth: 1.0% (2018) Area: 617 km² Government: Unitary parliamentary constitutional monarchy Monarch: Queen Elizabeth II Governor-General: Neville Cenac Prime Minister: Allen Chastanet Currency: East Caribbean dollar (XCD) HDI: 90th (2018) Ease of doing business index: 93rd (2018/19) Time Zone: GMT -4 Dialling code: 1 758


aint Lucia is a sovereign island country in the eastern Caribbean. Part of the Lesser Antilles, it is located between St. Vincent to the south and Martinique to the north, with Barbados approximately 174 kilometres to the southeast. The island measures just 43 kilometres long by approximately 22 kilometres wide and has a coastline of 158 kilometres. With its sandy palm-fringed beaches, crystal clear waters, beautiful bays and lush rainforests, it is a popular destination for tourists and cruise ships.

The island is the only country in the world named after a historical woman, specifically Saint Lucy of Syracuse, who was executed in 304 and venerated as a saint in Roman Catholic, Anglican, Lutheran, and Orthodox churches. Legend has it that some French sailors were shipwrecked there on 13 December, which is the feast day of St. Lucy, and named the island in her honour. The French were the island’s first European settlers, signing a treaty with the Carib Indians in 1660. Over the next 150 years, the rule of the island switched at least 13 times between France and Britain – giving rise to the nickname ‘the Helen of the West Indies’ – before the British gained definitive control in 1814. After becoming one of the West Indies Associated States in 1967, Saint Lucia gained its independence from the UK on 22 February 1979 and became a member of the Commonwealth of Nations. English is the official language

48 Citizenship By Investment

of Saint Lucia, although Saint Lucian Creole French is also used. Geography and climate St. Lucia is more mountainous than most Caribbean islands and even has a drive-in volcano. On the southwestern side of the island, two volcanic peaks rise up out of the clear blue waters. These peaks are the Pitons, the Gros Piton being 771 m high and Petit Piton 743 m high. This area was designated a UNESCO World Heritage site in 2004 and is located near the town of Soufriere, which used to be the French capital of Saint Lucia. Many tourists visit Soufriere for the tranquillity of the Saint Lucia Botanical Gardens and the medicinal properties of the Sulphur Springs. The modern day capital is at Castries, a flourishing port city in the district of Castries, where nearly a third of the island’s population live. Castries took over as the

capital city in 1967 and retained that honour when Saint Lucia gained its independence. The local climate is tropical, moderated by northeast trade winds, with daytime temperatures averaging around 30°C, falling only to around 24°C at night. As the island is located near to the equator, the temperature does not vary greatly throughout the year. Saint Lucia typically has two seasons during a year, a dry season from December until the end of May, and a wet season from June through November. Politics Saint Lucia is a two party parliamentary democracy, and a Commonwealth nation. Queen Elizabeth II is the Head of State, and her presence is represented by a Governor-General. The Prime Minister is usually the head of the party that commands a majority in the House of Assembly. There are 17 seats in the House of Assembly, and 11 seats in the second chamber of Parliament, the Senate. The seat of government is located in Castries, which also houses the head offices of many foreign and local businesses, a number of international embassies and consulates, and the secretariat of the

Organisation of Eastern Caribbean States. The city is located in Castries Quarter in the northwest of the island, one of eleven ‘quarters’ (administrative districts) that the country is divided into. The country is a mixed jurisdiction in that its legal system is based on both civil law and English common law. As well as being a member of the Commonwealth and the United Nations, which it became a member of in December 1979, Saint Lucia is a member of CARICOM (the Caribbean community) and the Organisation of Eastern Caribbean States. It maintains friendly relations with all of the active major powers in the Caribbean including the US, UK, France and Canada. Economy and tourism Saint Lucia is categorised by the UN as a Small Island Developing State economy. Its GDP grew by 3.7% in real terms during 2017 but contracted to just 1.0% real growth in 2018, due principally due to a downturn in both the public and private

construction sectors. Nevertheless, the Caribbean Development Bank are forecasting an improvement in 2019. Saint Lucia’s 2018 nominal GDP figure of $1.874 billion ranked 170th on the World Bank listings, but in terms of nominal GDP per capita rankings, Saint Lucia’s figure of $10,610 placed as high as 68th. The services sector accounted for approximately 82.8% of GDP, with industry 14.2% and agriculture 2.9%. The island nation has been able to attract foreign business and investment, especially in its offshore banking and tourism industries, attracted by a well-developed legal and commercial infrastructure, an educated workforce, improved roads, an upgraded communications system, port facilities, and a business-friendly entrepreneurial climate. The manufacturing sector is the most diverse in the Eastern Caribbean area. Crops such as bananas, cocoa, coconuts, avocados and mangos are grown for export. Tourism is vital to Saint Lucia’s economy, accounting for 65% of GDP, and is the

main source of jobs, income and foreign exchange earnings. The popular tourist season tends to be January to April during the dry season. The island was attracting over 900,000 visitors annually, most of whom were stopping off as part of a cruise. However, after 2017 registered an all-time record of 1,105,541 inbound tourist arrivals, 2018 saw a further 10.2% increase with 1,218,294 visitor arrivals. Of these, 760,306 (62.4%) came by cruise ship as the Caribbean cruise sector enjoyed its best ever performance. The number of stay-over visitors arriving by air improved from 386,127 in 2017 to 394,780 in 2018. As with other Caribbean destinations, the USA, UK and Canada are the major tourism revenue markets, accounting for 44.3%, 19.3% and 10.2% of stopover visitors respectively. A different kind of tourist attraction is the Saint Lucia Jazz Festival. First held in 1992, this annual event has grown in stature and encompasses live music performances, street parties, educational activities and fashion shows at various venues across the island.

49 Citizenship By Investment

CITIZENSHIP BY INVESTMENT The Saint Lucia Citizenship by Investment Programme was founded in 2015 and came into force from 1 January 2016, making it the newest of the Caribbean citizenship programmes.

• Each extra qualifying dependant, of any age: US$25,000


The Cabinet of Ministers evaluates proposed real estate projects for the possibility of citizenship. Approved real estate projects may be luxury branded hotels and resorts or high-end boutique properties.

Saint Lucia is a stable nation and has a quality of life that very few places in the world can rival. Having a Saint Lucian passport allows for visa-free travel to more than 120 countries, including most of Europe, the UK, and Hong Kong. Saint Lucia recognises dual citizenship, which can provide advantages for business expansion and tax belief. There is no tax on wealth, gifts, foreign income or capital gains. There is no requirement to visit Saint Lucia during the application process, no interview requirement and there are no residency requirements. Applications for citizenship by investment must be submitted in English by an authorised agent on behalf of the applicant. Applications, including those with dependents, are processed within 3 months. In order to qualify for citizenship, applicants must choose one of the following four options: 1. 2. 3. 4.

National Economic Fund Real Estate Projects Enterprise Projects Government Bonds

1. National Economic Fund This is a fund established to receive investments of cash from the citizenship program that will be used in the funding of government sponsored projects. The Finance Minister must seek approval from Parliament for the allocation of funds for his chosen purposes.

2. Real Estate Projects

The minimum investment is US$300,000 per application plus additional government fees of US$50,000 for the main applicant and US$35,000 for spouse, plus additional fees for dependants. The real estate must be held for at least five years following the grant of citizenship. 3. Enterprise Projects Applicants may choose to make investments in pre-approved enterprise projects such as marinas, research institutions or infrastructure projects (e.g. ports, bridges, roads and highways). Joint investments are allowed, with each applicant investing at least US$1 million and the entire project must be valued at no less than US$6 million and create at least six permanent jobs. A sole applicant must make a minimum investment of US$3.5 million and create at least three jobs. 4. Government bonds The fourth option is through the purchase of non-interest-bearing Government bonds. These bonds must be registered and remain in the name of the applicant for a minimum of five years from the date of first issue and not attract a rate of interest. Once approved, the following minimum investment is required:

Once an application for citizenship through investment in the Saint Lucia National Economic Fund has been approved, an investment is required as follows:

• Sole applicant: US$500,000

• Single applicant: US$100,000

• Applicant applying with spouse and up to two dependants: US$550,000

• Main applicant plus Spouse: US$165,000 • Applicant applying with spouse and up to two other qualifying dependants: US$190,000

50 Citizenship By Investment

• Couple (applicant and spouse): US$535,000

• Each extra dependant: US$25,000.

INVESTING IN BEAUTIFUL SAINT LUCIA An interview with BRENDA FLOISSAC FLEMING, Senior Partner, Floissac Fleming & Associates Brenda Floissac Fleming, B.A. (Law) is the Senior Partner and Head of Chambers at Floissac Fleming & Associates. Ranked as a Band 1 Lawyer with Global Ranking Chambers and Partners for General Business Law in Saint Lucia, she has spearheaded the transition of the firm from a prominent family practice to one of the largest and most diverse practices in Saint Lucia. With over thirty years of legal experience, Brenda has amassed a wealth of experience in all areas of corporate practice. She currently oversees the Commercial/Corporate and Property departments of the firm. She sits on the Board of directors of 1st National Bank (the largest local indigenous bank) and is also the honorary counsel for Chile. She is a member of the International Trademark Association (INTA) and the Intellectual Property Caribbean Association (IPCA).

Floissac Fleming & Associates is well known as one of Saint Luciaâ&#x20AC;&#x2122;s oldest and most reputable law firms with nearly 60 years of legal experience. Can you please tell us about your relationship with the Polaris Consultancy Services company?

providing an efficient service to its clients and encouraging investment in the CIP Programme. Floissac Fleming & Associates as an associated entity of Polaris compliments Polaris as it provides a full suite of legal services.

Polaris Citizenship & Investment Consultancy Services Limited (a.k.a. Polaris) is a company formed by the partners of Floissac Fleming & Associates to render services to applicants for Saint Lucian citizenship under the Saint Lucia Citizenship by Investment Act No. 14 of 2015. Polaris is an authorised agent under the Citizenship by Investment Programme (CIP).

What are some of the services that Floissac Fleming & Associates are able to provide for any high-net-worth individuals who are considering investing in or moving to Saint Lucia?

How does Floissac Fleming & Associates interact with Saint Luciaâ&#x20AC;&#x2122;s Citizenship by Investment programme? Note that it is Polaris, as the licensee under the CIP Programme, which is the entity which contributes to the programme by

Floissac Fleming & Associates provides a host of legal services to the clients of Polaris, and is a full-service civil practice. It is particularly known for its specialization in Commercial Law and boasts the ability to serve clients in both contentious and non-contentious matters. It provides services to the financial sector, Alternative Dispute Resolution Services, Intellectual Property - Trademarks Patents & Designs registrations and renewals, and advice on

Employment and Labour issues. We also provide Notarial Services, render advice to investors in the hospitality industry and advice in mergers and acquisitions. Please explain/clarify the benefits of investing in Real Estate in Saint Lucia versus the Government approved fund. Investing in a CIP approved real estate development means that you have a tangible investment in the island of Saint Lucia and not just citizenship status. Secondly depending on the type of real estate you can have a shareholding in the respective project or have freehold title supported by an actual deed of ownership. The Sale and Purchase Agreement will define the return on the specific real estate investment that will accrue to the respective applicant. The real estate investment also gives the investor the option of five years to sell your ownership holding.


Floissac Fleming & Associates

51 Citizenship By Investment

A CLIENT FOCUSED APPROACH TO CITIZENSHIP BY INVESTMENT by Cindy Emmanuel-Mclean consulting partner at TM ANTOINE Partners


ANTOINE Partners Advisory has carved out a special place in the citizenship by investment landscape of Saint Lucia, the Caribbean and the globe. As an authorised agent, registered in Saint Lucia, we do not just help clients submit their applications for citizenship of Saint Lucia â&#x20AC;&#x201C; our work is much more specific and detailed than that. We specialise in creating targeted solutions for each client. This includes helping clients choose the best Caribbean citizenship programme for their circumstances. The individualised approach to citizenship by investment was a result of a conscious effort to make the clients and their solutions the first and only focus for our citizenship advisory. Our inspiration Before launching the citizenship advisory as part of the law firm of TM ANTOINE Partners, Thaddeus M. Antoine, the managing partner, travelled extensively attending citizenship by investment conferences and educating himself about the industry. He played a pivotal role in helping shape Saint Luciaâ&#x20AC;&#x2122;s programme as a Senator of Government in 2015/2016. During his many fact-finding missions, he met extensively with marketing agents, promoters, agents and government officials. The conferences did not cater to the individuals who would be applying for citizenship. Everything to be learnt about the needs of the clients was offered by third, fourth- and fifth-party service providers. Thirty months ago, in March of 2016, TM ANTOINE Partners Advisory submitted the first application for citizenship by investment. Today, the process used by the company to assess clients, prepare applications for submission and communicate with clients has completely evolved. Everything we do is aimed at making our assertion that we provide fivestar service, offering a tailored approach for the unique circumstances of each of our clients from enquiry to citizenship, the reality that the client experiences when working with us. This is first evidenced by the free Pre-Application Assessment that is offered by TM ANTOINE Partners Advisory to each of the clients who express an interest in applying for citizenship of Saint Lucia.

52 Citizenship By Investment

Finding the perfect fit The free Pre-Application Assessment involves conducting an initial due diligence background check on the prospective applicant. Any areas of concern are immediately pointed out to the client and discussed as to how it would affect their application for citizenship. Where the due diligence background check reveals issues that legislatively would prohibit the prospective applicant from obtaining citizenship of Saint Lucia, TM ANTOINE Partners Advisory advises the client that the application cannot proceed. This is a clear example of putting the interests of the client ahead of those of the company. Another key feature of the Pre-Application Assessment is providing clients with a comprehensive estimate of the costs of obtaining citizenship of Saint Lucia as well as the other four countries offering citizenship by investment in the Caribbean. Cost is perhaps the most significant factor for some clients and there is value in giving the clients the full range of options available to them. The result of that practice is that each client gets to apply for the Caribbean programme that is the best fit for them. That is important to TM ANTOINE Partners Advisory, more critical than persuading every client to subscribe to any single programme. We are always happy to meet the clients’ needs either on our own or through our trusted partners throughout the Caribbean. TM ANTOINE Partners is committed to guiding prospective applicants who, after the completion of the Free Pre-Applicant Assessment, have determined that they will proceed with their application. We design a customised checklist for each applicant detailing the documents and forms that they will need. Clients who follow the TMA checklist save time by focusing their efforts on only what is needed to complete their application. We will often include a request for additional supporting documents not ordinarily required by the Citizenship by Investment Unit. We do so because a complete application should answer all questions that are likely to arise about our clients. This approach has resulted in an almost 100% success rate for the applications we submit to the Unit. Our TMA Online Tool is used to provide Assessment Feedback to clients who can provide corrections, additional information and explanations online in real time. This has reduced the time it takes to get a file ready for submission by over 65%. Our Assessment Feedback is detailed and lets each client know exactly what must be done to bring their application into compliance with the requirements of the Citizenship by Investment Unit. Meeting client expectations TM ANTOINE Partners Advisory would love to boast 100% satisfaction among our clients but at this time it is not possible to do so. Of most concern to clients is what they see as the inordinate amount of time it takes for their applications to be processed. Other than costs, the processing time is the second most quoted reason for our clients choosing other Caribbean islands. It is clear that Saint Lucia

values its reputation and therefore puts a premium on due diligence background check on all applicants. This accounts for the longest part of the application process and sometimes takes the delivery of decisions on applications way beyond the desired 90 days.

application process needs to be streamlined by reducing the number of forms to be completed, widening the range of supporting documents that can be used to bolster one’s case for obtaining citizenship and presenting options for applicants to engage with the Programme.

As new options for obtaining a second citizenship are being offered to global citizens, it is critical that the Caribbean become more responsive to the needs of the clients. Governments processes are often clogged with bureaucracy and political interests but that should not dissuade them from building an elasticity into their citizenship by investment programmes that allows them to change to meet the ever-changing expectations of prospective investment citizens. Other Caribbean islands, most recently Grenada, and especially Dominica and St. Kitts have managed this process relatively well. In recent times, these countries have made changes to their offerings, which we believe make them more attractive to the global market.

Saint Lucia – Let her inspire you

Based on the requests that we are getting from our clients Saint Lucia is lagging in significant ways. Our clients want the option to add new members of their family to their applications after approval. They want to apply for their dependent children who are past the age of 25. They need to include their children between the ages of 18 and 25 who are not currently enrolled in schools. All these are options which they have in the other Caribbean countries and are willing to pay a premium to get them. We must strive the find the balance between our need to protect our reputation and the desired longevity and viability of our Programme.

Given all the changes that TM ANTOINE Partners Advisory would like to see in the Programme we are always ready to answer the question – why Saint Lucia? We are unashamed to provide you with the most biased answer that we can provide – Saint Lucia is simply good. Saint Lucia is simply good for business with a diversified economy, diversified and skilled labour force and a diversified investment portfolio. Saint Lucia is simply good for life. Our life expectancy is 74.5 years for men and 79 for women. We have a rich and vibrant culture that caters to every lifestyle. Saint Lucia is simply good for fantasy. Oprah Winfrey described Saint Lucia as the number one location to see before you die. That is further endorsed by the numerous couples that have made Saint Lucia consistently rank as the number one wedding and honeymoon destination in the world, most recently in 2018.

Contact us TM ANTOINE Partners wants to give you your passport to Saint Lucia, to freedom. Please contact me to discuss your options.

