“Your passport defines your identity as much as it defines the places where you’re able to go and the countries you’re able to live in, invest in and bring your family to if you wish.” (Nomad Capitalist)
Theory
What is Investment Migration? 💭
🛂 obtaining a residence permit or second citizenship in another country by making a substantial investment
💰colloquial referred to as buying a residence permit or citizenship
- increased freedom of travel
- possibility to reside, work, study and own property in another country
- enhanced business and investment opportunities
- reduced personal taxes with the right strategy
- usage of certain privileges in two countries (e.g. social security)
- increased consular protection (usually only granted by the country whose passport was used for entry though)
- political independence and a Plan B
- passing on the privileges to the next generations
- by Birth
- by Descent
- by Marriage
- by Investment
- through Naturalization
Citizenship & Residence by Investment 💸
🏦 obtain residency or citizenship by making a substantial investment
👉🏼 2 types of investment are widespread:
- a non-refundable contribution to a government fund or development project, usually applied by developing countries
- investment into the private sector (i.e. company shares, creating jobs), usually applied by industrial nations
direct and immediate path to citizenship
only a residence permit is granted, but usually citizenship can be obtained through naturalization afterwards
Naturalization 🙋🏽♂️
🏡 obtain citizenship after a certain period of residence in a country
🥰 show attachment to the country (usually pass a language and naturalization test)
🔄 formalized process, usually requiring the acquirement of temporary residence first, followed by permanent residence and finally citizenship
Further Aspects to Consider 🤔
- lawfulness of dual citizenship in the involved countries 🔗
- requirements and length of the application process
- private factors: family, security, climate, cost of living, comfort, daily life
- business factors: economic potential, market and growth opportunities
- passport strength (see Passport Comparison Tools below)
- physical presence requirements
- reputation of the country
- national service obligations
- helpful rankings like the Human Development Index or the Ease of Doing Business Ranking
- Henley Passport Index 🔗: focuses on visa free entries
- Nomad Passport Index 🔗: also takes factors like taxation, perception and personal freedom into account
- obligation to pay taxes in a country is determined on the basis of tax residency
- 4 different taxation systems worldwide to determine tax residency
- Residential Taxation: taxes on the worldwide income based on the country of residence
- Territorial Taxation: taxes only on domestic income, foreign income is tax free
- Non-Dom System: combination of 1. and 2. with tax benefits for foreigners, but mostly complicated to use
- Zero Taxation: no income taxes
- Citizenship-based Taxation (only USA): taxes on the worldwide income irrespective of the country of residence
Regulations for German citizens 👍🏽
- in general: acquisition of a second citizenship automatically leads to a loss of the German citizenship (§25 Abs. 1 S. 1 StAG) ❌
- but 2 exceptions exist ✅
- The second passport is obtained in an EU member state (§25 Abs. 1 S. 2 StAG)
- The applicant receives a personal approval by the German authorities beforehand (§25 Abs. 2 S. 1 StAG)
- the EU Freedom of Movement allows all EU citizens to live, work, study, look for a job and retire in any EU country
- only a valid ID and the registration at a local authority are necessary
- after 5 years of residence, permanent residence is automatically granted and usually citizenship can be obtained through naturalization
legal frameworks: Deutsches Staatsangehörigkeitsgesetz 🔗 and EU Freedom of Movement🔗
Comparative Analysis of 15 selected Countries
Cayman Islands 🇰🇾
⭐️ Program Type: Residence by Investment & Naturalization
✅ Dual Citizenship: allowed
✈️ Visa free entries: difficult legal status due to British Overseas Territory Citizenship (BOTC)
- investment into developed real estate
- temporary: $1.2 Mio., no work permit, limited to 25 years
- permanent: $2.4 Mio., work permit possible, unlimited
- additional fees apply
- $1.2 Mio. investment into a business that creates local jobs
- 25 years validity
- business experience necessary
- physical presence requirements (90 days/year)
- additional fees apply
- own min. 10% of a business in an approved industry OR
- have senior management position
- 25 years validity
- right to work included
- physical presence requirements (90days/year)
⏰ Average time until Residency: 3 months
- possible, but complicated
- first obtain British Overseas territory (BOT) Citizenship after 5 years (no right to work or vote)
- obtain Cayman Citizenship after 5 more years (includes full rights)
⏰ Average time until citizenship: min. 10 years
- tax benefits (0% tax)
- exclusive place to live
- highly developed banking sector
- lower crime rate than other Caribbean countries
Portugal 🇵🇹
⭐️ Program Type: Residence 🔗 through the EU Freedom of Movement & Naturalization
✅ Dual Citizenship: allowed
✈️ Visa free entries: 187
- after 5 years of residence
- processing time ~6 months
- language test (A2 Level)
- favorable: show connections to the Portuguese community
⏰ Average time until citizenship: 5-6 years
- tax benefits through NHR in the first 10 years (Non-Habitual-Tax Regime)
- developed banking system
- attractive place to live
- low cost of living
The linked website by the Portuguese Ministry of Justice still claims that citizenship can be obtained after 6 years, but this is not correct anymore since Portugal changed its legislation in 2018 and now grants citizenship after 5 years of residence.
