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Citizenship by Real Estate Investment: The Top Global Programs

David Bonellie

David Bonellie

Last updated: November 16, 2023

Citizenship by Real Estate Investment: The Top Global Programs

Citizenship by investment has become an important consideration for investors because it can provide them with several benefits. Obtaining a second citizenship and Golden Visa with a clear path to citizenship is an attractive option for high-net-worth individuals looking to diversify their portfolios and secure their future.

It can provide greater freedom of movement, allowing easier travel to countries without requiring visas or other restrictive travel documents. Additionally, the programs provide access to better business opportunities and improved political and economic stability in the country where they acquire citizenship. 

High net worth individuals (HNWI) use a second citizenship to diversify and protect their assets and potentially reduce their tax liability. Lastly, it can also provide a sense of security for the investor and their family. It it allows them to relocate to a new country in the event of political or economic instability in their home country. 

Multiple investment options are available to applicants to obtain their citizenship or Golden Visa. Some investors opt to make a sizable donation or Government contribution. Others look to make business or fund investments. These options carry additional risk to an investment or 100% as the donation is a non-refundable option. Investors do not get their money back. 

The citizenship by real estate investment route is often the smart choice as property. Land values generally hold their value when compared to other investments, even in the backdrop of looming recessions and negative global outlooks. The real estate investment is also rented out to holidaymakers or long-term tenants to collect a passive income. 

Using Real Estate Investments to Build a Passport Portfolio

Diversifying your investment portfolio by purchasing property in different locations worldwide can be an intelligent strategy. It allows you to spread your risk across other markets and provides a hedge against currency fluctuations. 

Owning property in different countries can allow you to take advantage of other economic conditions and growth prospects. The magic of growing your property portfolio in countries that offer citizenship in return is that you can increase your passport portfolio simultaneously.

Where Are the Top Citizenships by Investment Programs?

So which programs offer a real estate investment option, and what are the precise criteria for an applicant and their family to obtain their citizenship or Golden Visa?  

Citizenship by investment programs, also known as economic citizenship programs, are found in the Caribbean and Europe, with a handful of other countries in the South Pacific and parts of Asia. 

The Caribbean Islands Citizenship by Real Estate Investment

The Caribbean is widely known internationally for its citizenship by investment programs. Saint Kitts and Nevis program sprung its roots immediately after independence from the United Kingdom in 1984. 

Several island nations in the South Pacific started introducing their programs in the late 1980s but received much international scrutiny as there needed to be more structure and due diligence. These programs were duly closed while other Caribbean countries started introducing their economic citizenship programs backed by official Government legislation. 

The primary citizenship by investment programs countries in the Caribbean include:

  • Antigua and Barbuda;
  • Commonwealth of Dominica;
  • Grenada;
  • Saint Lucia; and 
  • Saint Kitts and Nevis.

The Caribbean is a thriving tourist destination hub in the Western Antilles and Leeward islands. Development on the islands is growing at a tremendous rate as major infrastructure projects get rolled out that improve the overall status of the islands. 

Additional developments in hotels, resorts, residential housing, and commercial businesses are key focus areas. These improvements in day-to-day living have enticed thousands of people to obtain economic citizenship. At times it is beneficial to become tax residents by living the majority of the year in their newly acquired country. 

Typical Investment Opportunities

Although each program will develop its investment criteria for applicants to be eligible for citizenship, there are overlaps in each Caribbean program. All programs have a donation or Government contribution as well as real estate investment options for their applicants. 

The donation option is a lower value on all programs. However, it is a non-refundable donation. The donations start at $100,000 but can increase to $150,000 for a single applicant. The investor will not get any portion of their money back using this option. The real estate investment options allow an investor to purchase various types of property. They can sell the property after holding for three to seven years, depending on the program. 

The applicants can use their real estate investment to generate passive income from rental income over five to seven years. The investors can often secure a fixed rate on annual rental yield through the developers to reduce their risk. The income earned improves their return on investment. Four of the five programs have a real estate investment option at $200,000, and one (Grenada) has an option at $220,000. 

Other investment routes include purchasing Government bonds, investing in public and private projects, or investing in businesses on the islands. 