The desired future At TM ANTOINE Partners we still concur with the findings of the Task Force on Citizenship by Investment who proffered that there are five important decision-making factors for persons considering investment in a CIP programme. • Cost – measuring the costs pertinent to the application and the net investment that the applicant is required to make • Speed – the time it takes to citizenship • Global Mobility – the total number of countries accessible visa-free on a passport as well as access to the most desirable places to visit • Simplicity – clarity and seamlessness of the application process • Quality of Life – based on external quality of life indices. For at least three of the five factors, there are simple, easy and painless steps that Saint Lucia can take to increase the unique selling point of its Programme. We must find ways to effectively reduce the time it takes to get to a decision. An aggressive campaign of increasing the number of countries with which we have visa-free access must be pursued while working diligently to protect those existing visa-free relationships. The

Cindy Emmanuel-McLean consulting partner TM ANTOINE Partners Tel: 1 (416) 727 1648 1 (758) 519 2917 1 (758) 453 2000 cmclean@tmantoinelaw.com https://cip.tmantoinelaw.com

53 Citizenship By Investment

Country Spotlight



Full name: Republic of Cyprus Capital city: Nicosia Population: 1,179,551 (1 January 2018) GDP in Current Prices: USD $24.49 billion (2018) GDP real growth: 3.9% (2018) Area: 9,253 km² Government: Unitary presidential constitutional republic President: Nicos Anastasiades President of Parliament: Demetris Syllouris Currency: Euro (€) (EUR) HDI: 32nd (2018) – “very high” Ease of doing business index: 57th (2018/19) Time Zone: GMT + 2 Dialling code: 357


yprus is an island country situated in the far eastern end of the Mediterranean Sea. Geographically, it is closer to Asia than it is to Europe, lying just 70 kilometres south of Turkey, 105 km west of Syria, 207 km northwest of Lebanon and 390 km north of Egypt. Although the Greek island of Crete lies 785 km west of Cyprus, historically and culturally Cyprus is definitely in Europe. The island is 225km long at its largest point and 97 km at its widest, with a coastline that measures 648 km, making it the third largest island in the Mediterranean. Its climate is subtropical and is one of the warmest countries in Europe with an average annual temperature of 24° along its coast and over 340 days of sunshine a year. Not unsurprisingly, the island is a major tourist destination, not just for its fabulous beaches with shallow turquoise waters, but also for its many historic churches and archaeological sites dating back to the Greek and Roman empires. Cyprus has long been revered as the birthplace of the goddess Aphrodite who, in Greek mythology, was born in the sea and came to the shore 25km east of Paphos on the coast road to Limassol. History Its strategic location has meant that Cyprus has seen a lot of history and been a major trade hub between Europe, northern Africa and the Middle East. The earliest known settlers date back to around 10,000 BC,

54 Citizenship By Investment

with some archaeological discoveries pre-dating ancient Egyptian civilisation. One of the most important finds is that of a remarkably well-preserved Neolithic settlement at Khirokitia which was discovered in 1934 and designated a UNESCO World Heritage Site in 1998. Cyprus was colonised by Mycenaean Greeks during the 2nd millennium BC and was later occupied at different times by Assyrians, Egyptians and Persians before Alexander the Great seized the island in 333 BC, after which the island became fully immersed in Greek culture and language. Cyprus became part of the Byzantine Empire after the division of the Roman Empire in AD 395 between west and east. In 1489, Cyprus was annexed by the Republic of Venice. However, the island endured frequent attacks from the Ottoman Empire and fell under Ottoman rule from 1570. In July 1878, British occupation began by mutual agreement as the Ottomans sought protection from Russian aggression, whilst the British were keen to protect their vital

sea route to India via the recently opened Suez Canal. Cyprus became a strategic naval outpost and to this day, Britain still has two sovereign military bases at Akrotiri and Dhekelia. The British Empire formally annexed Cyprus in November 1914 following the outbreak of World War I, and, after Turkey had relinquished any claim to Cyprus in 1923, continued to hold the island as a crown colony. However, by the 1950s, the Cypriot Turks were increasingly uneasy at the attempts by the Greek Cypriot population to align the country directly with Greece. After talks held in London and Zurich between the UK, Greece and Turkey during February 1959, agreements were reached on a draft constitution and Cyprus was officially proclaimed an independant state on 16 August 1960. Modern Cyprus Archbishop Makarios III had been elected president in December 1959 and, having accepted that full union with Greece was politically unworkable, he moved more towards non-alignment and cultivated good relations with Turkey as well as with Greece after taking office as the 1st President of Cyprus. At the time, the population of Cyprus was 573,566 of whom 77.1% were Greeks and 18.2% were Turks. However, simmering discontent over the constitutional

that the Greek allocation of 56 seats would be numerically sufficient to maintain the smooth running of the parliamentary committees and the legislative body. The members are elected every five years by a proportional representation system and voting is mandatory. The last election was held on 22 May 2016 and the 24 seats allocated for the Turkish Cypriots remain vacant. Economy

allocation of rights between the Greek Cypriots and Turkish Cypriots led to intercommunal attacks, threats of invasion and an attempted Greek-led military coup to oust Makarios III, prompting a full-scale Turkish invasion during July and August 1974. This led to the UN-organised partition of the island and the creation of a buffer zone, commonly referred to as the Green Line, which went through the capital city of Nicosia. Around 150,000 Greek Cypriots were expelled from the occupied northern territory and between 40,000 to 65,000 Turkish Cypriots were later displaced from the south to the north.

opened the border in Nicosia. However, the Annan Plan of 2004 drafted by the then UN Secretary Kofi Annan was rejected in a referendum. The net result is that the Republic of Cyprus was accepted as a full member, but the rights of membership are still suspended for Northern Cyprus. Cyprus adopted the euro as its national currency on 1 January 2008 and is expected to be able to join the Schengen Area in the near future. Politics

In 1983, the Turkish part of the island – some 3,355 km² amounting to 36.25% of the total island’s area – declared its independence as the Turkish Republic of Northern Cyprus, but Turkey is the only country to recognise it. The rest of the international community regard the Turkish Army based there as an illegal occupation force.

Cyprus is a unitary republic with a presidential system of government. The President of Cyprus is both head of state and head of government and he or she (although there has yet to be a female incumbent) is elected every five years during the middle of the parliamentary term. The current president Nicos Anastasiades was re-elected for a second consecutive term of office on 4 February 2018.

Cyprus has been a member of the UN since 20 September 1960 and of the Commonwealth of Nations since 1961. On 1 May 2004, Cyprus joined the European Union despite unsuccessful attempts by the UN Security Council to find a peaceful resolution to the ongoing partition. Several rounds of talks were held throughout 2000 -2002 ahead of an EU Summit in Copenhagen in December 2002 and in April 2003 the Turkish side unilaterally

The House of Representatives is the parliament of the Cypriot Republic based in the capital Nicosia and was originally intended to have 50 representatives, with 35 seats (70%) allocated to the Greek Cypriot community and 15 seats to the Turkish Cypriot community. However, the Turkish Cypriots have not attended since 1964 and a decision was made in 1985 to increase the number of seats to 80, but keeping the same constitutional share so

Cyprus has evolved from a small exporter of agricultural products and minerals into an advanced high-income economy based on services and some light manufacturing. Despite the damage done to the island’s infrastructure and tourist industry in the aftermath of the Turkish invasion, its GDP grew steadily during the 1980s with an average annual real GDP growth of 6.1%. The 1990s saw more fluctuating swings but still maintained continuous positive growth averaging 4.9%. But 2009 saw Cyprus suffer more than most during the global economic depression having only just joined the euro zone, and the economy contracted by 2.0%. Worse was to follow during the 2012/13 Cypriot financial crisis, largely caused by a series of what turned out to be bad loans made to Greek companies during Greece’s own financial crisis as part of the wider Eurozone sovereign debt crisis. In June 2012 the Cypriot government requested help from the EU as its economy contracted by 2.9% and its international credit rating was reduced to ‘junk status’. In March 2013, the government received a €10 billion bail-out from the European Commission, the European Central bank and the International Monetary Fund (IMF) with several unpopular austerity strings attached. These included the dismantling of the Cyprus Popular bank in March 2013, with its ‘good’ assets being taken over by the Bank of Cyprus. The economy declined a further 5.8% in 2013, but by Q1 2015 the economy had started to grow again after three and a half years of recession. The Cypriot government was praised by the EU for its financial reforms and the country was able to exit the programme in March 2016, having only drawn €7.3 billion of the available funds. Since then, the economy has been growing again at a real annual growth rate of 4% and, in 2018, the major international credit ratings agencies upgraded Cyprus’ economic outlook to ‘stable’.

55 Citizenship By Investment

The economic recovery was helped by a resurgent tourist trade and real estate market after the government relaunched its economic citizenship programme in 2014. This contributed to a huge surge in demand for luxury apartments and homes in coastal areas and town centres. Property sales rose by a reported 24% between 2016 and 2017, with over a quarter of new purchases being made by non-Cypriots, which has also had the effect of pushing prices up whilst boosting the construction sector. Trade and tourism Agriculture has remained a strong sector for Cyprus, with citrus, potatoes and cheese amongst its main exports. In 2017, agriculture contributed 2.3% to GDP, while industry contributed 11% and services 86.7%. Cyprus imports more products than it exports, but a 27% growth in exports during

2018 helped reduce the annual trade deficit by over 13%. The island’s geographical location and its proximity to the Suez Canal has greatly benefitted its economy as many ship management companies have established offices in Limassol. Cyprus has one of the world’s top ten merchant fleets with more than 1,600 ships sailing under the Cypriot flag. Each of the past five years has seen an increase in the number of international tourists heading for Cyprus. 2018 saw a record breaking 3,938,625 tourist arrivals according to Cystat, an increase of 7.8% over 2017’s total of 3,652,073 and over 63.7% higher than 2013. The highest number of inbound tourists come from the UK (36% in 2018) followed by Russia (22%). The total contribution of travel and tourism to Cyprus’ GDP last year was 21.9% and generated around 22% of employment.

Fuel for growth Looking to the future, large gas fields were discovered off the Cypriot coast in 2011 in Aphrodite Field and industrial gas production is expected to begin in 2022. Egypt also discovered a large gas field in 2015 adjacent to the Aphrodite field and has been in discussions with Cyprus about a shared undersea pipeline. In February 2019, US energy giant ExxonMobil confirmed it has discovered a huge natural gas reserve off the south coast of Cyprus within the island’s Exclusive Economic Zone (EEZ) and there is speculation that the find could prove to be a game-changer in the region’s energy resources, even potentially helping to resolve the ongoing dispute with Turkey over the island’s partition.

CITIZENSHIP BY INVESTMENT Cyprus first introduced its Citizenship by Investment programme in 2002 but with a highly prohibitive minimum entry figure of €15 million. In the wake of the 2012/13 financial crisis, the government effectively relaunched the programme in May 2013 and every year since has seen an increase in the number of applications, coming mainly from Asia, the Middle East and Eastern European countries. The minimum investment was reduced to €2,000,000 in 2016, and a further review in May 2018 put a cap of 700 approved new applicants a year under the Cypriot Investment Programme (CIP) and tightened up on due diligence. With the number of yearly applicants soon reaching the self-imposed cap for approvals in 2018, the Council of Ministers approved further amendments to the CIP effective from 15 May 2019. To qualify for the scheme, applicants must meet the following requirements: • Own or purchase a permanent private residence in the Republic of Cyprus valued at €500,000+ • Possess a valid passport and have a valid Schengen Visa

56 Citizenship By Investment

• Not have been refused for citizenship by another EU member state • Invest €2,000,000 in real estate property development, infrastructure projects or in businesses recognized under the Registered Alternative Investments Organisations (UCITS) including investment made within the Cyprus shipping industry. (The option to invest in government bonds has now been abolished) • Furthermore, the investment is required to be maintained for a period of at least five years from the date of naturalization, whereas previously the period was three years • In cases where residential property is acquired and had already been used for the purposes of the CIP, the required investment amount increases from €2 million to €2.5m • A donation of €75,000 must be made to the ‘Research Promotion Foundation’ • A donation of €75,000 must also be made to the ‘Cyprus Land Development Corporation’.

Residency Visas One of the fastest ways of securing residency in Cyprus is via the family residency visa, also known as a ‘golden visa’. The minimum investment level for non-EU citizens is just €300,000 in brand new real estate and the residency visa is usually granted within just two months. This covers all the family including parents of both the main applicant and spouse and dependent children up to the age of 25. Benefits of Cyprus permanent residency • Visa-free entry to 173 countries including freedom of movement throughout the European Union • There are no language requirements and no requirement to live in Cyprus, although a visit to Cyprus once every two years is required to maintain residence status • Cyprus allows dual nationality • Citizenship is also passed on to dependents and future generations subject to basic documentation • Advantageous tax system for businesses; corporate tax rate in Cyprus is 12.5%.

Country Spotlight



Full name: Hellenic Republic Capital city: Athens Population: 10,741,165 (1 January 2018) GDP in Current prices: USD $218.06 billion (2018) GDP real growth: 1.9% (2018) Area: 132,049 km² Government: Unitary parliamentary republic President: Prokopis Pavlopoulos Prime Minister: Kyriakos Mitsotakis Currency: Euro (€) (EUR) HDI: 31st (2018) Ease of doing business index: 72nd (2018/19) Time Zone: GMT +2 Dialling code: 30


reece is one of the oldest countries in Europe and is generally considered to be the cradle of Western civilisation. Situated in Southeast Europe on the southern tip of the Balkan Peninsula, the country shares land borders with Albania to the northwest, North Macedonia and Bulgaria to the north, and Turkey to the northeast. The rest of the mainland is washed by the Aegean Sea to the east, the Mediterranean and the Cretan Sea to the south, and the Ionian Sea to the west. Geography and administrative regions Greece is basically a peninsular country with an archipelago of several thousand islands and has three main geographical constituents: • The northern mainland, which is mostly mountainous, has a total land area of 96,733 km² and contains eight of the 13 regions that Greece was divided into with effect from 1 January 2011 following a major administrative reform. These include Attica, the capital of which is also the national capital of Athens, one of the oldest cities in the world with a recorded history of 3,500 years. • The Peloponnese peninsula to the south is separated from the mainland by the Corinth Canal and is an individual region with a land area of 15,511 km². The canal stretches for 6.3 kilometres across the Isthmus of Corinth linking the Corinthian

of 15,511 km². The canal stretches for 6.3 kilometres across the Isthmus of Corinth linking the Corinthian Gulf with the Saronic Gulf. Several rulers including the Roman emperors Caligula and Nero had commissioned studies into digging a canal, but it wasn’t until 1881 that work actually commenced and it formally opened in July 1893. The canal has a water depth of 8 metres and a width of between 21-25 metres and is mainly used now by tourist ships. • The rest of Greece is made up of around 6,000 islands and islets that between them make up around 19.805 km² (15% of Greece’s total land area) and are divided into the remaining four administrative regions: - Ionian Islands, with Corfu as its capital - North Aegean, including the islands of Lesbos and Samos

- South Aegean, including the Cyclades and Dodecanese island groups - Crete, which includes the island of Crete, the largest and most populous of the Greek islands, and the island of Gavdos, which is the southernmost point, not just of Greece, but of the whole of Europe. According to the Hellenic Statistical Authority, 227 islands are inhabited and account for 13% of the country’s total population of 10.74 million. Classical History There were several advanced civilisations evident in Greece during the 3rd and 4th millennia BC before the rise of the Mycenaeans on the Greek mainland around 1900 BC. By the end of the Bronze Age, following a period of considerable regional upheaval, Greece was a conglomerate of city states which also spread into Southern Italy and Asia Minor. In 776 BC, the first Olympic Games were held at Olympia on the Peloponnese peninsula and it was around this time that Homer composed his classical works the Iliad and the Odyssey as part of a great cultural boom.