United Kingdom (UK) 🇬🇧
⭐️ Program Type: Residence by Investment & Naturalization
✅ Dual Citizenship: allowed
✈️ Visa free entries: 185
obtain ILR status (=Permanent Residency, called Indefinite Leave to Remain) after 5 years
obtain ILR status (=Permanent Residency, called Indefinite Leave to Remain) after 3 years
obtain ILR status (=Permanent Residency, called Indefinite Leave to Remain) after 2 years
- no language test
⏰ Average time until Residency: 3 weeks
- Start-up & Innovator Visa: to set up a viable, innovative business with potential for growth and which is approved by authorized body
- Global Talent Visa: for emerging and recognized leaders in specific fields of work
- Ancestry Visa: for Commonwealth citizen
- General Work Visa: for skilled workers in specific fields
- after 5 years in the UK and 1 year under Indefinite Leave to Remain (ILR) status (=permanent residence)
- physical presence requirements:
- not spent more than 450 days outside the UK during the 5 years before the application
- not spent more than 90 days outside the UK in the last 12 months
- intend to continue living in the UK
- pass ‘Life in the UK‘ test about British traditions and customs
⏰ average time to citizenship: 6-7 years
- attractive, multi-cultural place to live
- excellent education institutions
- international business setting: No. 8 on the Ease of Doing Business Ranking
- possible CANZUK alliance between Canada, Australia, New Zealand and the UK
United States 🇺🇸
⭐️ Program Type: Residence by Investment & Naturalization
✅ Dual Citizenship: allowed
✈️ Visa free entries: 185
- $ 500,000 into Targeted Employment Area (rural or with high unemployment)
- $ 1,000,000 into High-Employment Area
⏰ Average time until Residency: 20-24 months
⚠️ there is conflicting information about the investment sums necessary, since the requirements had changed to $900,000 / 1,800,000 in the meantime. Due to a court decision from June 22, 2021 the old amounts are currently valid, i.e. $500,000 and $1,000,000.
- for young adults over the age of 18
- choose from 15 different activity-related visas
- examples: au-pair visa, camp counsellor visa, research visa, teacher visa
- similar to the Working Holiday Visa programs
- for seasonal or temporary agricultural and non-agricultural jobs
- when there are not enough U.S. workers for a particular type of work
- employer needs to apply on person's behalf
Immigrant Visas: Green Card 🔗
- for skilled workers (with advanced degrees or exceptional abilities)
- right combination of education, work experience and extraordinary skills required
- job offer in the U.S. might be necessary
- for family member of U.S. citizens or permanent residents
- citizen can sponsor a spouse, parent, child or sibling
- permanent resident can sponsor only a spouse or an unmarried child
- for immigrants from countries with historically low rates of immigration (German citizens are eligible)
- limited number of visas available each year
- random distribution amongst eligible candidates → "Lottery"
- after 5 years of lawful Permanent Residence
- continuous residence (dwelling place) in the US for these 5 years (no absence of more than 6 months)
- residence in the state or service district having jurisdiction over the application for 3 months prior to filing
- physical presence in the US for at least 30 months out of the five years immediately prior to filing
- read, write and speak basic English
- knowledge and understanding of the fundamentals of the history, and of the principles and form of government, of the USA
- interview with USCIS officer
- attend naturalization ceremony, take Oath of Allegiance
⏰ average time to citizenship: 7-8 years
- strong passport
- settle anywhere in the U.S.