Looking more closely at each program provides the investor with the information required to make a better-informed decision on which might be best suited to them. 

Antigua and Barbuda

In 2013, Antigua and Barbuda introduced a citizenship by investment program intending to attract foreign investments, promote economic growth, and direct funds toward essential institutions such as universities and hospitals. 

The investment options for Antigua and Barbuda are:

  • Real Estate Investment: A minimum investment of $200,000 in an approved real estate project if combined with a second investor;
  • National Development Fund (NDF) Contribution: A one-time, non-refundable contribution to the NDF of a minimum of $100,000 and $125,000 for a family of five (excluding Government fees of $30,000);
  • University of West Indies Fund (UWIF) Contribution: A donation of $150,000 for a family of six; and
  • Business Investment: A minimum investment of $1,500,000 in an approved business.

The Antiguan Government offers two pathways for applicants to qualify for citizenship through the real estate investment option. One option is for an applicant to purchase property valued at a minimum of $400,000 and hold the title deed. Another option is for two applicants to make a joint purchase. The property must be valued at a minimum of $400,000. Each applicant must invest no less than $200,000 and holding the title jointly. The applicant cannot sell the real estate investment property within the first five years after purchase.

Applicants using the real estate investment option need to pay $30,000 in Government fees for the first four applicants and $15,000 for any additional applicants. 

The Commonwealth of Dominica 

Dominica’s citizenship by investment program, which has been in existence since 1993, has been able to offer affordable investments and is consistently attracting new applicants. The Government of Dominica uses the funds generated from this program to support healthcare and infrastructure projects and enhance the country’s tourism industry, which is considered vital for its future growth.

The investment options for Dominica are:

  • Real Estate Investment: A minimum investment of $200,000 in an approved real estate project; and
  • Economic Diversification Fund (EDF) Contribution: A one-time, non-refundable contribution to the NDF of a minimum of $100,000 for a single applicant. $150,000 for a principal applicant and spouse, and $175,000 for a family of four.

Dominica‘s citizenship by investment legislation allows applicants to make a real estate investment in authorized property. The investor must hold the real estate for three years. There is a five-year timeframe if the future purchaser is also citizenship by investment applicant. 

There are Government fees when purchasing the property:

  • $25,000 for the principal applicant; 
  • $35,000 for the principal applicant and up to three dependents; 
  • $50,000 for the principal applicant and up to five dependents; and 
  • $25,000 for any additional qualified dependents.

Please note that the prices and options may change. Checking with the Government of Dominica for the most recent information on their investment options is advisable. Although the contribution option may be enticing for a single applicant, the real estate investment route shows significant value for a family looking for dual citizenship. 

Grenada 

Grenada’s citizenship by investment program, also known as the Grenada Citizenship by Investment Program (GCIP), was launched in 2013. The program aims to attract foreign investment to the island nation of Grenada by offering individuals and their families the opportunity to gain citizenship in exchange for making a significant economic contribution to the country. 

Citizens can be eligible to apply for the US E2 investor residence program after meeting specific criteria as Grenadian citizens. The E2 investor residence visa is significantly cheaper than the EB5 investment visa, saving applicants hundreds of thousands of dollars.

The investment options for Grenada are:

  • Real Estate Investment: A minimum investment of $220,000 in an approved real estate project. The investor purchases a share in a unit but does not hold the title deed to a freehold property. Investors must retain their share in the real estate investment for at least five years; and
  • National Transformation Fund (NTF) Contribution: A one-time, non-refundable contribution to the NDF of a minimum of $150,000 and $200,000 for a family of four. There is $25,000 for each additional dependent.

Obtaining citizenship in Grenada through real estate investment involves investing in Government approved development. These projects currently include the construction of hotels, villas, and resorts. 

With the increasing popularity of tourism, there is a growing need for accommodation for tourists. As such, investing in real estate developments can be a lucrative opportunity for those looking for high returns on their investment.

The real estate investment option carries a $50,000 Government fee for the first four applicants and $25,000 for any additional applicants after four.  