57 Citizenship By Investment

In 508 BC, the world’s first democratic system of government was instigated in Athens. But several city states in Macedonia and Asia Minor were falling victim to raids by the Persian Empire and in 481 BC, the Hellenic League was formed to repel the Persians. Led by Sparta and Athens, the Greek victories heralded a period of stability referred to as The Golden Age of Athens, during which time many of the foundations of western civilisation were established. Philip II of Macedon united most of the Greek mainland before his assassination in 336 BC, and his son Alexander the Great expanded the empire into northeast Africa and Asia, helping to spread Greek culture, language and technology. Greece later fell under Roman rule from 146 BC and was absorbed into the Roman Empire by the emperor Augustus in 27 BC. However, the Romans admired and protected Hellenistic culture and Greece continued to flourish for the most part into the middle ages. During the 14th and 15th centuries, much of the Greek peninsula fell into the hands of the Turkish Ottomans, prompting waves of Byzantine Greek scholars to flee to the west, taking with them (and thereby preserving) great hoards of Classical Greek and Latin literature. By 1460, the whole of the Greek mainland had been conquered by the Ottomans with most of the island groups falling during the 16th century. Only the Ionian islands escaped long-term Ottoman rule, as the Republic of Venice

58 Citizenship By Investment

retained control until the islands were captured by the French Republic in 1797 and later ceded to the UK in 1809. The early nineteenth century saw a rise in what was termed the Modern Greek Enlightenment, as dispersed Greek merchants gained wealth through commerce and shipping. A series of separate revolts against the Ottomans and their Egyptian allies brought brutal response on some islands, which in turn led to the French, Russian and British sending fleets to aid the Greeks in what later became known as the Greek War of Independence (1821-1829). Following a decisive victory at the Battle of Navarino and subsequent negotiations, Greece secured its independence and the new state was formally recognised by the major powers in an agreement signed on 3 February 1830. Greek Independence Day is celebrated as a national holiday on every 25th of March, this being the traditional anniversary date of the declaration of independence in 1821. Modern Greece Over the next few decades, Greece became embroiled in several more conflicts with the Ottomans, including the Balkan Wars of 1912-13, which saw Greece consolidate and expand its territory into Macedonia and Thrace. The onset of World War II saw much of Greece occupied by Nazi forces during 1941-1944 while its government was in exile, during which time the Greek

resistance was regarded as one of the bravest and most effective resistance movements in Europe, despite the brutal reprisals meted out by the occupation forces. However, Greece’s liberation by the Allied troops in October 1944 did not alleviate the social hardships for long, as the country descended into a violent civil war between the government’s national army (backed by the USA and the UK) and the communist forces of the DSE (backed principally by Yugoslavia) lasting until October 1949. With increased aid from the USA, the Greek government won through and the country joined NATO in 1952 to strengthen the Western bloc during the early days of the Cold War. But political tensions during the 1960s culminated in another coup d’etat on 21 April 1967. For the next seven years, the country was ruled by far-right military juntas in what was commonly referred to as the ‘Regime of the Colonels’. During this period, civil liberties were brutally suppressed and the repercussions of the regime continued to reverberate for many years afterwards, with the leading junta members later arrested and sentenced to death (later commuted to life imprisonment) for high treason. Parliamentary democracy was restored in November 1974 and a referendum held the following month voted against the restoration of the monarchy. This created what is generally referred to as the Third Hellenic Republic and a new democratic

constitution was drawn up and adopted on 11 June 1975. In 1980, Greece rejoined NATO, having previously suspended its membership in 1974 in protest at the Turkish invasion of Cyprus. On 1 January 1981, Greece became the tenth country to join the European Economic Community, heralding a sustained period of economic growth. Greece joined the Eurozone in 2001, having successfully satisfied the criteria for acceptance, and in August 2004, Athens successfully hosted the summer Olympic Games, using the motto ‘Welcome Home’. Politics Officially, although starting as a republic, Greece was a constitutional monarchy from 1844 and a crowned republic from 1864 until 1924. The monarchy was restored in 1935 but finally abolished in 1974. The 1975 Greek constitution describes Greece as a ‘presidential parliamentary republic’. The head of state is the President, who is elected by the parliament for a five-year term with a maximum of two terms. The Greek parliament is a unicameral legislature which is elected for a maximum four-year term using a complicated form of proportional representation to determine who fills the 300 seats. All voters are automatically registered and voting is mandatory. In 2016, the voting age was recuced from 18 to 17, taking effect from the 2019 elections. The Prime Minister is formally appointed by the President and

is usually the leader of whichever political party polls the most votes and is able to form a majority or coalition government. The parliament is located at the Old Royal Palace which overlooks Syntagma Square in Athens. The latest parliamentary election was held on 7 July 2019 and was the sixth legislative election in less than ten years. The previous Prime Minister Alexis Tsipras had taken the left-wing political party Syriza to power in the January 2015 elections with an antiausterity manifesto and he was re-elected in the September 2015 snap election at the height of the Greek bail-out crisis (see below). But following defeats in the 2019 local elections and European elections, Tsipras called a snap election and ultimately paid the price for under-delivering on his campaign promises, losing 59 seats as the New Democracy party returned to power with an outright majority of 158 seats. Economy and trade Greece has an advanced high-income developed economy with a high standard of living. The country went through a period of rapid economic growth after joining the EU, averaging over 2.5% real year-on-year growth between 1984 and 2007, by which time Greece had climbed into the World Bank’s list of top 30 largest economies by nominal GDP. However, the global financial crisis of 2007-2009 affected Greece more severely than most countries as the country’s public

debt rose to unsustainable levels. In 2010, the other Eurozone members together with the IMF agreed an initial €110 billion euros rescue package, followed by a second bail-out in 2012, but on condition that the Greek government implemented strict austerity measures. Unfortunately, the crisis was to get worse before it got better; the country suffered a 25% drop in its GDP between 2009 and 2012, for which, in June 2013, the IMF acknowledged and apologised to Greece for mistakes in underestimating the impact of the austerity conditions. Unemployment rose from 7.8% in 2008 to 27.5% in 2013, with youth (age 15-24) unemployment rising from 21.7% to 58.2% over the same period, leading to social unrest and targeted strikes by public service workers. But in 2014, after six consecutive years of recession and restructuring of the national debt, the economy grew by 0.7% and a third bailout was finally agreed after several months of negotiation in July 2015, payable in tranches until August 2018. Slight contractions of -0.4% and -0.2% followed in 2015 and 2016 respectively, but 2017 saw a real growth rate of 1.5% and the latest figures for 2018 show an improved real growth of 1.9%. Unemployment has also improved, down to 19.6% across 2018 with youth unemployment hovering just under 40%, although Greece still has one of the highest levels of unemployment in Europe.

59 Citizenship By Investment

Travel and tourism

driver in the recovery of the Greek economy. Tourism has always been important to Greece, with its cultural heritage, extensive beaches and Mediterranean climate making Greece one of the most visited countries not just in Europe, but globally. Greece has no fewer than 18 UNESCO World Heritage Sites and its island Santorini – a favourite destination for cruise passengers as well as direct holiday-makers – was voted the world’s best island in 2011 by ‘Travel + Leisure’ and was the most visited island in Greece last year with close to two million visitors. The total number of international tourists to Greece reached 30.12 million during 2018, 10.8% higher than 2017’s total of 27.19 million and more than double the number of arrivals in 2009.

2018 was also a very good year for the tourism industry, which has been a key

The Bank of Greece reported that the revenues generated by the tourists

The economy, which now ranks 50th in terms of nominal GDP, is largely based on services, tourism and shipping. The agricultural sector contributes about 4% to GDP, industry 16% and services 80%. Exports rose by 15.7% in 2018 to achieve a record high of €33.4 billion (including oil products), while the value of imports rose by 9.5% to €55.1 billion. This gave a trade deficit for 2018 of around €21.7 billion, which is a significant improvement on the €44.3 billion negative balance of trade in 2008. The Panhellenic Exporters’ Association are expecting 2019 to be another record year for exports which, with sustained investment, they hope will help to boost local jobs.

amounted to €16.11 billion ($18.30 billion). 71% of the tourists were nationals from other EU member states, with 4.4 million coming from Germany, followed by 2.9m from the UK and 1.5m from France. The number of international air arrivals grew by 12.9% to a record 20.7 million, with Athens International Airport – the largest of 15 international airports in Greece – seeing a 19.4% year-on-year increase in international arrivals to 5.7 million. Figures from the World Travel & Tourism Council (WTTC) show that the total Travel and Tourism sector in Greece grew by 6.9% in 2018 – well over three times the national economy growth rate – and contributed the equivalent of $44.6 billion to GDP. This represents a record 20.6% of Greek GDP, compared with a global average of 10.4%.


Advantages of the Greece Golden Visa Program include:

A minimum of just €250,000 must be invested in real estate, making this one of the most accessible investment immigration policies in Europe. Note that this excludes legal fees and taxes; new property purchases are subject to 24% VAT. Any number of properties may be combined to make up the minimum required investment and joint buyers may also combine their investments into one higher-priced property. Applicants must have a clean criminal record and have medical insurance covering their stay in Greece. Residency can be obtained within 60 days and is valid for five years, which can be renewed every five years thereafter provided the applicant still owns the property.

• No requirement to actually reside in Greece

Citizenship and a Greek passport may subsequently be applied for, but only after seven years of actually living in Greece, whereas to qualify for a residency card does not require the holder to live in Greece.

• Residence permits can be acquired within 30–60 days • Visa-free travel within Europe’s Schengen Area • Unlimited expiry date of residence permit, subject to continued property ownership • Opportunity to rent out the investment property • Residence applies to the whole family (married spouse, children under 21 years old, and parents of the main applicant and spouse) • Permit holders may hold shares and receive income from the dividends of a company registered in Greece; however, they are not allowed to be employed in Greece.

Chart 1. Golden Visa Approvals in Greece by Year Number of approved applications

Chart 2. Greece’s Approved Residency Permits by Country of Origin



China (2,757)


Russia (428)

2% 2% 2%

Turkey (413)



Egypt (132)


Lebanon (125)





Iran (92) Ukraine (85)




968 1399

751 423 423

0 2013






Main applicants

60 Citizenship By Investment




Iraq (85) Jordan (69) Others (349)



Family members

2019 H1

Data from July 2013 to 4th June 2019 Source: Enterprise Greece /Ministry for Migration Policy

GREEK GOLDEN VISA STAKEHOLDERS REJOICE AS NEW GOVT. ELIMINATES VAT ON PROPERTY INVESTMENT Greek property just got a whole lot cheaper for foreign investors. The country’s new center-right government has declared it will not collect VAT on real estate investments for the next three years. Still 25% below its pre-crisis peak, Greece’s GDP is set to grow by more than 2% this year. Newly elected Prime Minister Kyriakos Mitsotakis of the center-right New Democracy party ran on a platform of tax cuts and spending increases – diametrically opposed to the policies of his far-left predecessors.

going again after many of the country’s developers faltered for a lack of liquidity during the crisis years.

The new government, elected on July 7th, committed to making across-the-board tax reductions a “key priority”, has already begun to make good on its promises. While Mitsotakis has presented a slew of tax cuts applicable to all tax-paying Greeks, the announced reforms are particularly welcome to those in the property sector, to which the country’s golden visa market is inextricably tied.

“So the only people buying property now are those who can afford to pay cash upfront, which is to say the buyers are generally either Greeks who have saved up funds that they don’t know where else to put [deposit rates and equity markets are of little interest], institutional investors, or foreigners,” factors making the upward trend more sustainable.

On July 21st, Mitsotakis announced an immediate 22% reduction in property tax with an aim to lower it by a total of 30% during his first two years in office. He also plans tax deductions of up to 50% for renovation and property investment over the next three years, as well as a three-year tax holiday on real estate capital gains and on VAT for construction-related activity. Panos Rozakis, CEO of Prime Synergy, a Greek property and residence specialist, highlights the three-year pause in construction-related VAT as a measure that will help boost interest in Greece’s golden visa program. “VAT, up to now, was at 24% and applied to real estate buyers who a) did not use the property as their primary residence and b) were not Greek. Naturally, eliminating this will have a very positive effect on foreign interest in Greek real estate, which was growing tremendously to begin with,” says Rozakis, who hopes it will get construction

“This is a very different bull-market,” he continues. “Back in 2006, credit was cheap and easy to get. Anybody could get a loan. These days, banks essentially don’t lend out any money to private buyers,” a phenomenon he attributed partly to the lack of capital to lend out among many banks and partly to EU restrictions.

Rozakis is careful to point out that the Greek housing price index – which, although it began pointing upward in 2017, is still some 40% below its pre-crisis peak – does not adequately capture wide divergences in the Greek market. Rozakis believes this is the right time to buy property in Greece, and that low prices won’t last. Four particular factors support his prognosis:

by CHRISTIAN HENRIK NESHEIM IMCM Founding editor Investment Migration Insider www.imidaily.com

• Prices are still far below their 2006 peak • Many people who want to buy cannot buy because mortgages are virtually impossible to come by • A three-year tax holiday on VAT and property-related capital gains has just been instated • Chinese investor interest in Greece is at an all-time high. While Rozakis emphasizes that not all the price growth is thanks to growing foreign interest, he acknowledges that it’s playing a big part. “A few years ago, all the news about the Greek market was bad and foreign clients were calling me asking if they should sell. Now, it’s exactly the opposite. As to the sellers, everybody seems to be imagining that a Chinese buyer is going to knock on their door and pay ridiculous money for their flat. And it’s not always just a pipe dream; some Chinese buyers really do overpay for their Greek real estate,” an occurrence that, he explains, has become more frequent as Chinese companies buy property in bulk on the cheap only to later flip it to Chinese individual investors with – some would say – unconscionable markups.

Same crisis, different reactions - Housing price indices, Portugal and Greece Portugal


130 120 110 100 90 80 70 60







2019 Q1

Chart: Investment Migration Insider - Source: Bank of Greece, Statistics Portugal

61 Citizenship By Investment

Country Spotlight



Full name: Republic of Malta Capital city: Valletta Population: 493,559 (31 December 2018) GDP in Current Prices: USD $14.54 billion (2018) GDP real growth: 6.6% (2018) Area: 316 km2 Government: Unitary parliamentary constitutional republic President: George Vella Prime Minister: Joseph Muscat Currency: Euro (€) (EUR) HDI: 29th (2018) – “very high” Ease of doing business index: 84th (2018/19) Time Zone: GMT + 1 Dialling code: 356


he Republic of Malta is a small South European island country that lies approximately 80 miles south of Italy and 207 miles north of Libya. Malta is an archipelago in the Mediterranean Sea, but only the three largest islands of Malta, Gozo and Comino are inhabited. The landscape of the islands is characterised by terraced fields, dry vegetation, rock and limestone. This is due to the long hours of strong sunshine that they receive throughout the summers, which are usually dry and hot. The average annual temperature is around 23°C.

Malta is the 10th smallest country by land area and one of the most densely populated nations in the world. Its capital Valletta is the smallest national capital in the European Union. Maltese and English are the official languages, although Italian is also widely spoken. History Malta is a popular tourist destination due to its warm climate and its architectural and historical heritage. The islands have been inhabited since around 5900 BC and some of the Megalithic Temples of Malta are UNESCO World Heritage sites. Malta’s location in the middle of the Mediterranean has historically given it great strategic importance as a naval base and a crossroads between Europe, North Africa and the Middle East. A succession of powers, including the Phoenicians, Carthaginians, Greeks, Romans, Byzantines, Arabs, Normans, Sicilians, Spanish, French, and British have ruled the islands, each adding to the distinctive cultural mix.

62 Citizenship By Investment

Malta is particularly known for its connection with the Order of the Knights of St. John, who were given the island by the Spanish king Charles V in 1530. They introduced the Italian language to the island, built the city of Valletta, and developed the cultural and economic links through the region. The official state religion of Malta is Catholicism, with the island having a long Christian legacy dating back to around AD 60 when St. Paul was shipwrecked in Malta whilst traveling from Jerusalem to Rome and stayed there for three months. After briefly falling under Napoleon’s rule in 1798, the Maltese managed to oust the French rulers with British help and they voluntarily became a British protectorate in 1800 and a Crown colony of the British Empire in 1813. The importance of their location greatly increased after the opening of the Suez Canal in 1869. During the early years of the Second World War, Malta came under concentrated bombing and naval siege by the Axis powers – so much so that in 1942 King George VI awarded the whole Maltese population the

George Cross in recognition of their bravery. A depiction of the medal is incorporated onto Malta’s national flag. Malta gained independence from the United Kingdom on the 21 September 1964, whereupon it joined the Commonwealth and the United Nations. On 13 December 1974 Malta became a republic with the President as head of state and adopted a policy of neutrality in 1980. It joined the European Union in 2004 and on 1 January 2008 it became part of the Eurozone. Politics The parliamentary system is closely modelled on the Westminster system. The parliament is made up of the president, a prime minister and the multi-party House of Representatives. The country is divided into five regions – including Gozo and Comino which are classified as one region – with each having its own Regional Committee which serves at an intermediary level between local government and national government. The House of Representatives consists of 65 members, with five members being elected from each of the thirteen electoral districts. The role of the President of Malta is largely ceremonial, and he or she is appointed by the House of Representatives for a five-year term. The President appoints a Prime Minister, selecting a member

of the House of Representatives who is judged to be best able to command the support of the majority of its members. The current President is George Vella, who was sworn in on 4 April 2019. The current Prime Minister is Joseph Muscat, leader of the Labour Party, who was re-elected on 3 June 2017, with the main opposition leader being Adrian Delia, leader of the Nationalist Party. The next general elections are scheduled to be held by 2022. Economy Malta is a highly industrialised, highincome, advance service-based economy and is listed within the top 30 countries by the International Monetary Fund (IMF). Malta’s real GDP growth in 2018 of 6.6%, compared with 6.7% in 2017, was one of the highest growth rates in the EU and was mainly attributable to domestic demand. Malta’s main advantage has always been its central location for trade, and the economy reflects that. Being a small island nation, it has limited natural resources and can only produce around 20% of the food requirements for its relatively large population. The economy therefore is dependent on human resources and foreign trade. Malta’s economy is driven by financial services, tourism, real estate, and manufacturing, particularly of electronics. Other significant sectors are pharmaceuticals, information technology and call centres. Ahead of its entry to the EU, the Maltese Government pursued a policy of gradual economic liberalisation and privatisation, taking steps to shift the emphasis from reliance on direct government intervention and control to policy regimes that allow a greater role for markets. In 2007 the government sold off its 40% stake in ‘MaltaPost’, and by 2010, Malta had managed to privatise its telecommunications, postal services, shipyards and shipbuilding. Malta produces almost all its electricity from oil, and energy costs, which are some

of the highest in Europe, have become an issue. The government is looking into the potential of solar and wind power and Malta and Tunisia are currently discussing the commercial exploitation of petrochemicals on their shared continental shelf.

France the next most important markets. The total tourist expenditure was estimated at nearly €2.1 billion, an increase of 8.0% year-on-year. In 2017, travel and tourism contributed 27.1% of Malta’s GDP compared with 21.6% in 2009.