- access to the U.S. American job market and economic area
- No. 6 on the Ease of Doing Business Ranking
- Right to vote in elections for public officials
- Right to apply for federal employment requiring U.S. citizenship
- Right to run for elected office
⚠️ BUT: citizenship-based taxation
Australia 🇦🇺
⭐️ Program Type: Residence by Investment & Naturalization
✅ Dual Citizenship: allowed, if Germany allows it
✈️ Visa free entries: 184
- be nominated by an Australian State or Territory government agency (or Austrade for SIS)
- no history in unacceptable activities
- meet health requirements
- meet character requirements
- sign Australian values statement
- no debt to Australian government
- no previous visa cancellation or refuse
- investment: none
- residence requirements: 1 year
- language requirements: functional English
- age limit: be under 55
- score min. 65 on the points test (age, qualification, experience...)
- successful business career with a business turnover of at least AUD 750,000, ownership and management of an Australian business and net assets of AUD 1.25 million
- investment: AUD 2.5 million into a complying Australian-managed investment fund for the duration of the visa
- residence requirements: 2 years
- language requirements: functional English
- age limit: be under 55
- score min. 65 on the points test (age, qualification, experience...)
- have the right experience
- investment: AUD 5 million into a complying Australian-managed investment fund for the duration of the visa
- residence requirements: 40 days / year
- language requirements: functional English
- investment: none
- residence requirements: 2 years
- language requirements: competent English
- age limit: be under 55
- entrepreneurial activity related to innovation
- receive endorsement by state or territory government
- Premium Investor Stream (PIS) closed
- possible after 3 years
- certain business/investment criteria must be met (see above)
- residence criteria must be met (see above)
- adult child is a citizen or PR of Australia / a citizen of New Zealand
- need to have a sponsor
- meet age requirements
- pass the balance of family test (determine the extent of links to Australia)
- apply with profession on the critical skills occupation list (high-demand professions)
- assessment by the authorities
- choose from different visa schemes according to eligibility
- special program to attract global talents in 10 future sectors
- sectors: e.g. DigiTech, Circular Economy, AgriFood/AgTech, Energy…
- eligibility: internationally recognized with evidence of outstanding achievements
- Talent Officers in Europe, USA and Asia to recruit talents"
- be a permanent resident
- live in Australia on a valid visa for the past 4 years
- permanent resident for the past 12 months
- away from Australia for no more than 12 months in total in the past 4 years, including no more than 90 days in total in the past 12 months
- be in Australia when decision on the case is made
- intend to live in or mainatin lasting link with Australia
- pass citizenship test with min. 75%: knowledge of Australia, citizenship obligations & benefits and country's values
- basic English knowledge
- attend citizenship ceremony within 12 months
⏰ average time to citizenship: 5-6 years
- strong passport
- straight forward, objective, merit-based process
- good base for business and investment activity in Australia and SEA
- access to Trans-Tasman agreement with New Zealand
- possible CANZUK membership with Canada, New Zealand and the UK
- attractive place to live, high living standard
- No. 8 on the Human Development Index (HDI)
- renowned healthcare system
- political, social and economic stability
- ability to apply for permanent residency and citizenship
Singapore 🇸🇬
⭐️ Program Type: Residence by Investment
❌ Dual Citizenship: NOT allowed
✈️ Visa free entries: 192
- permanent residence through an investment of SGD 2.5 Mio.
- designed to attract wealthy foreign entrepreneurs and investors
- extensive application process (see factsheet for details)
- rigorous requirements
- no language test
- intention to live in Singapore
- reside in Singapore for more than half of the time to be able to renew the Re-Entry Permit (REP) after 5 years
⏰ average time to residency: 9-12 months
- for foreign professionals, managers and executives with a job offer in Singapore
- minimum salary and qualifications required
- initially granted for 2 years
for skilled foreign workers in specific sectors
- for entrepreneurs who started, or intend to start, a company
- fulfill specific innovation requirements
for spouses of Singapore citizens or permanent residents
- excellent infrastructure and public services
- one of the lowest crime rates in the world
- high quality of life
- one of the wealthiest countries when measured by GDP per capita
- harmonious multi-racial and multi-cultural community
- political stability, economic prosperity
- reputable education system
- reliable healthcare system
- tax-friendly for foreign investors (territorial tax regime)
- include spouse and children (below 21)
- possibility to apply for citizenship after 2 years of PR 🔗
❌ dual citizenship is not allowed
⚠️ male dependents might be liable for national service