Saint Kitts and Nevis

The original Caribbean citizenship by investment program is Saint Kitts and Nevis. The program’s first iteration, which ran from 1984 to 1991, required a donation to the Sugar Industry Diversification Foundation (SIDF). In 2011, the Government of Saint Kitts and Nevis introduced a new real estate investment option that allowed citizens to invest in approved developments.

Further changes were made to the real estate investment option in November 2020, allowing investors to purchase freehold property on the island and hold the title deeds. The initial twelve-month trial period has been made permanent by the Government. 

The CIU in St Kitts and Nevis introduced a six Limited Time Offer (LTO) in 2023 for the Sustainable Growth Fund: 

  • Sustainable Growth Fund (SGF) Limited Time Offer: A one-time, non-refundable contribution to the SGF of a minimum of $125,000 for a single applicant. $175,000 for a principal applicant and spouse. $195,000 for a family of four. There is $10,000 for each additional dependent under eighteen and $25,000 for dependents over eighteen.

Regular investment for St Kitts and Nevis options include:

  • Real Estate Investment: A minimum investment of $200,000 in an approved real estate project combined with a second investor (total of $400,00);
  • Private Real Estate Investment: A minimum of $400,000 in a free-standing private dwelling on the island; 
  • Sustainable Growth Fund (SGF) Contribution: A one-time, non-refundable contribution to the SGF of a minimum of $150,000 for a single applicant. $150,000 for a principal applicant and spouse, and $170,000 for a family of four. There is an additional $10,000 for each additional dependent under eighteen and $25,000 for dependents over the age of eighteen; and
  • Public Goods Investment Option (PGIO): An investment in social infrastructure and housing, the minimum contribution amount is $175,000. 

The real estate investment follows two legal streams: developers cannot sell developments before being approved by CIU in St Kitts and Nevis. There are Government fees of $25,000 for the principal applicant. $15,000 for a spouse. $10,000 for each additional dependent under eighteen, and $15,000 for dependents over eighteen.

The approved developments further require applicants to golf the real estate investment for a minimum of seven years if they opt for the $200,000 option. It is reduced to five years when making the total investment of $400,000. 

Investors cannot sell their holdings within the first seven years. Additionally, a new law restricts applicants from selling their property to another citizenship by investment applicant. Applicants cannot convert the approved development into apartments or condominiums after the initial approval. 

Saint Lucia

Saint Lucia is the youngest of five Caribbean countries with a citizenship by investment program. The island is incredibly popular with US citizens as it is a significant tourism destination for visitors from the Continental US. In 2015 the Government started to accept citizenship by investment applicants to attract foreign investment and boost economic growth and development. 

The program offers several investments to gain citizenship, including being the only island to provide a Government bond option. Other investment routes include a Government contribution, investment in real estate developments, and approved enterprise projects.

The investment options for Saint Lucia are:

  • Real Estate Investment: A minimum investment of $200,000 in an approved real estate project in resorts or boutique hotels. The investor will own the title deed of their real estate investment;
  • National Economic Fund (NEF) Contribution: A one-time, non-refundable contribution to the NEF of a minimum of $100,000 for a single applicant. $140,000 for a principal applicant and spouse. $150,000 for a family of four. There is a $25,000 fee for each additional dependent outside of the immediate family. $15,000 for immediate family dependents; and
  • National Action Bond (NAB): An applicant may invest in the NAB of St Lucia for $300,000. The applicant of the non-interest-bearing bonds can sell them after five years. The NAB has a $50,000 Government fee. However, there are no additional fees for any additional qualifying dependents added onto the principal applicant; and
  • Enterprise Projects: There are currently no open projects. The St Lucian Government is open to receiving proposals from investors. Single investors need to propose a $3.5m investment, while dual applicants need to propose a $6m investment (maximum of 6 investors x $1m each). 

The Saint Lucian real estate investment route is likely to grow as it is now in line with other programs. The $200,000 investment enables the applicants to physically hold the title deed. St Lucia’s cruise terminal in Castries is one of the largest in the Caribbean and consistently expanding, with new real estate and commercial developments built each year. This is a fantastic opportunity for investors to obtain Saint Lucian citizenship.

There are Government fees when purchasing the property:

  • $30,000 for the principal applicant; 
  • $45,000 for the principal applicant and up to three dependents; 
  • $5,000 for qualifying dependents under eighteen years old; and 
  • $10,000 for any additional qualified dependents over eighteen.