Malta has managed to maintain a relatively low unemployment rate of less than 4%, mainly because of constant economic growth and by policies encouraging continuous training for the labour force. Malta ranks high on global inward foreign direct investment comparisons and is among the top twenty countries most likely to sustain economic growth. Malta didn’t suffer in the same way as other jurisdictions during the Eurozone crisis, because of low debt and sound banking. Malta regularly ranks within the top 30 financial systems on the World Economic Forum’s Global Competitiveness Report and placed 36th overall in the 2018 Global Competitiveness Index.

There are currently five times more tourists than there are residents. The increased numbers of visitors have increasingly stretched resources and put pressure on the existing infrastructure (such as water, waste management, hotels, beaches and roads), with overcrowding especially during the peak summer months. Consequently, the Malta Tourism Authority (MTA)and the Ministry for Tourism have been promoting cultural tourism and festival tourism as ways to attract visitors during all months of the year rather than just the summer months.

Another major factor in Malta’s economic growth has been its property market, helped by the fact that Malta does not have a property tax. Because of pressure from population growth and foreign direct investors, the property market has been in constant boom, especially in towns like St Julian’s, Sliema and Gzira and around the harbour area. Tourism Malta relies heavily on tourism and 2018 has again seen record-breaking arrival numbers. Tourist arrivals and foreign exchange earnings derived from tourism have steadily increased over the last 30 years. 2018 brought 2.634 million inbound visitors to the country, 13.8% higher than in 2017 and more than twice the 2008 total of 1.291 million. The United Kingdom and Italy remain Malta’s most important source markets, accounting for 24.7% and 16.0% of total visitors, respectively, with Germany and

As part of the Schengen Area, visitors to the EU can travel freely. While Malta cannot unilaterally drop the requirement for nations it makes agreements with to obtain visas to enter the Schengen Area through its border crossing points, it is permitted to offer visa facilitation agreements to some nationalities. Transport The main mode of public transport in Malta is bus, offering a cheap and frequent service to many parts of Malta and Gozo with the majority of buses departing from a terminus in Valletta. There are also frequent daily car and passenger ferry crossings between Malta and Gozo. Malta has just the one airport, located approximately 5 miles southwest of Valletta, through which 96.9% of its international visitors arrived last year. The rest come by sea. Malta has three large natural harbours, one of which – Malta Freeport on the south-eastern side of the island – is the 9th busiest container port in Europe.

63 Citizenship By Investment

CITIZENSHIP BY INVESTMENT Malta currently has two investment migration programmes: • The Malta Individual Investment Programme (MIIP) for citizenship

Eligibility To be eligible for citizenship by investment, applicants must: • Be over 18

• The Malta Residence Visa Programme (MRVP) for permanent residency.

• Be in good health

MIIP for Citizenship

• Have a clean criminal record

Introduced at the beginning of 2014, the Malta Individual Investment Programme (MIIP) offers high- and ultra-high-networth-individuals worldwide citizenship in a highly respected EU member state.

• Not been refused a visa for a country with which Malta has visa-free arrangements.

Gaining citizenship in Malta via investment is a simple, quick process which can allow the entire family to immigrate with ease. Citizenship is typically approved after just four months processing time. Family eligibility extends to parents of the applicant and spouse, minor children and unmarried adult children under 27. Descendants gain citizenship automatically. Since its inception five years ago, the MIIP has raised more than €1 billion in revenue for the government. As of June 2019, over 1,000 applications have been made from more than 40 different countries. The original IIP regulations put a cap of 1,800 successful applicants (excluding dependents) for the duration of the programme, so they have reached more than half the pre-established target. However, it should be pointed that Malta exercises tight due diligence; on average, one in five applications fail for whatever reason as Malta strives to be more transparent and more exclusive.

64 Citizenship By Investment

The main applicant is required to contribute €650,00 to Malta. Spouses and children are required to contribute €25,000 each and unmarried children between 18 and 25 and dependent parents are required to contribute €50,000 each, although these contributions can be made after application approval. Applicants are required to invest at least €350,000 in purchasing property or to enter a rental property agreement for at least €16,000 p.a. on five year contract. Applicants are also required to invest €150,000 in bonds or shares. The investments must be in Stock sanctioned by the Maltese government. Applications can be supported by a genuine link to Malta through residence. MRVP for residency Malta’s Residence Visa Programme was launched in spring 2017, and received over 1,000 applications during its first eighteen months, with 250 (main applicants) visas approved by July 2018. To be eligible, applicants must be nationals of a non-EU/EEA country and be able to prove that they either have an annual income of at least €100,000 from outside Malta, or have capital assets of not less than €500,000. In addition, the applicant must:

• Make an investment of €250,000 in Government bonds or accepted securities/shares on the Malta Stock Exchange; the investment must be retained for a minimum period of five years • Purchase or rent a property for a minimum value of €270,000 or yearly rental of €10,000 in the south of Malta or on Gozo, or a minimum value of €320,000 or yearly rental of €12,000 if the property is in the north of Malta • Make a contribution to the government of €30,000, of which €5,500 is a non-refundable administrative deposit and must be paid upon submission of the application; once it is established that the beneficiary qualifies for such status, the balance of the contribution must be paid. Benefits of Maltese Citizenship A successful application for Citizenship by investment in Malta gives the right to live, work and study in any country in the European Union and Switzerland, plus visa-free travel to over 180 countries. The Maltese tax system is based on domicile and residence, rather than citizenship. Tax is only due on income and capital gains arising in Malta. After a period of five years, property can be sold in Malta completely tax free, so long as it was the resident’s sole residence for at least three years. If selling the property before three years of residence, a tax of 12% is charged on the selling price. In addition, there are no inheritance or death taxes, no net worth or wealth taxes, no municipal taxes, rates or real estate taxes and no estate duty. With tax benefits such as these, a stable economic climate and banks ranked as some of the most stable in the world, investment in Malta is a sound way to gain citizenship.

Country Spotlight



Capital city: Podgorica Population: 622,182 (1 January 2019) GDP in Current Prices: USD $5.4 billion (2018) GDP real growth: 4.5% (2018) Area: 13,812 km² (land 13,452 km²) Government: Unitary parliamentary constitutional republic President: Milo Dukanovic Prime Minister: Dusko Markovic Currency: Euro (€) (EUR) HDI: 50th (2018) Ease of doing business index: 50th (2018/19) Time Zone: GMT + 1 Dialling code: 382


ontenegro is a small but proud country in Southeastern Europe, located on the Adriatic coast. A former member of the Socialist Republic of Yugoslavia, Montenegro is bordered by Croatia to the west, Bosnia and Herzegovina to the northwest, Serbia to the northeast, the disputed country of Kosovo to the east, and Albania to the south. The country has a picturesque coastline stretching for 295 kilometres, including 75 kilometres of popular beaches and many well-preserved ancient towns and fishing villages. By contrast, the north of the country features some of the most rugged terrain in Europe, with mountain peaks averaging more than 2,000 metres above sea level. Montenegro enjoys a Mediterranean climate and averages 240 days of sunshine a year. The country’s name actually means ‘Black Mountain’ and is reputed to derive from the appearance of Mount Lovcen (elevation 1,749 m) when covered in dark dense forests. History As a territory, Montenegro’s history dates back to pre-Roman times. Because of its geographic location between west and east, dating back to the division of the Roman Empire in 286 between the Western Roman Empire and the Eastern Roman Empire (which would later become known as the Byzantine Empire after the fall of Rome in 476), Montenegro has seen many diverse cultures and political regimes. Between 1496 and 1878, large parts of the modern-day country were under the control of the Ottoman Empire, while the Republic of Venice controlled much of the coastal region until 1797. During the 19th and early 20th centuries, Montenegro was a principality and briefly a Kingdom (1910-1918) during the tumultuous years of the Balkan Wars and World War I, after which, and with the king in exile, a resolution was passed

uniting Montenegro with Serbia on 28 November 1918. This in turn led to the creation of Yugoslavia, which by the time the dust of World War II had settled, was a communist socialist republic (1945-1992), of which Montenegro was the smallest of six constituent republics. Following the dissolution of the former Yugoslavia in April 1992, Montenegro joined with Serbia in establishing the Federal Republic of Yugoslavia (FRY) and applied to take over Yugoslavia’s membership of the United Nations as the sole legal successor. However this claim was opposed by the other former Yugoslav states and the request was officially denied. Bosnia and Herzegovina, Croatia and Slovenia were admitted to the UN in May 1992 and Macedonia was granted membership in April 1993 pending a settlement with Greece over its name (since changed to North Macedonia with effect from February 2019).

Political relations between Serbia and Montenegro soured during the mid-1990s but were restored after the Serbian leader Slobodan Milosevic was ousted from office in the 2000 presidential elections, following which the FRY reapplied for, and was granted, membership of the United Nations on 1 November 2000. In 2002, Serbia and Montenegro entered a new agreement for cooperation and the following year the FRY was renamed Serbia and Montenegro, with a proviso that any referendum on independence of Montenegro would be delayed for at least three years. That referendum came on 21 May 2006, when 55.5% of the votes cast (within an 86.5% turn-out) voted for independence. The referendum was monitored by several international observer missions headed by the Organization for Security and Co-operation in Europe (OSCE) and proceeded peacefully, meeting all compliance

65 Citizenship By Investment

checks. Montenegro’s parliament declared its independence on 3 June 2006 and, with no objections from Serbia, the independence of Montenegro was ratified and, three weeks later, Montenegro was admitted to the UN in its own right. Montenegro has been negotiating with the European Union since 2012 to become a full member of the EU, having been granted candidate status in 2010. Following the decision to drop the Yugoslav dinar as its official currency in 1999, Montenegro has been unilaterally using the euro since 2002, despite concerns raised by the European Central Bank. However, it looks likely that these and other issues will be resolved by 2025 when Montenegro is expected to be granted full membership of the EU. Infrastructure The country is divided into three regions and 24 municipalities, following the transition of Tuzi into an independent municipality from 1 September 2018. The Central region is the most populous region and now has five municipalities including Podgorica, which is not just the administrative centre of Montenegro, but also the main economic hub. The biggest region by area is the Northern region with 13 municipalities, while the Coastal region has six municipalities including Bar, which is a major tourist destination with its 20 beaches stretching over 9 kilometres, mostly surrounded by pine forests and olive groves. Although the country has an extensive rail and road network, Montenegro lacks a proper motorway network and the construction of new motorways is a stated

66 Citizenship By Investment

priority of the government. One of its biggest and most ambitious projects is the construction of a 165 km highway with a permanent supply of electricity linking the seaport of Bar to Boljare, Serbia, through the imposing mountains north of Podgorica. The government hopes that the new highway, the first phase of which has been funded by China, will provide an economic boost to the northern region and bolster trade with Serbia. In addition, the EU has contributed millions of Euros in aid for transport and environmental projects as part of its pre-accession assistance programme for EU candidate countries. Economy and tourism Since gaining independence, Montenegro’s economy has been transitioning to a market economy and has been growing steadily for the most part. The World Bank classifies Montenegro as an upper middleincome country. By 2015, around 90% of Montenegrin state-owned companies had been privatised, including all its banking, telecommunications, mining and oil distribution. Montenegro’s economy grew by 4.5% during 2018, following 4.7% growth in 2017, giving a nominal GDP of $5.4 billion. The economy is mostly service-based, with Services comprising 71% of GDP, Industry 21% and Agriculture 8%. Foreign Direct investment accounted for 11.7% of GDP in 2017, with tourism, real estate, energy, telecommunications, banking and construction attracting most of the FDI inflow. However, the Central Bank in Podgorica recently reported that the net inflow of FDI into Montenegro dipped from €484.3 million euros in 2017 to €327.6 million in 2018. The biggest

foreign investors in Montenegro are Russia, Italy, Cyprus, Denmark, Hungary and Serbia. Tourism, having been hit severely by the Balkan Wars, started recovering in 2003 and has been a key driver of the Montenegrin economy. In 2009, Montenegro – ‘the pearl of the Balkans’ – was cited as one of the top places to go to in 2010 by the New York Times and Yahoo Travel. Having breached the one million mark in 2008, the number of international tourists arriving into Montenegro has continued to rise each year, with 2017 setting a new record of 1,877,212 foreign arrivals – up by 12.9% over the previous year. Figures just released by the Montenegro Statistical Office reveal a further 10.6% year-on-year increase in 2018 to pass the two million mark. Of the 2,076,803 foreign visitors, approximately 90% were from Europe, with 19.7% coming from Serbia, 16.3% from Russia and 9.3% from Bosnia and Herzegovina. The total contribution of Travel & Tourism represented 23.7% share of GDP in 2017 and is forecast by the World Travel & Tourism Council to rise to 27.9% share of GDP by 2028. The sector is also a major employment contributor, directly supporting 14,500 jobs in 2017 (equating to 7.6% of total employment) plus a further 22,000 jobs indirectly supported by Travel & Tourism. By 2028, the WTTC forecast that the contribution will rise from 19.3% in 2017 to 21.5% of total employment. Montenegro has one of the lowest corporate tax rates at just 9% and foreign companies receive equal treatment to domestic companies, making Montenegro an attractive proposition for business investors.

RESIDENCY AND CITIZENSHIP BY INVESTMENT In July 2018, the government of Montenegro announced that it would be launching its own Special citizenship by investment programme (SCIP) for non-EU citizens. The window for applications opened on 1 January 2019 and is designed to last for a limited period of three years. A statement issued by the government said that “the programme aims to further accelerate Montenegro’s economic development by creating new tourist, agricultural and processing capacities and creating new jobs.”

€100,000 to a government fund for the development of poor communities. In addition, all applicants are required to invest in approved real estate projects with a choice of two levels: • €450,000 for projects in the coastal region or in the capital Podgorica • €250,000 for projects in the north or central Montenegro.

The government has applied a cap of 2,000 applications and applicants must provide documents supporting the source and origin of invested funds.

There are also government fees of €15,000 for single applicants, and €10,000 for each family member up to a maximum of four. Thereafter, each next family member must pay €50,000.

To qualify for citizenship, applicants must make a non-refundable contribution of

The procedure is fast, in that permanent residency may be granted within three

weeks. Citizenship and a Montenegrin passport is granted within six months for approved qualified investors after due diligence checks and the names of successful applicants will be published in a gazette. The benefits for Asians of having a passport from Montenegro are that, apart from its strategic location between Europe and Asia with direct access to the Adriatic Sea, there is no obligation to relinquish current nationality and there are no language requirements. A Montenegrin passport gives enhanced global mobility with access to 123 countries including the EU Schengen states. In addition, the country already uses the Euro as its currency and has applied for membership of the EU.

67 Citizenship By Investment

BENEFITS OF RESIDENCY IN PORTUGAL About RAX Boutique Portugal  (Real Assets Exchange) RAX Portugal (Real Assets Exchange was founded in 2015 as a partnership of  Gobusiness group in the real estate area, with the particular goal to address existing needs and gaps in the market concerning the creation of opportunities and value for individual and institutional investors. We provide global investment solutions, through a network of international partners that use Rax Boutique, as a vehicle to present and promote investment opportunities. RAX Portugal (RAX) embraces all real estate areas, urban and rural. It operates in every region of Portugal and different parts of the world. We are experts in client services. RAX works with the best agents, lawyers, construction companies in Portugal.

way. Given that we have partners in different areas, it allows us to be totally independent and have the ability to reach all the real estate market. RAX is your reliable real estate agency, offering boutique services to find the best solutions in accomodating each particular client’s needs, in a way that all their problems disappear. In every stage of the process, RAX is always at the side of the client, before, during and after the property is acquired. After the acquisition/investment, the client needs to be followed by a specialist in the area who takes into account his particular goals and that deals with the whole process, in a strict manner. Taking all these issues in consideration, RAX has created different solutions, customised to the needs of each client:

According to the required features, our work is to find the property that every client/investor wants. RAX’s goal is to satisfy the needs of every client/investor, in a detailed, customised and innovative

• • • • •


NHR (10 years)

Golden Visa

Tax advantages

To get a temporary residency permit for investment activities. • Move freely in the Schengen Area • Apply for permanent residency in Portugal • To live, work and study in Portugal

Setting up support in Portugal Decoration support Investment and return Wealth Protection Golden Visa cost of €350,000

Be a tax resident in Portugal.

• 20% tax rate on some employment and self-employment income • Elimination of double taxation • 0% taxation on pension income

• Acquisition of property • Investing in companies

Acquisition of property - possibility to acquire different types of properties, on different places – offices and/or tourist complexes/resorts.

68 Citizenship By Investment

RAX Boutique Portugal

If you need a provider for a unique and exclusive service contact us RAX Portugal www.raxboutique.com ps@raxboutique.com + 351 9690 64767



Portugal ranks second in terms of quality of life.

Source: InterNations - Quality of Life Index 2018

• 0% taxation on certain categories of income (example: interests and dividends received from abroad) Attractive investment opportunities (Golden Visa and Non Habitual Residents)

Move freely in the Schengen Area - in conducting business, contacts or simply when travelling for leisure or work.