European Union Citizenship by Real Estate Investment

European citizenship is a sought-after asset for many non-EU nationals. EU citizenship provides several social and economic benefits to its citizens. 

The European Union only has one active citizenship by-investment program at the moment. Maltas Exceptional Investor Naturalization program allows an applicant to fast-track citizenship after only holding residence for twelve months.  

Malta

The first iteration of the Maltas Exceptional Investor Naturalization (MEIN) program was launched in 2013. However, after several years the program relaunched in November 2020 with several new requirements. 

The program allows applicants to apply for citizenship after holding residence for twelve or thirty-six months, depending on their investment route. The applicant does not have to reside in Malta for this period but does need to be present when completing their biometric residence and receiving their naturalization certificate for citizenship.

MEINs program requires the applicant to complete the below investments:

  • Real Estate Investment: Applicants can make a freehold real estate investment of €700,000 and hold for at least five years. OR sign a long-term rental agreement with an annual value of no less than €16,000 per annum. Applicants must have a lease for five years; 
  • Government Contribution; A one-time, non-refundable Government contribution of €750,000 to be eligible to apply for citizenship after twelve months of holding residence. OR €6000,000 to be eligible to apply for citizenship after thirty-six months; and
  • NGO Donation: Make a €10,000 donation to an approved NGO.

Real estate investments in Malta are something highly valued on the Mediterranean island. The applicant can choose their property type. There are no restrictions to a hotel or resort-type accommodation on the island. Freedom of choice when making a sizable real estate investment allows the applicant to try to maximize their return on investment over five years. 

Montenegro

Montenegrin citizenship by investment is no longer active in its current form. The program, scheduled to run for three years from 2019 to 2022, has had calls from senior cabinet officials to be reinstated to continue to attract foreign investment to the country. 

Despite strong calls from the EU to permanently cease the program, The Finance Minister believes a program has significant potential to continue to attract foreign investment and increase Government revenues.

Rest of the World’s Citizenship by Investment

There are two additional citizenship by investment programs worthy of including, and both provide exceptional opportunities for obtaining second citizenship by investing in real estate. 

Turkey and Vanuatu are popular choices for diversifying a passport portfolio, and both have significant regional benefits in terms of visa-free travel and business purposes. 

Turkey (Republic of Türkiye)

The Republic of Türkiye‘s citizenship by investment program is possibly the largest in terms of applicants each year. Since its modified program in 2016, the real estate investment has stood at $250,000. Additional changes increased the minimum value to $400,000. The increase has had little impact on the number of applicants as the program continues to succeed. Turkey is a treaty country with the US, allowing citizens to be eligible to apply for the E2 investor resilience permit after meeting specific criteria. 

The investment options for Turkey include the following: 

  • Real Estate Investment: A property purchase of at least $400,000 equivalent in Turkish Lira. The property cannot be resold to another citizenship by an investment applicant. 
  • Capital Investment: Investors can invest $500,000 equivalent in Turkish Lira into Government Bonds, Investment Funds, opening a business, or making a bank deposit. After three years, the investor can sell the real estate investment.

The real estate market in Turkey has been growing in recent years. The country becoming increasingly popular among foreign buyers, particularly those from Middle Eastern neighbors. 

Investors must consider the depreciation of the local currency in Turkey. Although the transaction must be in Turkish Lira, real estate in Turkey holds its value against the US dollar. Investors must consider forex changes when deciding which investment might be best. 

As a result of the increased demand from foreign buyers, prices for both residential and commercial properties have been rising. Major cities such as Istanbul, Antalya, and Bursa are particularly popular among investors. 

Notable Golden Visa Programs in the European Union 

If citizenship by investment program is not an ideal investment decision for an applicant, they can invest in European Golden Visa programs. These allow an investor to obtain temporary and, at times, permanent residence after making a qualifying investment. All Golden Visa holders can live permanently in the country of investment if they choose. They can travel also throughout the EU without obtaining a Schengen visa.

The largest three countries in terms of annual applicants for Golden Visas in Europe are Portugal, Greece, and Spain. Most applicants are real estate investors, regardless of the program. 