PAULO SILVA Founding Partner


Portugal ranks as the fourth most peaceful country in the world

Source: Institute for Economics and Peace - Global Peace Index 2018


Portugal ranks fourth in the cost of living ranking

Source: InterNations - Cost of Living 2017

Country Spotlight



Full name: Portuguese Republic Capital city: Lisbon Population: 10,276,617 (2018) GDP in Current Prices: USD $238.5 billion (2018) GDP real growth: 2.1% (2018) Area: 92,212 km² Government: Unitary Semi-presidential constitutional republic President: Marcelo Rebelo de Sousa Prime Minister: Antonio Costa Currency: Euro (€) (EUR) HDI: 42nd (2018) Ease of doing business index: 34th (2018/19) Time Zone: GMT + 0 Dialling code: 351


ortugal is the westernmost sovereign state of mainland Europe, located on the Iberian Peninsula, bordered by Spain to the north and east and by the Atlantic Ocean to the west and south. It is one of the most geographically diverse countries in Europe with mountain ranges, valleys, national parks, beautiful beaches and abundant wine regions. Portugal’s climate is described as a Mediterranean climate and is one of the warmest countries in Europe with over 3,000 hours of sunshine a year. The annual average temperature varies from 12°C in the mountainous northern highlands to 22°C in the southern coastal areas, with average high temperatures in the popular Algarve region ranging from 16°C in January to 29°C in July. The fact that much of the country faces the ocean has influenced many aspects of its culture – its beautiful beaches are a very popular tourist destination and much of the country’s architecture is rooted in its rich history which harkens back to its naval past, influenced and paid for by its colonial possessions at a time when Portugal was one of the world’s major economic, political and military powers. Portugal is one of the safest countries in the world. It overtook Austria to rank as the 3rd most peaceful country in the world behind Iceland and New Zealand on the 2019 Global Peace Index rankings, and for the past ten years it has consistently been listed as one of the 30 most prosperous nations of the world (24th in 2018) on the Legatum Prosperity Index.

History Portugal has a rich history dating back to Roman times. Its foundation as the Kingdom of Portugal dates back to 1139, when Alfonso I was acclaimed King of the Portuguese internally and four years later was recognised by its neighbours through the treaty of Zamora. Portugal’s independence was formally recognised by Pope Alexander III in 1179 and the country remained a monarchy until 1910. During the late 14th century, Portugal embarked on a period of naval exploration, and this resulted in voyages which pushed the bounds of European knowledge across the Atlantic Ocean, along the African coast and beyond the Cape of Good Hope. Vasco Da Gama’s discovery of the sea route to India in 1497-1499 was significant in that he was the first European to connect the Atlantic and Indian oceans, paving the way for a period of global imperialism and enabling the Portuguese to create a colonial empire in Asia that was largely unchallenged for several decades. Meanwhile, Pedro Alvares Cabral landed in Brazil on 22 April 1500 and claimed

possession of the land in the name of the King. Throughout the 15 and 16th centuries, the Portuguese empire grew, as it largely monopolised the spice trade worldwide, thus creating immense wealth and expanding Western influence across the globe. However, disaster struck when, on 1 November 1755, its capital city Lisbon was completely destroyed at the hands of a violent earthquake, tsunami and subsequent fires. Then in 1756, a global conflict, which became known as the Seven Years’ War, broke out, during which Spain invaded Portuguese territory. After that, Portugal lost much of its power to other naval states like France and Britain. Brazil declared its independence in 1822 – formally recognised in 1825 – and after losing all its territory in South America, Portugal focused primarily on its African territories and a few in Asia including Macau, which remained a Portuguese colony until 1999 when it was handed back to China as a special administrative region. The dawn of the 20th century brought state bankruptcy, economic turmoil and social unrest. On 1 February 1908, King Dom Carlos I was assassinated along with his eldest son and heir apparent. The youngest son became King Manuel II, but was eventually overthrown during the 5 October 1910 revolution and Portugal became a constitutional republic.

69 Citizenship By Investment

Portugal was one of the few European nations to remain neutral during World War II, but the succeeding years saw several armed conflicts in its overseas territories and a mass exodus of Portuguese citizens from its African territories including Angola and Mozambique. By 1975, all its African territories were independent and in 1976 Portugal held its first democratic elections in 50 years. Politics

bilateral political capital to increase trade and investment and to partner together in science, technology, culture and education. Over recent years, trade has grown steadily and is relatively balanced with over 600 Portuguese companies having a presence in Brazil and an increase in Brazilian investment in Portugal. Co-operation between the countries extends across the areas of innovation, nanotechnology, biotechnology and energy production. Economy

Portugal is a parliamentary republic based on the 1976 constitution, amended in 2004. The government holds the nation’s sovereignty and not only has executive powers but also limited legislative powers, mainly concerning its own organisation. The parliament is known as the Assembly of the Republic with 230 deputies who are elected for a maximum term of four years. The legislature is elected by proportional representation, used in 20 multimember constituencies. Power is shared between the president, the assembly, the government and the courts. The country is a member of the European Union since 1986 and was a founding member of NATO, the eurozone and the OECD. It enjoys a high standard of living, has a low crime rate, little corruption, press freedom, social progress, prosperity. It is now a secular state with one of the world’s highest rates of moral freedom. Portugal is also a full member of the Latin Union and has a dual-citizenship treaty with its former colony Brazil. Sharing a long history and a common language, there is a mutual interest in using their

70 Citizenship By Investment

Portugal is a developed high income country. With a population of 10.3 million, Portugal currently ranks as the 88th most populous country in the world, but its GDP of $238 billion (2018) is the 49th highest and ranks 40th highest by GDP per capita ($23,186 nominal). Portugal saw real GDP growth of 2.1% in 2018, which is lower than the 2.8% growth in 2017 but still ahead of the EU average. The majority of industries, businesses and financial institutions have traditionally been located around Lisbon and Porto, but after the revolution in 1974, their most notable era of economic expansion ended and since they have tried to adapt to the changing modern global economy, a process that is successfully continuing still. There is now more focus on exports, private investment and developing a high technology sector. Having suffered from a severe recession and the indignity of accepting a bail-out in 2011 (which they have now exited), the national commitment to a reformist momentum endures and un-

employment continues to fall. The World Economic Forum places Portugal 34th on its 2018 Global Competitiveness Index, a significant rise from 51st in 2013. Portugal is a notable producer of minerals particularly copper, tin, tungsten and uranium. Lithium is also mined from their subsoil. Portugal is among the top ten producers of lithium, which is increasingly sought after by manufacturers of electric cars and mobile phones who use the element in their batteries. There is great interest in exploring lithium deposits further in the areas from Alto Minho to Beira Baixa, passing through Trás-osMontes, where Dakota Minerals already is mining the ‘white oil’ in a €370m investment. One of the country’s main exports is wine and it is the 11th largest exporter in the world by volume. The genesis of this trade dates back to the Roman Empire. Its wine-producing regions, the Douro valley and Pico Island, are protected by UNESCO and offer a large selection of different wines from a vast array of grapes, all distinctive due to variations in soil and climate. Portugal’s industry is diversified, ranging from textiles and food to automotive and aerospace, and investment is growing strongly in the biotechnology and IT sectors. Research grants are prolific, particularly for neuroscience and oncology. The country has a strong infrastructure with widespread broadband connectivity and it is also a leader in electronic payments. There is an open door to a market of 500 million and the country is currently ranked joint-highest in the World Bank’s

Trading Across Borders Rank. Portugal has a highly developed motorway network and a port system among the best in the world. (Sines was recently the fastest growing container port in the world). Porto Airport was named as the 3rd best European airport in 2013 while the Atlantic Corridor is a rail freight line across Europe which is among the best in the world.

foreign visitors, of whom 1.83m were from the UK, followed closely by 1.75m from Spain. Tourism and travel revenues now account for 10% of Portugal’s GDP and this is forecast to continue growing with more hotels and more daily direct flights from the US being added. Portugal has also been declared Europe’s leading destination for golf. Living in Portugal

Tourism Tourism remains extremely important to the country and it is one of the top 30 most visited countries in the world. The number of foreign arrivals has been growing steadily since 2009, attracted by breathtaking landscape, glorious beaches, fine cuisine and even finer wines! 2017 brought in a record number of 12.7 million foreign tourists, an increase of nearly 12% over 2016 and almost twice the 2009 figure of 6.4 million. Despite fears that the number of inbound tourists f rom the UK may go down because of Brexit, Portugal saw a further 0.4% increase to push the record to 12.8 million

A large majority of Portugal’s citizens are Roman Catholic but it is home to a large number of small communities representing different faiths and so it gives off a welcoming impression to all who grace its borders. The official language is, of course, Portuguese derived from early Latin. Although if Portuguese is not your first language, you should not fear as according to the latest EF English Proficiency Index, Portugal has a high proficiency level in English, higher than in countries like Italy, France or Greece. Many people, after spending time in Portugal, come to the conclusion that

they would like to live there permanently. To these people, there is some good news as citizenship by investment is entirely possible in Portugal, but you will need to invest a minimum of €500,000 in order to qualify for a “golden visa”. Once you have acquired a golden visa, it is then possible to apply to become a citizen of Portugal after six years. In comparison to other some other EU countries, the minimum cost of investment is a little higher, but there are many benefits to Portuguese citizenship, including low tax rates, low minimum stay periods and, of course, the benefits of a climate and culture that are in-line with each other – easy going, with hot periods. While being a more expensive option than some of its neighbours, Portugal offers investors a warm and friendly climate, gorgeous coastlines and vibrant cities in which to seek residence. Diverse, beautiful and culturally arresting, Portugal, in many ways, offers bits of the best of all of Europe.

CITIZENSHIP BY INVESTMENT Routes to CBI in Portugal • Property Investments: - Acquisition of property above €500,000. - Acquisition of property above €350,000 – for properties more than 30 years old or located in areas of urban renovation.

Once issued, the Golden Visa will be valid for an initial period of one year and then will be renewed for subsequent periods of two years. The simplicity of the Golden Visa Programme implies an extremely reduced amount of requirements being asked from the investor. The Golden Visa Programme sets out that the investor must comply with general requirements applicable to all types of qualifying investments and also with the specific requirements of each type of qualifying investment.

• Capital Investments:

In general, all investors have to comply with the following requirements:

- Transfer of funds above €1,000,000.

- Creation of a minimum of 10 jobs.

- Transfer of funds above €350,000 for research activities.

- Keep the investment for a minimum period of five years

- Transfer of funds above €250,000 for artistic or cultural activities.

- Funds for investment should come from abroad

- Transfer of funds above €500,000 for capitalisation of small and medium-sized companies. • Job creation: - Creation of a minimum of 10 jobs.

- Entry in Portugal with a valid Schengen visa - Absence of references in the Portuguese Immigration and the Schengen services - Absence of conviction of a relevant crime - Minimum stay in Portugal: seven days during the first year and 14 days during each subsequent period of two years.

71 Citizenship By Investment

THE PORTUGUESE GOLDEN VISA OR RESIDENCE PERMIT Filipe Espinha attorneys-at-law is a law practice office based in Lisbon, Portugal. We work to deliver smart legal solutions that contribute to transforming our clients’ realities. Our human capital is highly capable of offering integrated solutions that combine expertise in various areas of law to solve problems, create and preserve value for clients. We preserve the values of ​​ legal intelligence, commitment, courage and proactivity to build a relationship with our clients based in proximity and empathy. Our culturally diverse team has a fundamental knowledge of Portuguese speaking countries, European and International cultures, laws and jurisdictions, offering services in several languages. We believe to be a reference for our clients from all over the world, representing them in a broad range of matters. Our clients include multinationals, foundations, associations, companies, SMEs, entrepreneurs and families. To better serve our customers, we have partnerships and network with colleagues worldwide. We offer a wide range of legal services for individuals, businesses and industries such as: • Corporate, commercial and business advice • Employment, residential and commercial property transactions, Litigation and dispute resolution • Migration and citizenship • Tax (including personal and offshore companies) • Wills, probate and trusts (including family trusts).

Website: www.filipeespinha.pt Tel: (+351) 215 809 150 Fax: 215810699 Email: agenda@filipeespinha.pt

72 Citizenship By Investment

programme: The Residence Permit for  Investment Activity or the Golden Visa Programme. THE GOLDEN VISA PROGRAMME IN PORTUGAL


Strategic and Legal Solutions Creator Attorney at Law

WHY PORTUGAL? Portugal is a very peaceful country, economically and politically considered an “oasis of stability”. It is the third safest country in the world and it is a fantastic place to live calmly with your family and enjoy the breathtaking landscapes. You can find a safe, environmentally responsible culture, abundant leisure and an excellent Health System. Portugal is a place of adaptability, warm welcoming and also innovative. Some of the most superior technologies, products and software are developed in Portugal and presently impacting the world. Moreover, it is the birthplace of some of the best traditional products and a country that defines itself by the talent of its people. The country has an extensive logistics infrastructure, advanced communication systems and a friendly economic environment. With such great weather, food and people, the Portuguese authorities managed to launch a straightforward and attractive

Type of Investment: Real Estate: 7291 Capital Transfer: 431 Job creation: 16

The Golden Visa programme was launched in 2012 and promoted as a visa or a Citizenship-by-Investment scheme. This visa has proven to be the most attractive and accessible option across Europe for Investors, due to its ease and flexibility to obtain along with all the benefits it provides. THERE ARE NO DISCRIMINATION ON NATIONALITIES OR RELIGIONS. IF YOU INVEST, YOU GET THE RESIDENCE PERMIT. This visa allowed the applicant and family to gain a residency permit in Portugal for 12 months and can be renewed on a 2-yearly cycle. This visa allows its holder to travel freely across Europe within the Schengen Zone1. Portuguese Golden Visa in Numbers 7738 Permits granted

13108 Permits granted to Family members

Main Nationalities China – 4331 Brazil – 801 Turkey – 303 South Africa – 303 Russia - 269

QUALIFYING INVESTMENTS You must fit at least one of the following investments: • EUR 500,000 in real estate property in Portugal or EUR 350,000 in specific Portuguese urban or rural areas • EUR 1 million Capital transfer into Portugal • 10 job positions creation in Portugal • EUR 350,000 in scientific research in Portugal

It is a very straightforward investment programme (check Qualifying Investments  box), very few documents are required, and applications have priority processing with the Immigration Authority (SEF). To get the Residence Card, you should get the support of professionals in all the steps from investment to application and afterwards. Once residency is granted, you will have the right to live, work and study anywhere within the European Union and, once citizenship is obtained, you will become a European citizen with the same rights as any Portuguese citizen. BENEFITS

• EUR 250,000 in Portuguese arts, culture and heritage • EUR 500,000 in small and medium businesses in Portugal.

YOUR RIGHTS AS A RESIDENT A professional activity, (as an employee or as an independent professional) Education and professional training Official recognition of education diplomas and professional qualifications Healthcare provision Social security benefits, tax concessions and trade union protection The law and the courts of law Tax benefits.

The most beautiful part is that after five years of holding temporary residency, you can then apply for permanent residency within Portugal, and after six years you can apply for citizenship! The requirements to qualify are the initial investment, a clean criminal record and the ability to spend a minimum of seven days in Portugal each year, without the need to reside in Portugal.

Those who hold a Portuguese Golden Visa are entitled to: · Freedom to live and work in Portugal - the minimum stay requirements are seven days in the first year and fourteen days during each of the two subsequent 2-year periods, (whether or not consecutive), whilst keeping residency in another country. · Visa-free travel in Europe/Schengen area - permanent free entry and circulation in Portugal and the other 25 Schengen countries. · Fully extendible benefits to direct family members without further investment  - including the spouse or partner, under-aged or dependent children, dependent parents, and under-aged siblings. · EU Citizenship – the applicant and his or her family may obtain permanent resident status after five years, or after six, they will be eligible to acquire Portuguese citizenship. Portugal accepts dual citizenship and has one of the best ranking passports in the world. · Property or investment ownership in an EU country  – Portugal is a free market and open economy with many business opportunities

with no need for individual authorisations and with many e-government fast procedures. · Residency in Portugal – an alternative residency in terms of safety, security, health, education and lifestyle, with access to all Portuguese public services, including health, law and education. · Tax Benefits  – there may be additional tax benefits to the Portuguese investor visa in that holders will not have to pay tax on worldwide income if they live in Portugal for less than 183 days per Portuguese tax year. Alternatively, there is the option to become a “non-habitual resident” of Portugal, which can be for tax purposes, thereby paying little or no tax for at least ten years. COSTS Besides travel expenses, Government fees, taxes and professional fees are likely to add significantly to your total Golden Visa costs, so make sure that whomever you engage with provides a full and transparent quote. Also, it would help if you considered the several existing Taxes: Stamp Duty; Property Transfer Tax (IMT); the Real Estate Tax (IMI); Income Tax (IRS); Corporate Tax (IRX) and, of course, Value Added Tax (IVA). Your Portuguese attorney will assist your requirements for a Portuguese Golden Visa, plus details on the programme and Portuguese citizenship-by-investment. It would help if your attorney covered immigration law as well as real estate, corporate and tax matters. It is critical to ensure that you have the right project and legal advice before embarking on such investment. The Portuguese Golden Visa programme has proven to be very popular with our clients and investors. If you are interested in investing in Portugal, please contact us and we will endeavour to assist you every step of the way!

1. Schengen country members: Austria, Belgium, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Slovakia, Slovenia, Spain, Sweden, Switzerland, Liechtenstein.