Portugal

The Portuguese Golden Visa program is the only tangible European program with a straightforward citizenship route. The reduced physical presence requirement of only thirty-five days over five years allows applicants to realistically be eligible to apply for citizenship without physically moving to the country. 

The real estate investment options include: 

  • Residential or Commercial Real Estate Investment: Real estate purchase with a value of at least €500,000. Options include buying a new property or a resale property. Applicants can reduce the investment to €400,000 in a low-density area; and
  • Residential or Commercial Real Estate Investment: Investment into Government approved urban rehabilitation projects with a minimum investment of €350,000. Applicants can reduce the investment to €280,000 in a low-density area.

It’s worth noting that the investment in real estate must be maintained for a minimum period of five years. Investors can sell the property after five years. There are restrictions for residential property in major metropolitan areas. 

Greece

Greece’s Golden Visa program attracts thousands of applicants seeking permanent residency (PR) in Europe immediately after their application is approved. There is no physical presence requirement to maintain PR. An applicant must permanently reside in Greece for at least seven years to be eligible for citizenship. 

From 1 May 2023, the real estate investment options include: 

  • Commercial and Residential Real Estate Investment: Property investment of €500,000 or more in the following areas. Northern, Central, and Southern Athens, in the Municipality of Vari, Voula, Vouliagmeni, Thessaloniki, Mykonos, and Santorini.
  • Commercial and Residential Real Estate Investment: Property investments of €250,000 or more are considered eligible investments for the Greece Golden Visa Program in any region not mentioned in the municipalities above. 

The real estate investment of €250,000 will still apply for investors who will deposit 10% by 30 April. The final requirement is to complete the purchase by 31 December.

Spain

The Spanish Golden Visa does not allow for direct citizenship by investment but is a great tool to obtain residency by investing in real estate. 

Citizenship requires an applicant to live permanently in the country for a minimum of ten years and does not allow dual citizenship for most existing nationalities. The Golden Visa program provides a stepping stone for investors to obtain European residency. The pathway is relatively straightforward to permanent residence after five years. The initial visa is two years and five years after the initial renewal. 

The real estate investment options include: 

  • Commercial and Residential Real Estate Investment: Property investment of €500,000 or more. Real estate investment can be for one property or multiple properties. The investment residence laws do not declare that the investment total is for one real estate transaction.

Spain is Europe’s second top-visited destination. Over eighty million tourists visiting the country each year. High tourism allows investors to rent their property for good returns regardless of “the season.” 

Global Residence Index Program Comparison Tools

The multitude of citizenship and Golden Visa programs can be complex for investors to navigate and decide which may be best suited to them. The Global Residence Index team has a comparison tool to assist in the process. 



The tool allows prospective investors to easily see different programs side by side and interchange countries as they wish. Additionally, the team has built comparison guides for client viewing. 

What Program is Best for Real Estate Investing? 

Unfortunately, there is no straight answer for the best program. Real estate investing is something that, if done strategically, can provide an investor with a lot of wealth and passive income. Diversifying in different countries allows an investor to reduce risk while building a passport portfolio. 

It is often the case that clients invest in multiple programs. They first look to invest in obtaining citizenship in the Caribbean or Turkey within a matter of months. Investors make an additional real estate investment in Europe to get a residence and use it to visit or to move whenever they choose.

The Global Residence Index team is on call to give you expert consultation. We look to provide solutions best suited to your needs in the short, medium, and long term. 

FAQ

What is the fastest real estate by investment program?

Saint Kitts and Nevis have introduced their fast track option that can yield an approved application within forty-five to sixty days. 

Can I obtain European Union citizenship using the real estate investment option?

Yes, Maltas Exceptional Investor Naturalization allows an applicant to apply for citizenship after holding a residence permit for twelve months. 

Is it possible to sell your real estate investment after receiving citizenship? 

In most cases, a real estate investor must hold their investment for between three to seven years before being allowed to sell. 

Can I utilize more than one citizenship by real estate investment program?

Yes, many investors opt to use multiple programs worldwide to build not only their real estate portfolios but also their passport portfolio. 

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