73 Citizenship By Investment

Country Spotlight

QUICK FACTS Full name: Republic of Turkey Capital city: Ankara Population: 82,003,882 (2018) GDP in Current prices: USD $713.51 billion (2018) GDP real growth: 2.6% (2018) Area: 783,356 km² Government: Unitary presidential constitutional republic President: Recep Tayyip Erdogan Vice President: Fuat Oktay Currency: Turkish Lira (₺) (TRY) HDI: 64th (2018) Ease of doing business index: 43rd (2018/19) Time Zone: GMT +3 Dialling code: 90



he Republic of Turkey is a transcontinental country based mainly in West Asia. The total area of Turkey is 783,356 km² (which makes it the 36th largest country in the world), of which just over 3% (roughly the same size as the US state of New Hampshire) lies on the Balkan Peninsula in Southeast Europe. This European area is bordered by Bulgaria to the northwest and Greece to the west. It is separated from the rest of Turkey by the Sea of Marmara and the Turkish Straits – which include the Dardanelles and the Bosporus Strait – connecting the Aegean Sea in the south to the Black Sea, which washes Turkey’s northern shorelines. The rest of Turkey is bordered by Georgia to the northeast, Armenia and Iran to the east, and Iraq and Syria to the south. The population of Turkey is nearing 83 million, of whom approximately 71 million live in Asia and 11.7 million in Europe. 15 million live in the Istanbul metropolitan area that straddles the Bosporus Strait across which three suspension bridges link the European and Asian sides. Istanbul is the largest city in Turkey and one of the most popular tourist destinations of the world. 65% of its metropolitan population live on the European side (Eastern Thrace) and 35% on the Asian side (Anatolia). 92.3% of Turkey’s population live in cities and district centres compared with 7.7% in towns and villages (source: Turkish Statistical Institute 2018). History The Republic of Turkey was officially proclaimed on 29 October 1923 following the Turkish War of Independence (19191923) in the aftermath of World War I which saw the Ottoman Empire defeated and its capital, Constantinople, occupied by Allied French, British, Italian and Greek

74 Citizenship By Investment

troops. The Ottomans had entered WWI by launching a surprise attack on Russian Black Sea coastal ports on 29 October 1914. Russia responded by declaring war against the Ottomans on 1 November and was joined by its allies Britain and France four days later. Prior to the rise of The Ottoman Empire, much of the Anatolian Peninsula had been inhabited by various settlements and civilisations including Assyrians, Greeks and Armenians. The region became predominantly Hellenised after Alexander the Great defeated the Persian rulers in 334 BC and liberated much of Asia Minor. This became the Roman province of Asia in 129 BC and, as Rome began its transition from Republic to Empire, the region’s cities, including the provincial capital of Ephesus, flourished under Roman rule. In AD 324, the Roman Emperor Constantine the Great chose the city of Byzantium – founded as Byzantion on the shores of the Bosporus Strait in around 660 BC – to be the new Christian capital

of the Roman Empire and renamed it Nova Roma in AD 330. Following his death in 337, the city was renamed Constantinople and it became the capital of the Eastern Roman Empire after the permanent sub-division of the Roman Empire in 395. After the fall of Rome in 476, the Roman Empire continued in the east with Constantinople as its capital and enjoyed a golden age under the reign of Justinian I (Roman Byzantine Emperor from 527 to 565). The magnificent Hagia Sophia in Istanbul was built during 532537 as a church and remained the world’s largest cathedral for nearly a thousand years; the domed building later became an Ottoman mosque and today is a museum that epitomises Byzantine architecture. The Ottoman state arose at the end of the 13th century in northwest Anatolia and crossed into Europe around 1354, conquering much of the Balkans. In 1453, they captured Constantinople, bringing the Byzantine Empire to a close. At its peak during the 16th and 17th centuries,

the Ottoman Empire extended well into central and southeast Europe, across north Africa and much of west Asia. But by the late 17th and 18th centuries, Ottoman power was waning and beset with internal rebellions while the Russian Empire expanded and asserted itself as a protector of Christians in Ottoman territories. Having lost much of its Balkan territories during the Ottoman Great Eastern economic crisis and the Russo-Turkish War of 1877-78, many Balkan Muslims migrated to Anatolia and ethnic tensions increased. The Armenians in particular suffered huge losses in genocidal attacks shortly before, during and immediately after World War I. The Ottoman Empire joined WWI with the German, AustroHungarian and Bulgarian side which ultimately was defeated. In 1916, the British engineered an Arab Revolt within Anatolia and this helped to destabilise the Ottoman government. Unhappy with the terms of the Armistice signed on 30 October 1918 which allowed the Allies to occupy Constantinople and other key ports and garrisons, a Turkish National Movement sprung up in Ankara and declared itself the legitimate government of Turkey on 23 April 1920. The Turkish Parliament formally abolished the Sultanate on 1 November 1922, finally bringing the Ottoman Empire to

an end after 623 years, and the Treaty of Lausanne of 24 July 1923 gave international recognition to the new Republic of Turkey with Ankara as its capital. On 6 October 1923 – two days after the last of the allied British, French and Italian troops had left Constantinople – the troops of the Ankara government marched ceremoniously into the city and declared Liberation Day, the anniversary of which is celebrated every year. The Republic of Turkey was officially proclaimed on 23 October 1923 and the city of Constantinople was renamed Istanbul. Foreign relations Turkey remained neutral during most of World War II, before joining the side of the Allies in February 1945. Turkey is a founder charter member of the United Nations and a founder member of the G20. In 1949, Turkey was one of the first countries to join the Council of Europe and in February 1952 Turkey was one of the first two countries to join the founding 12 members of NATO as it sided with the US and Western Europe during the Cold War with Russia. In 1961, Turkey was one of the founder members of the Organisation for Economic Co-operation and Development (OECD) and two years later became an associate member of the EEC. Turkey applied for full membership of the European Community in 1987 but a

decision was deferred partly due to events in Cyprus. Turkey had invaded Cyprus in July 1974 in response to a Greek-led military coup and this led to the UNorganised partition of the island. In 1983, the Turkish part of the island declared its independence as the Turkish Republic of Northern Cyprus, but Turkey is the only country to recognise it. In 1996, a customs union between the European Union and Turkey came into effect and a free trade area was established for certain industrial products. This gave a significant boost to Turkey’s trade and helped increase its GDP per capita. In December 1999, Turkey was officially given candidate membership status. However, UN efforts to resolve the Cyprus situation failed to win enough Cypriot approval in a referendum, with the result that, whilst the Republic of Cyprus was accepted as a full member on 1 May 2004, the rights of EU membership were (and still are) suspended for Northern Cyprus, and Turkey has still not achieved the criteria for full membership. Turkey historically has good relations with the US and has assisted international missions under NATO and the United Nations. It has the second largest standing military force in NATO and has been actively involved in trying to find a resolution to the ongoing conflict in neighbouring Syria.

75 Citizenship By Investment

Politics and administration Turkey was a parliamentary representative democracy from 1923 until a referendum, held under a state of emergency in April 2017 following a failed military coup attempt in July 2016, narrowly approved 18 amendments to the Turkish constitution. The new rules came into effect with the presidential election of 24 June 2018, abolishing the office of prime minister, increasing the number of seats in parliament from 550 to 600 and giving complete control of the executive to the President, who is head of state. Parliamentary and presidential terms are extended from four to five-year terms with the elections being held on the same day, allowing for a presidential run-off if no candidate wins an outright majority in the first round. Turkey is divided into 81 provinces administratively. The most populous province is Istanbul which lies on both the European and Asian sides. Three other provinces lie fully on the European side. The second most populous province is Ankara, which includes the country’s capital city of the same name, and is effectively at the heart of the country. Turkey is a unitary state and each of the

76 Citizenship By Investment

provinces is run by governors and senior city officials appointed by the central government in Ankara rather than by locally elected mayors. Officially, Turkey is a secular state with no official religion. Freedom of religion and conscience is provided for within the Turkish Constitution and there are no questions relating to religion or ethnicity within the Turkish censuses. However, around 96% of the population are Muslims, most of whom are Sunni Muslims. Economics and trade Turkey’s economy has tended to fluctuate in recent years, rising by 7.4% in 2017 in real terms, but going into recession at the end of 2018 after two successive quarters of falling growth (Q3 down by 1.6% and Q4 down by 2.4%). The annual real growth rate for 2018 was +2.6% which is the lowest figure since the global downturn of 2009. The full year’s nominal GDP of US $713.5 billion ranked 19th largest globally, having slipped from 17th in 2017. On the GDP by PPP (Purchasing Power Parity) tables, Turkey still ranks 13th largest. Turkey’s currency dropped by 30% against the US dollar as a result of a trade war with the US, making imports

a third more expensive on average and prompting the central bank to raise interest rates while annual inflation peaked at over 25% in October 2018. Turkey is a net exporter of agricultural products and has been self-sufficient in food production since the 1980s. Around 11% of Turkey’s land is used for agriculture with wheat as its main crop. The country is also the world’s largest producer of hazelnuts, figs, cherries and various other fruits. Much of the produce still comes from small farms. In 2018, 18.75% of the employed population worked in agriculture (compared with 29.5% in 2009) and contributed 6.1% of the GDP. Industry accounted for 29.2% of GDP with automobile manufacturing and textiles being the main sectors. The services sector grew rapidly in the 2000s, peaking at 59% of GDP in 2009, but slipped back to 53.3% of GDP in 2018. Tourism Tourism is an important part of Turkey’s economy and had been growing rapidly since 2000, with the country becoming the6th biggest tourist destination in the world in terms of numbers of international

arrivals (source: UN World Tourism Organisation). However, the numbers took a big dip during 2016 due to a spate of terrorist attacks, the attempted military coup and heightened political tension with Russia. The Russian tourists – who are usually the number one tourism market for Turkey – started returning in 2017 after the restoration of bilateral relations and heavy advertising campaigns, and 2018 saw an 18.1% increase in visitor numbers to 45.6 million. Of these, 85.4% were foreign – with Russia (15% of foreign tourists), Germany (11%), Bulgaria (6%), UK (6%) and Georgia (5%) being the top five countries of origin – and 14.6% being Turkish citizens residing abroad. According to Turkey’s statistical authority, tourism revenue during 2018 reached $29.5 billion compared with $26.3 billion in 2017. Turkey is famous for its historical sites and has 17 UNESCO World Heritage sites as well as two of the Seven Wonders of the Ancient World. The Turkish Riviera has many excellent beach resorts along the Aegean and Mediterranean coastlines. The country is also renowned for its cultural experiences and excellent food.

RESIDENCY AND CITIZENSHIP BY INVESTMENT Turkey was the first Middle East country to introduce a Citizenship by Investment (CBI) programme, launching it in January 2017. Originally, the scheme had required investments of US $3 million in government bonds or deposited into a Turkish bank for three years, or purchasing real estate valued at US $1 million, but after a relatively slow take-up, the government reduced the charges in their Citizenship Act amendment published on 19 September 2018. Having received just over 250 applications for citizenship by investment worth slightly less than $100 million by the end of 2018, the number of applications is expected to boom during 2019. The options available for anyone aged 18 or over applying for Turkish citizenship are as follows: 1. Real Estate – invest a minimum of US $250,000 (or the equivalent in Turkish Lira or other convertible currency as in all options) on the stipulation that the immovable property is not sold within the next three years. 2. Bank deposit – that $500,000 (or equivalent) be deposited for at least three years in one of the Turkish banks. 3. Fixed capital investment – that a minimum of $500,000 (or equivalent) be made in fixed capital investment and confirmed by the Ministry of Industry and Technology; previously the minimum required investment was US $2 million. 4. Government bonds – that a minimum of $500,000 (or equivalent) be used to purchase government bonds and bills on condition that they be held for at least

TURKEY’S CIP NUMBERS By 30th June 2019, the number of approved main applicants had reached 981, according to official figures from the Turkish Interior Ministry, generating over $1 billion since the start of the programme. Most of the applications for Turkey’s CIP are from Middle Eastern countries, although 21 Chinese applicants and several Russians are included within the ‘others’ on this chart.

three years and that the investment shall be confirmed by the Ministry of Treasury and Finance. 5. Job creation – it is also possible under the new regulation to gain Turkish citizenship by employing a minimum of 50 new personnel; previously the requirement was for 100 personnel. Benefits of Turkish Citizenship • Visa-free or visa-on-arrival travel to 115 countries including Hong Kong, Singapore and Japan • Dual nationality is allowed • Citizenship is granted within 3-6 months after receipt of the application and investment • No requirement to reside in Turkey or to learn Turkish language • No military service requirements for applicants • Citizenship covers spouse and children under 18 years of age • Access to full free medical assistance for life, including all direct family members Turkey offers a democratic and safe • environment for the whole family with high quality education facilities and social healthcare reforms Prospective visa-free travel facilities to • EU Schengen Zone in near-term future.

Nationality of applicants 22%


6% 6%


6% 10%


Iran - Iraq - Yemen - Afghanistan Syria - Palestine - Jordan - Others Source: Ministry of Interior, Republic of Turkey

77 Citizenship By Investment

Country Spotlight




he United Kingdom, more commonly referred to simply as the UK, is a sovereign country in the northwest of Europe, separated from the European mainland by the North Sea to the east and the English Channel to the south. To the west lies the Irish Sea and the island of Ireland, which incorporates Northern Ireland and the Republic of Ireland, and the Atlantic Ocean. The UK was the world’s first industrialised country and, with a strong naval history dating back to the 16th century, became a world leader as the British Empire spread to become the largest empire in history during the 19th and early 20th centuries. Many of its former colonies gained independence during the latter part of last century, but remain members of the Commonwealth of Nations, a political association with 53 member states, the majority of which are former British territories. The UK is a founder member of the United Nations and a permanent member of its Security Council since 1946. It has also been a member of the EU/EEC since 1973 but is currently embroiled in protracted negotiations to leave the EU on 31 October 2019. The UK is actually a union of four countries – England, Scotland, Wales and Northern Ireland. Great Britain is the name of the largest island in the UK (and also Europe) with an area of 229,848 km² of which roughly 57% is England, 34% Scotland and 9% Wales. Wales was formally annexed into the Kingdom of England in 1535. The Kingdom of Ireland was officially created in 1542 by an Act of the Irish Parliament recognizing the English monarchy, although the two countries remained separate. Following a union of crowns in 1603, Scotland and England joined together in a Treaty of Union in 1707 to create the

78 Citizenship By Investment

Kingdom of Great Britain. The United Kingdom of Great Britain and Ireland was officially enacted on 1 January 1801 after the British and Irish parliaments passed their acts of union in 1800. However, subsequent events in Ireland led to the partition of Ireland in 1921 and the creation of the Irish Free State on 5 December 1922, while the six historical counties of Northern Ireland remained part of the United Kingdom. Administration The UK’s capital is London, which has a population of around 8.9 million and is one of the main financial centres and cultural capitals of the world. It is also home to the UK parliament which is based in the Palace of Westminster and has two houses: the House of Commons, which has 650 members elected by popular vote, and an appointed House of Lords. Of the 650 UK parliamentary constituencies, 519 are in England (of which 14 are in Greater London), 73 are in Scotland, 40 in Wales and 18 in Northern Ireland. In addition, Scotland, Wales and Northern Ireland have their own devolved governments in Edinburgh, Cardiff and Belfast respectively, each with their own education and healthcare administrations and other varying powers. The head of state is Queen Elizabeth II who is the longest-serving English monarch, having reigned since 6 February 1952.

Full name: United Kingdom of Great Britain and Northern Ireland Capital city: London Population: 66,435,600 (30 June 2018) England: 55,977,200 Scotland: 5,438,100 Wales: 3,138,600 N. Ireland: 1,881,600 GDP in Current prices: USD $2,808.90 billion (2018) GDP real growth: 1.4% (2018) Area: 242,495 km² Government: Unitary parliamentary constitutional monarchy Monarch: Queen Elizabeth II Prime Minister: Boris Johnson Currency: Pound Sterling (£) (GBP) HDI: 14th (2018) Ease of doing business index: 9th (2018/19) Time Zone: GMT +0 Dialling code: 44 Economy  The UK has the fifth largest economy behind the US, China, Japan and Germany; but whilst the economy grew by 1.4% in 2018, the rate of real GDP growth has declined every year since 2014 and the economy is forecast to be overtaken by India within the next year. Services account for 79% of GDP, Industry 21% and Agriculture less than 1%. The UK has a rich cultural and historic heritage. Being a primarily liberal democracy, creative arts and fashions have flourished and contributed enormously to global music, literature, visual art and cinema. In 2008, Liverpool – home of the Beatles who were the most influential and successful popular music band of the 20th century – was named European Capital of Culture, while Glasgow was only the third city to be awarded the title of UNESCO City of Music, with Liverpool receiving the same accolade in 2014. England is also home to two of the world’s five oldest surviving universities – the Universities of Oxford (from 1096) and Cambridge (founded 1209).


On 29 March 2019 the Immigration Rules for Entrepreneurs and Investors changed. For Investors, this meant stricter control on the provenance of the funds and a new requirement that the transfer of the funds to the UK should not have been in breach of the laws of any country involved in the transfer, not merely comply with the laws in the UK, as was the case previously. Investment into government bonds (or gilts) is no longer allowed. The recipients of the investment funds are expected to be active and trading UK companies. Where investment vehicles are used, it is required to disclose the entire chain of investment, including all intermediary entities, up to the final recipient of the funds. The purpose of the changes was to ensure that the investments are of better value to the UK economy and to prevent investment into high profit enterprises outside the UK using British intermediaries. So, what are active and trading companies? An active and trading UK company is subject to UK taxation, has a business bank account and can demonstrate regular trading of their own goods or services. It is required that the company has at least two UK resident employees who are not directors of the company. There are no specific requirements related to the ownership of the company, profitability, or the type of shareholding capital. The investment, though, has to be made within three months of entering the UK and has to be maintained at the required level during the period of leave to remain. Where the investment portfolio or part of it is sold, the total amount of the gross proceeds of sale has to be re-invested in qualifying investments. I am frequently asked by prospective investors if they have the option of investing into a business of their own. The answer is

yes, this option is open. You can manage your funds and invest in a business or businesses you own, provided they trade in the UK, are subject to UK taxation and meet the requirements in relation to the number of settled non-director employees. Investors are encouraged to take a hands-on approach and be actively involved in business affairs in Britain. Entrepreneurs, as an immigration category, are not fairing that well at the present moment. The changes of 29 March closed the Tier 1 Entrepreneur category for new entrants. In its stead, the Home Office introduced two new immigration categories – Start-Ups and Innovators. The reason for this change is not entirely clear and we all hope that the situation will be reversed. The Innovator category has not really taken off due to very burdensome and not entirely clear endorsement requirements and a very high threshold for indefinite leave to remain, which many businesses may not be able to meet. The hurdle of getting the initial endorsement followed by the perennial risk of having the endorsement withdrawn does not contribute to confidence among entrepreneurs.

we continue to work with those who are already in the country or applying for entry clearance having previously held an Entrepreneur visa in the last 12 months. Where entrepreneurship begins My last client to come to the UK as a Tier 1 Entrepreneur made his application on the late afternoon of 28th March, just hours before the route closed. Now, with his visa granted, residence permit issued, flat rented and bank account opened, we finally meet for an unhurried lunch by the Thames. Basking in the August sun and watching the river boats glide by under Blackfriars Bridge, towards the Houses of Parliament to the west and the Tower of London to the east, we talk about his business ideas and plans. An hotelier with experience around the globe, from the Americas, to the Emirates, and to China, he tells me that he is fascinated with London. “With a fresh eye”, he tells me “I can see an endless wealth of opportunities. Lots of things can be improved and lots of people may benefit from the improvement. That’s where entrepreneurship begins.”

In the meantime, those who are in the UK as Tier 1 Entrepreneur visa holders can extend their stay until 5 April 2023 and apply for indefinite leave to remain until 5 April 2025. Graduate entrepreneurs can still switch into Tier 1 Entrepreneur route until April 2021 and can apply for settlement in the UK until April 2027. There are huge opportunities associated with this route – the initial investment requirement is £50,000 and the requirements for job creations are not too burdensome for an average business. As a business, we see our mission in helping 1,000 graduate entrepreneurs to achieve their business and immigration goals by the shortest and safest route. As for others,

Helena is the founder and managing director of Kadmos Consultants and has focused on immigration for the last 12 years. She is actively involved in all aspects of business immigration and enjoys working with businesses who rely on overseas talent as well as migrant entrepreneurs and investors. Helena can be contacted at: Kadmos Consultants 166 College Road Harrow HA1 1BH Tel. +44 (0)20 8930 9503 E-mail: helena@kadmosimmigration.com Website : www.kadmosimmigration.com

79 Citizenship By Investment

Country Spotlight




anada is a country in the continent of North America, stretching from the Pacific Ocean in the west to the Atlantic Ocean to the east and sharing a land border with the United States to the south and the US state of Alaska to the northwest. Its northern territories extend well into the Arctic Ocean with the Danish territory of Greenland situated off to the northeast.

By total area, it is the second-largest country in the world after Russia, although this includes nearly two million lakes, with nearly 9% of Canada’s surface area covered by freshwater. With a population of over 37 million people, Canada is the 38th most populous nation and has a strong multi-cultural heritage. Canada is a highly advanced country with the 10th largest economy in the world and a very high Human Development Index (HDI). Importantly for anyone thinking of migrating, Canada is one of the most ethnically diverse and multicultural countries in the world with extremely high degrees of civil liberties and quality of life. A founder member of the Commonwealth of Nations and the United Nations, it is also a

member of the G7. Canada is also one of the wealthiest countries globally, ranking 8th in the 2018 Credit Suisse listings with USD $ 8,319 billion. Canada’s provinces and territories Each of Canada’s ten provinces has its own legislative assembly with one parliamentary house and shares government responsibilities with the federal government. The three territories also have their own legislative councils but with no sovereignty and fewer responsibilities. Canada’s official languages are English and French and these have equal status in

Capital city: Ottawa Population: 37,412,852 (1 April 2019) GDP in Current prices: USD $1,733.7 billion (2018) GDP real growth: 1.8% (2018) Area: 9,984,670 km² (land 9,093,507 km²) Government: Federal parliamentary constitutional monarchy Monarch: Queen Elizabeth II Governor-General: Julie Payette Prime Minister: Justin Trudeau Currency: Canadian dollar (CAD) HDI: 12th (2018) Ease of doing business index: 22nd (2018/19) Time Zones: Ontario and Quebec GMT -4 Alberta GMT -6, British Columbia GMT -7 Dialling code: 1 parliament, the courts and in all federal institutions. French is the official language in Quebec and New Brunswick is officially bilingual under the Canadian Charter of Rights and Freedoms. The rest of the provinces use mainly English as their primary language, while the territories give official status to several indigenous languages, with Inuktitut the majority language in Nunavit as one of its three official languages. According to the 2016 Census, 56% of the Canadian population spoke English as their mother tongue and 21% spoke French as their mother tongue, with around 98% able to speak one or both languages.

Table 1. List of administrative provinces and territories of Canada


Population (Apr 1, 2019)

% of pop’n.


Largest City

Year joined Confederation

Share of Nat. GDP















British Columbia




























Nova Scotia







New Brunswick







Newfoundland and Labrador



St. John’s

St. John’s



Prince Edward Island







Northwest Territories





















National Total





80 Citizenship By Investment

Source: Statistics Canada (2018 GDP data)

CITIZENSHIP BY INVESTMENT Canada was one of the first countries to operate immigration investment programmes, launching its Federal Immigrant Investor Program (FIIP) in 1986. However, this was closed permanently and suddenly in 2014. Currently, the only Canadian citizenship by investment program open is the Quebec Immigrant Investor Program (QIIP). This is a very popular scheme for business owners and company directors, particularly as there are no age limitations and no language or minimum education requirements, but it only opens for fixed time-periods. The QIIP program now only accepts a maximum of 660 applicants per year. The 2019/20 program is due to start in August 2019 and interested applicants are advised to prepare their applications as soon as possible as it takes around five to eight months to complete the application process. Note too that, by law, all QIIP applications must be processed by a Quebec -based office and registered immigration consultant and lawyer, as no offices outside Quebec are allowed to process applications. The required level of investment has increased since the 2018 program and the qualification requirements for 2019/20 are as follows: • The applicant (and spouse) have to show they have a legally obtained minimum net personal wealth of CAD $2,000,000 or the equivalent in foreign currency; previously this benchmark was CAD $1,600,000. • The applicant must have been a shareholder of a private company for the past two years, or to have been one for at least two of the past five years. If the applicant does or has not owned a company, they must have at least two years’ managerial experience as a paid employee in an admissible company. • The applicant must make a risk-free deposit of CAD $1,200,000 (previously

$800,000) into an authorised investment fixed-term account guaranteed by the Government of Quebec within 60 days of receiving provisional approval, and must keep the money invested for five and a half years without taking any interest but paying the related costs, after which time the money is returned. The interest generated by the deposit is used by the government to help fund new businesses and generate new jobs.

Provincial Nominee Programs (PNPs) allows participating provinces and territories to nominate a set number of economic immigrants they would like to put forward to the IRCC for applying for permanent residence each year. These are predominantly targeting graduate entrepreneurs and SME businesses and skilled workers, as well as experienced young farmers in some provinces including British Columbia and Manitoba.

• As most applicants may be reluctant or unable to liquidate assets to meet the mandatory investment amount within the time allowed, applicants may make use of the QIIP Financing Option which is to make a one-time non-refundable payment of CAD $350,000 which covers all government broker fees but not does not cover the legal professional fees to prepare and follow the application process.

Each of the provinces and territories (except Quebec and Nunavit) has its own immigration ‘streams’ with its own features and minimum qualifying criteria, but all of them require a medical examination and a police check. It is also desirable to – and in most cases mandatory – to make an exploratory visit to the province you are thinking of relocating to and to prepare a business plan that should include provision for the creation of at least two jobs for local Canadian citizens.

Once the applicant has received a Permanent Residency Visa under the QIIP, this entitles them to live, work, invest or study anywhere in Canada and to enjoy all the benefits of Canadian citizens. Canada is one of the safest and most liberal countries in the world and offers free universal health care, free education and highly reputable universities. After the applicant has been physically present in Canada for just three years (and not necessarily consecutively if one is a frequent traveller), he or she is able to ask for and receive full Canadian citizenship including a Canadian passport, which gives visa-free or visa-on-arrival access to 184 countries, plus the right to vote. Provincial Nominee Entrepreneur programmes Although the National programme was closed down a few years ago, many of the provinces have signed agreements with the federal government to develop their own business immigration programmes. The

‘‘ Canada is one of the safest and most liberal countries in the world’’ Most of the programmes are fixed for a determined period and have a maximum limit of applications within those timeframes. In 2017, Canada welcomed 159,262 permanent residents through its Economic Class programmes, of whom a record 49,724 (from 23,504 accepted applications) came through the Provincial Nominee Programs. For 2018 the IRCC had set a target of 55,000 rising to 61,000 for 2019 and 71,300 in 2021. These programmes are constantly changing and they are usually over-subscribed, so it is advisable to check online with the Canadian Immigration Services website at www.canada.ca and look up the Immigration, Refugees and Citizenship Canada (IRCC). You can also check our own website www. citizenshipinvestment.org for regular updates on the provincial programmes.

81 Citizenship By Investment

Country Spotlight



he United States of America (USA), also commonly known simply as the US, is primarily a country within the continent of North America. The area known as the contiguous United States, which consists of 48 of the 50 states plus the federal district of Columbia, has a total area of 8,081,867 km² and is bordered to the north by Canada, to the south by Mexico and by the Pacific Ocean to the west and the Atlantic Ocean to the east. The 49th state, Alaska, is situated to the northeast of Canada and is the largest state by area, while the 50th state, Hawaii, is a group of islands located in the Pacific Ocean within the continent of Oceania.

The District of Columbia is more commonly referred to as Washington D.C. and is the capital of the United States, named after the country’s first president George Washington, one of the country’s Founding Fathers and president from 1789 to 1787. The Constitution of the original thirteen states – created and presented during September 1787, ratified on June 21, 1788 and effective from March 4, 1789 – allowed for a federal district to be created along the Potomac River on the East Coast between the states of Maryland and Virginia that would be under the direct jurisdiction of the U.S. Congress. In total, the US is the fourth largest country by total area and the third most populous country in the world after China and India, with over 327 million people from various ethnic backgrounds. There is no official national

82 Citizenship By Investment

language as such, but English is spoken as a first language at home by around 79% of the population aged 5+, compared with Spanish by 13% and Chinese dialects by 1%. Alaska and Hawaii also recognise their native languages, while French is widely used in Louisiana.

global companies, particularly within the financial and IT sectors. The US also ranked first last year for the breadth and quality of its universities and higher education facilities, attracting international students particularly from Asia.

Economy and trade The US has been the largest economy in the world for several decades, growing by about 4% each year since 1999 on average (an average of 2.0% in real growth). In 2018, the nominal GDP exceeded US $20 trillion, of which Services accounted for an estimated 80%, Industry 19% and Agriculture just under 1%. However, comparing GDP based on purchasing power parity (PPP) basis, the US ranks second behind China, having been overtaken in 2014. On a GDP per capita basis, the US currently ranks 8th highest according to IMF 2018 figures (US $62,606). The country is rich in natural resources and is one of the world’s producers of oil and natural gas. It is also one of the world’s largest industrial manufacturing markets. In this regard, the US has attracted immigrants from all over the globe and continues to attract skilled workers. Its biggest trading partners are China (15.7% of 2018 imports and exports), Mexico (14.7%), Canada (14.5%), Japan (5.2%), Germany (4.4%), South Korea (3.1%) and the UK (3.0%). The United States has been at the forefront of scientific research and technological development since the start of the last century and is home to many of the top

QUICK FACTS Full name: United States of America Capital city: Washington D.C. Population: 327,167,434 (1 July 2018) GDP in Current Prices: USD $20.891 trillion (2018) GDP real growth: 2.9% (2018) Area: 9,833,520 km² (land 9,531,905 km²) Government: Federal presidential constitutional republic President: Donald Trump Vice President: Mike Pence Currency: United States Dollar ($) (USD) HDI: 13th (2018) – “very high” Ease of doing business index: 8th (2018/19) Time Zones: Eastern Standard Time Zone (EST) GMT -5 Central Standard Time Zone (CST) GMT -6 Mountain Standard Time Zone (MST) GMT -7 Pacific Standard Time Zone (PST) GMT -8 (All zones switched to Daylight Saving Time from Sunday March 10, 2019 until Sunday November 3, 2019) Dialling code: 1



There are new rule changes that will be brought to the EB-5 program, which are going to officially come into effect on 21st November 2019.

of the petitions, there will also be other conditions that will be applied to the changes, which are to be revisited every five years.

These changes include: priority date retention to certain EB-5 investors, substantial increases to the required minimum investment amounts, reforms to targeted employment area (TEA) designations, clarification for the USCIS procedures for the removal of conditions on permanent residence, plus there may be other technical and conforming revisions to be made.

In addition to this, the state or local government will no longer be making any TEA designations; these will all be managed by the Department of Homeland Security (DHS). They will review and conclude on the designation of highunemployment TEAs.

In regards to the priority date retention, specific investors would be able to retain their priority date from their previous petition when applying for a new petition. As for the increased investment price for TEA, it will no longer be $500,000 but now $900,000. Further, non – TEA costs have also been raised to $1.8million from $1million. Along with the increased cost

Within these changes, there is a chance that cities with a population of 20,000+ outside of metropolitan statistical areas will be included as a TEA, on the condition that they have had at least a 150% unemployment rate of the national average. This allows the investment to be guided to the areas that requires development and employment the most. There are also clarifications to the procedures for the removal on conditions

on permanent residence. This rule will make clear when derivative family members who are lawful permanent citizens would have to file to remove conditions on their permanent residence. This clarification will cover a larger area for interview locations and update the regulations to show the Green Card issuing process. Since the price increase is coming into effect on 21st November 2019, applicants should grab the opportunity to file their EB-5 petition before then. New Retrogression dates for Indian EB-5 applicants The USCIS has just announced in its September 2019 bulletin that the retrogression date for India has been brought forward to 1 September 2017. Meanwhile, Vietnam has been given the same final action date as for Mainland China, which has now been moved to 22 October 2014. All other countries are currently still showing as ‘current’.

83 Citizenship By Investment



9th Annual IIUSA EB-5 Industry Forum

October 29-30, 2019 Seattle, WA

Embassy Suites Seattle Downtown Pioneer Square

The EB-5 Industry Forum is the yearâ&#x20AC;&#x2122;s premier EB-5 conference focusing on education and business development on a global scale. We welcome more than 300 EB-5 industry stakeholders to forge our future during this pivotal time for the EB-5 industry.


Invest In the USA

Join us as we share the latest industry insights; provide educational opportunities and resources; and network and conduct business development, including with new Allied Partners and economic development professionals!

Early Bird Rate: $850 Sign up before Sept. 15 and receive an additional 10% off! Visit iiusa.org/seattle2019 for more info.


by ROBERT C. DIVINE Vice-President Emeritus

USCIS has published its final regulation changing the “EB-5 Program” that awards permanent residence to certain investors who create 10 new jobs for U.S. workers. Effective for I-526 filings arriving at USCIS on or after November 21, 2019, new EB-5 investments must be at least $900,000 in a “targeted employment area” (TEAs) and otherwise $1,800,000, and the areas that can qualify as TEAs for the lower investment amount are more limited. Absent legislation to provide additional visa numbers, the next few months may be the last great days for entering and subscribing investments under the EB-5 Program for the foreseeable future. 1. Before the Rule Takes Effect The new regulation is as important for what it will cause pre-effective date as after.

investment rush unless Congress allocates additional visa numbers to the program. The Scramble

The rule allows investors to remain under the current investment amounts and TEA areas if they file the first step in the EB-5 process (I-526 petition) before the November 21, 2019 effective date. This means that during the next four months anyone who is contemplating making an EB-5 investment should rush to invest and file at the lower investment level of $500,000. According to the regulation’s preamble, EB-5 investments already made appear likely to use up at least seven years’ worth of the 10,000 visa numbers available to investors and family members each year. In fact, the nationalities of the heaviest usage face even longer waits due to a 7% per-country limit, and those born in lower volume countries face much shorter or zero waits.

In the scramble to invest and file, some investors will ask to invest with less than the full $500,000 amount, using the law’s allowance for those “actively in the process of investing.” Some sellers of investments may be tempted to accept such investors. If such investors can qualify under present law, their I-526 filing with less than the full amount might preserve their ability to invest only $500,000 under current regulations. The new regulation itself only acknowledges placing the full funds in escrow. USCIS case law requires that if an investor invests part of the required capital plus “indebtedness” (owing the remainder not in escrow), the investor’s debt to the investment enterprise must be adequately secured by his or her personal assets under arrangements that are legally perfected in their location. Full investment up front is strongly advised to avoid risk of denial.

The new rush of filings in the next four months will extend the existing waits for high volume countries by many years. (Oft-proposed but yet unpassed legislation could eliminate the per country cap and make all new investors wait the same regardless of nationality.) The combination of nearly doubled minimum investment amounts and expanded wait time for visa numbers will pose huge disincentives for investors filing under the new rule. Thus, now begins the last great four-month EB-5

Even apart from the capital actually invested, investors must show in their I-526 filing that their source of funds is legitimate. Investors will be tempted to slap together skeletal evidence of their sources of funds. But USCIS can deny petitions that turn out not to have been “approvable at the time of filing.” While responses to USCIS requests for evidence normally can add evidence about facts that existed at the time of filing, USCIS can refuse evidence of newly identified or switched sources.

The Surge

USCIS might take more aggressive positions against investors who slopped in sketchy filings to lock in the $500,000 investment amount. All of this argues against only partial capital contribution and in favor of making the best effort possible to document sources on the front end. The Risks Issuers of investments should consider amending their offerings now to include disclosure of risks posed by the new regulations’ higher investment amounts, including the prospect that any EB-5 capital not raised for the project before November 21 might be much more difficult to raise, necessitating other sources for any funding gaps. Many projects that are in state-designated TEAs today may not qualify under the new rules, making post-November subscriptions of EB-5 capital practically impossible. 2. After the Rule Takes Effect Here is how the rules will change for I-526 petitions filed on or after November 21, 2019: Investment Amount The normal minimum investment level will increase from $1 million to $1,800,000. The minimum investment in a Targeted Employment Area (TEA) will increase from $500,000 to $800,000. The rule also provides for a process of inflation-based adjustments to the minimum investment amounts beginning on October 1, 2025 and every five years thereafter, with the TEA level always 50% of the “normal” amount. The price adjustment of the normal amount will be based on the Department of Labor’s “Consumer Price Index for All Urban Consumers for the U.S. City Average” as compared to $1 million in 1990 when the EB-5 program was created, rounded down to the nearest $100,000.

85 Citizenship By Investment

TEAs for lower investment Whether a project’s location can qualify for the lower $900,000 level by being in a TEA will remain as crucial as before, given the 50% differential. The TEA definition of a rural area remains unchanged: both outside a town of 20,000 and outside a Metropolitan Statistical Area (MSA). Some areas will be TEAs based on federally published data showing an unemployment rate of 150% of the national average: an MSA; a county within an MSA; or a city or town outside an MSA. Otherwise, a “specially designated” high unemployment area may be determined only by USCIS itself (not by the states as before) and must either include the single census tract or contiguous census tracts in which the job creating business will operate or also any or all census tracts directly adjacent to such tract(s). This change is meant to cut down on the “gerrymandering” of extended snake-like areas previously subject to state designation including project areas that many criticized as not worthy of the lower investment level. Process for TEA “Special Designation”

relied on most, and the rule’s preamble mentions the need to use consistent data both for the local and national unemployment rates. But the lack of absolute clarity in data and methodology puts huge pressure on the economists on whom the project developers and regional centers rely to make a correct assessment of TEA eligibility, and on investors to make sure that the data to be used in their filing is the latest available data as of the time of filing. Date that locks in TEA Importantly, under the statute the date of investment is the date the investment area must qualify as a TEA. But when capital is placed first in escrow until I-526 filing (and possibly beyond), USCIS considers the time of investment to be the time of I-526 filing. Therefore, we can expect the popularity of even short escrows to decline in order to ensure that an investor can depend on the TEA data as of the time of actual investment and can avoid any disastrous change in TEA data that could occur between investment and filing. Retention of I-526 Priority Dates

Sadly, USCIS will not establish a separate process for “specially designated” TEAs before a project is organized or offered, except when a regional center seeks optional “exemplar” approval of a project, which can take a few years to get. Instead, investors must include in their I-526 petitions the data on which the TEA can be determined by USCIS. The rule does not identify one definitive set of data for these determinations, because “no one dataset is perfect for every scenario.” The regulation specifically mentions data from the U.S. Census Bureau in the American Community Survey or from the DOL’s Bureau of Labor Statistics as “reliable and verifiable,” which probably will result in those sets being

86 Citizenship By Investment

The onslaught of investment during this season will result in even longer waiting lists for visa numbers than already exist. The new regulation mercifully provides that if an investor gets an I-526 petition approved, and then for some reason that I-526 is abandoned or even revoked (because of some material change) other than for misrepresentation or for ineligibility as of the time of filing, then the investor can take the place in the queue marked by that first approved petition and apply it to a subsequently filed I-526 petition. Importantly, a priority date that is actually used to immigrate as a conditional resident cannot be carried forward to a new

petition, which means that investors who experience project-related problems that result in denial of I-829 would need to start all over in the queue. Also, a “material change” to an investment project that results in denial of an I-526 petition in the first place will provide no priority date, while a material change after that I-526 approval - though resulting in revocation of the petition before immigration to conditional residence - marks a place in the queue that the investor can take to a new petition. One investor who after I-526 approval decides not to immigrate cannot pass on a priority date to a family member. The regulation does not provide any new protection from a child “aging out” of eligibility by reaching an adjusted age of 21 (absolute age minus the time of I-526 adjudication) by the time a visa number becomes available to the investor. Thus, as in the I-140 context for the first three employment based preferences, only the time the ultimately used petition was pending will be subtracted from the child’s absolute age under the Child Status Protection Act. Importantly, a place in the visa queue marked by an approved I-526 will not be useful in immigrating under an I-140, and vice versa. And a subsequent I-526 retaining a prior petition’s priority date will not allow the investor to use the lower level of minimum investment that may have been in effect for the first petition. Miscellaneous Clarifications Several additional “changes” are basically clarifications of existing interpretations. For instance, the filing of an I-526 petition is what marks an investor’s place in any queue for visa numbers. EB-5 investors may take credit for all of the new jobs created by a project even if dependent on other capital in addition to that of EB-5

investors. Family members of investors who do not file with the investor (including divorced spouse or child who has married) or who do not file I-829 at all (such as because they have abandoned permanent residence to live elsewhere) must file their own individual petitions (not filing together without the principal) with their own fees and show how the investor sustained the investment and created the requisite jobs. Family members can file I-829 together with one fee if the investor has died. While essentially passive investments as limited partners in a limited partnership were recognized because of specific reference in the statute, now the regulation acknowledges that an investor is sufficiently engaged in policy making activities of the investment enterprise if the organization documents provide the investor with “certain rights, powers, and duties normally granted to equity holders of the … type of entity in the jurisdiction” which include the commonly used LLC structure. It does not appear that USCIS is seeking to use the regulation to tighten its current approach that essentially allows EB-5 investors to have essentially a passive role, even if only a nominal right to make “policy input.” Nevertheless, one could imagine a future nightmare if USCIS began to evaluate what kinds of rights LLC members are “normally granted.” I-829 Interview Locations One seemingly small change could have meaningful effect for investors. USCIS may require the investor and family filing an I-829 to remove conditions on residence to appear at an interview at the USCIS office having jurisdiction over either the location of the investor’s commercial enterprise, the investor’s residence in the United States, or the location of the adjudication of the petition, at the agency’s

discretion. These locations could be far from the investor’s residence, so interviews could cause meaningful inconvenience and expense. I-829 Denial Process The regulation clarifies numerous aspects of the process to remove conditions from an investor’s permanent residence based on an I-829 petition, including that a denial of the petition shall result in a “Notice to Appear” that starts removal proceedings where the investor and family can appeal the denial in front of an immigration judge. The regulation says that upon USCIS I-829 denial the investor must surrender the green card and does not say that USCIS will issue temporary evidence pending appeal in removal proceedings, but under the law investors are entitled to such temporary evidence and should demand it. Offering Tweaks The rule allows necessary modification of securities offering documents without jeopardizing any previously filed petitions based on some notion of material change, but it is hard to imagine how any changes necessitated by this rule would trigger such notions as to existing investors anyway. 3. Conclusion Some parties might bring litigation against USCIS to stop the regulation, alleging some fault in the rulemaking process or analysis. Congress might be persuaded to pass a new EB-5 law that overrules the regulation on the investment amount and TEA approach and makes other changes, including integrity measures, and maybe even to increase the available visa numbers (a very politically challenging task). Neither will stop a current rush of investors expecting the rule to take effect as planned.

ROBERT C. DIVINE Vice-President Emeritus, IIUSA; Shareholder and Global Immigration Group leader of Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. Robert C. Divine leads the Global Immigration Group of Baker, Donelson, Bearman, Caldwell, & Berkowitz, P.C., a law firm of over 700 lawyers and public policy advisors with offices in 20 cities in the U.S. including Washington, D.C. Mr. Divine served from July 2004 until November 2006 as Chief Counsel and for a time Acting Director of U.S. Citizenship & Immigration Services (USCIS). He is the author of Immigration Practice, a 1,600 page practical treatise on all aspects of U.S. immigration law now in its Fifteenth Edition (see www.jurispub.com). He has practiced immigration law since 1986 and served seven years as Vice President of Invest in the USA (IIUSA), the EB-5 industry trade association. Under his leadership, Baker Donelson serves a wide range of legal needs for regional centers, developers, and investors, including immigration, securities, business, real estate, tax, international, government investigations, and litigation. This analysis first appeared on IIUSA.org

For more information, visit IIUSA website at www.iiusa.org or contact IIUSA (info@iiusa.org)

87 Citizenship By Investment



T . 1 9 97

Helping over 5,400+ families live their American Dream for.... ...A better family life

...A better retirement

...A better education

...A better business opportunity

THE EB-5 INVESTORS VISA: A PATH TO PERMANENT RESIDENCY FOR THE UNITED STATES The EB-5 Investor Visa Program The EB-5 Investor Visa Program provides immigrant investors a path to permanently live and work in the United States. The program was created in 1990 by the United States Congress as a way to stimulate the U.S. economy through foreign investments. The EB-5 visa category allows qualified foreign nationals to obtain a permanent residency visa (green card) in the U.S. by investing into a new commercial enterprise that creates at least 10 full-time American jobs. Why people immigrate to the United States There are many reasons why people from around the world desire to immigrate to the United States. It may be that they are looking for access to the U.S. business markets, a more stable economy, a better education for their children, religious and political freedoms, to reunite with family, or to retire in a different climate. One of the main benefits for immigrants is the U.S. educational system for themselves or their children. Once an immigrant becomes a permanent resident, their children will be able to attend State

Universities at in-state tuition levels, which could provide savings of tens or even hundreds of thousands of dollars, depending on how many children they have and their educational aspirations. The current environment of the EB-5 program Since 2015, many U.S. lawmakers and industry stakeholders have been pushing for reform in the EB-5 program, but have been unsuccessful in making changes through legislation. However, in July 2019, the United States Citizenship and Immigration Services (“USCIS”), the federal agency that oversees the EB-5 program, announced that new regulations for the EB-5 program would go into effect on November 21, 2019. The new regulations represent the first step of meaningful reform for the EB-5 industry. The main change that will affect those considering immigrating to the United States through the EB-5 program is the significant increase in the investment amounts. The current minimum investment level to apply for an EB-5 visa is $500,000. However, with the recently announced regulatory changes, the minimum amount will increase to $900,000 from November 21, 2019.

CMB Regional Centers CMB is one of the oldest active regional center operators in the EB-5 industry with over 20 years of experience. CMB’s founder, Patrick Hogan, has been involved with the EB-5 program since 1994 and in 1997, CMB Export (CMB’s first regional center) was approved to operate in the state of California. Today, CMB is an operator of 16 approved EB-5 regional centers, with the ability to take on projects in 22 states and Washington D.C. CMB is an EB-5 industry leader in many ways, and has always kept the same philosophy of putting the investor’s goals ahead of their own. Today, CMB has over 5,400 investors from 100 countries that have chosen to invest in one of CMB’s 70 EB-5 investment opportunities. Of the 5,400 investors that have trusted CMB with their EB-5 pursuit, CMB has helped over 4,800 investors achieve an I-526 approval, which allows them to apply for a “conditional” permanent green card for themselves and their qualified family members. CMB has also helped over 1,100 families achieve success of permanent residency in the United States without conditions (green card), and has returned capital to over 1,000 investors. There are very few regional centers that can come close to this level of success for their EB-5 investors.

89 Citizenship By Investment

CMB AND HILLWOOD DEVELOPMENT COMPANY: A SUCCESSFUL EB-5 PARTNERSHIP CMB Regional Centers and our continued success with Hillwood Development Company CMB Regional Centers and Hillwood Development Company are both leaders within their respective industries. CMB has been recognized as a leader and pioneer within the EB-5 industry by different organizations, including IIUSA and EB5 Investors Magazine. Hillwood is one of the largest and most successful developers in the U.S. and has developed projects for over 90 companies listed in either Fortune 500 or Global 500, including Amazon, FedEx, and Wayfair. Together, CMB and Hillwood represent the most successful lender-borrower relationship in the EB-5 industry. CMB and Hillwood partnered for the first time in 2012, when the CMB Group 8 partnership loaned a Hillwood affiliate $65 million in EB-5 investment capital for the development of logistic and industrial facilities near San Bernardino Airport in

California. Since 2012, the limited partners in the CMB Group 8 partnership have achieved the major milestones of success all EB-5 investors strive for: I-526 approvals, I-829 approvals, repayment of the $65 million loan and a return of capital to the investors within the partnership. Group 8 is the first of six loans to Hillwood affiliated borrowers that have now been repaid to CMB partnerships.

partnership across all 27 CMB EB-5 partnerships that financed a Hillwood project. Through these 27 partnerships that CMB and Hillwood partnered together on, there was over $3.5 billion worth of economic spending that stimulated the U.S. economy, helping create nearly 25,000 new American jobs. This is a direct result of the efforts of these two industry leading companies.

Since 2012, 25% of all CMB EB-5 investors have placed their trust in a CMB partnership serving as a lender to Hillwood projects, which spans 27 separate CMB EB-5 partnerships, of which two were raised at the higher investment threshold of $1 million. Of the 27 partnerships, 25 have received I-526 petition approval. The 26th and 27th partnerships, CMB Group 61 and 70, are currently open and available for subscription with petitions on file and pending USCIS adjudication.

Hillwood and CMB continue to work together and have developed a pipeline of future EB-5 projects. This is a relationship that will continue for years to come in assisting EB-5 investors with their goals of immigrating to the United States. CMB has always maintained a consistent approvable structure in each of its EB-5 partnerships. Although there is change coming within the EB-5 program, CMB will continue to be a leader in the industry and structure their partnerships in compliance with the rules and regulations of the EB-5 program.

CMB has been able to consistently replicate the success of the Group 8

Previous Hillwood and CMB Partnerships



1,000+ I-526 Approvals

200+ I-829 Approvals

$750M+ Total EB-5




(1,375 Investors subscribed)


Partnerships with I-526/I-924 approvals (1,325 Investors)


Partnerships with I-829 approvals (412 Investors)


Partnerships with loan repayment ($260M)

Ignacio Donoso, Esq., is Managing Partner of Donoso & Associates, LLC. Donoso & Associates is nationally recognized as a leading business immigration law firm with particular expertise in visas for EB-5 entrepreneurs, companies expanding operations to the U.S., start-ups, skilled professionals, professional athletes and artists in the entertainment industry. Mr. Donosoâ&#x20AC;&#x2122;s career spans 23 years as a lawyer, advising thousands of investors in successfully navigating the U.S. visa system. More recently, Donoso & Associates, LLC expanded its operations to include visas for Canada and Mexico. Mr. Donoso founded Donoso & Associates in 2013, after previously working as Partner of FosterQuan, LLP (now Foster, LLP), one of the top immigration law firms in the U.S. Mr. Donoso has been selected to serve in many National Committees of the American Immigration Lawyers Association (AILA), including the National Annual Conference Planning Committee. From 2013-2018, Mr. Donoso has served on the AIL National EB-5 Committee. Mr. Donoso has been recognized among the Top 25 immigration attorneys in the United States for investor visas in 2015, 2016 and 2018. Mr. Donoso is a frequent speaker at national and international conferences on U.S. immigration law and has frequently published on specific issues related to immigration matters. He has been interviewed on national news media including Fox Business and the New York Times, as well as national television and radio in relation on immigration issues.

7401 Wisconsin Avenue Suite 400 Bethesda MD 20814 E-mail: eb5@donosolaw.com Tel: 01 301-276-0653 www.donoslaw.com 170 Citizenship By Investment



Citizenship By Investment 171

Promoting "Vibe" - a mixed use real estate project in downtown Newark, New Jersey. Available for refundable EB-5 Investment at lower level of $500,000 till Nov. 20, 2019

Concorde EB-5 Advisors operates Regional Centers in New York, New Jersey and Florida

Group III Group V Group VI-C

Group III Group I Group III

Group III

Group III


Group V

Group II

T. 1997

Group I Group III

The measure of success for any regional center is the success of their investors. CMB is proud to have helped over 800 investors achieve I-829 approvals and receive return of capital.

Group B Group VIII

Group V

Contact us for more information: (309) 797 - 1550 www.cmbeb5visa.com

Profile for BLS Media

CBI - Autumn 2019  

Welcome to the Autumn issue of Citizenship-by-Investment 2019, with various changes that has come in the migration and political world. It i...

CBI - Autumn 2019  

Welcome to the Autumn issue of Citizenship-by-Investment 2019, with various changes that has come in the migration and political world. It i...

Profile for bls-media