Israel 🇮🇱
⭐️ Program Type: Citizenship through the Law of Return 🔗
✅ Dual Citizenship: in combination with the Law of Return allowed, otherwise not
✈️ Visa free entries: 158
👉🏼 person who was born of a Jewish mother, or has converted to Judaism and is not a member of another religion
- no activity directed against the Jewish people
- no endanger of public health or security
- no criminal past that could endanger public welfare
- no further requirements
- citizenship will be granted automatically after 3 months in Israel, unless specifically rejected
⏰ Average time until Citizenship: 3 months
- strong passport complement to Germany (196 combined entries)
- vibrant place to live
- easy and straight forward process
- not allowed to marry a person from an enemy state
- travel restrictions: no visit to enemy states & denied entry in some countries
- compulsory military service
- high taxes (on worldwide income)
- difficult to renounce Israeli citizenship
- security issues
St. Kitts and Nevis 🇰🇳
⭐️ Program Type: Citizenship by Investment
✅ Dual Citizenship: allowed
✈️ Visa free entries: 157
$150,000 to the Sustainable Growth Fund
- worth min. $ 200,000 (held for 7 years) OR
- $ 400,000 (held for 5 years)
⏰ Average time until citizenship: 3-4 months
- strong passport complement to Germany (195 combined entries including Schengen, UK and Russia)
- attractive place to live
- certain privileges in the UK and Commonwealth
- tax benefits
- no minimum stay
Sweden 🇸🇪
⭐️ Program Type: Residence 🔗 through the EU Freedom of Movement & Naturalization
✅ Dual Citizenship: allowed
✈️ Visa free entries: 187
- after 5 years of habitual residence: live in Sweden with intention to stay
- absence of no more than 6 weeks per year
- processing time ~22 months
- currently no language test
⏰ Average time until citizenship: 7 years
- strong passport
- No. 7 on Human Development Index (HDI)
- No. 10 on the Ease of Doing Business Ranking
- high living standard
North-Macedonia 🇲🇰
⭐️ Program Type: Citizenship by Investment
✅ Dual Citizenship: allowed
✈️ Visa free entries: 125
- 200,000€ for at least 2 years in a private investment fund
- 400,000€ as a direct investment in new facilities employing at least 10 people indefinitely during a period of at least 1 year
⏰ Average time until citizenship: 2-5 months
- visas for work, study, volunteering, medical treatment, research, humanitarian reasons
- residency for EU residents who own a property in North Macedonia
- strong passport
- fast process
- European upper-middle income country
- friendly and hospitable culture
- favorable tax environment (10% flat tax)
- access to a strategically positioned trade market
- official EU candidate
- highly qualified workforce
- fast company registration systems
Canada 🇨🇦
⭐️ Program Type: Naturalization
✅ Dual Citizenship: allowed
✈️Visa free entries: 184
⚠️ The Immigrant Investor Program will be available again from April 1, 2023
- Canadian Experience class for people with work experience in Canada
- Federal Skilled Worker Program for people with foreign work experience
- Federal Skilled Trades Program for people qualified in a skilled trade who have a Canadian job offer
- for skilled workers with education and work experience
- nomination by a specific province / Quebec / one of the 4 Atlantic provinces necessary
- for entrepreneurs who want to build an innovative business and create jobs for Canadians
- support from a designated organization needed
for self-employed people who have experience and want to work in the cultural or athletic sector
permanent or temporary residence for people who will take care of others in need (children, elderly…)
for Canadian citizens and permanent residents who want to sponsor family members to live in Canada
- be a permanent resident
- have been physically present in Canada for at least 3 out of the last 5 years (1,095 days)
- citizenship test (history, geography, economy, government, laws, symbols)
- English or French language skills (CLB level 4 or higher)
⏰ average time to citizenship: 4 years
- attractive place to live
- exceptional educational opportunities
- multi-cultural, open-minded and immigrant-friendly society
- 1 year of free entry to natural parks
- possible CANZUK alliance between Canada, Australia, New Zealand and the UK
New Zealand 🇳🇿
⭐️ Program Type: Residence by Investment & Naturalization
✅ Dual Citizenship: allowed, if Germany allows it
✈️ Visa free entries: 186
- 10 Mio NZD (over a 3 year period) in acceptable investments
- 44 days in each of the last two years of the three-year investment period
OR
- 88 days over the entire three-year period if invest at least NZD 2.5 million in growth investments
- no further requirements
⏰ Average time until Residency: 5-6 months
- 3 Mio. NZD (4 year period) in acceptable investments
- 146 daysper year during the investment period
OR
- 438 days over the entire four-year investment period if invest at least NZD 750,000 in growth investments
- English-speaking background
OR
- International test report with overall band score of 3 or more
OR
- competent user of English
- business experience
- aged 65 years or younger
- pass eligibility test
⏰ Average time until Residency: 18 months
- Skilled Migrant Category Resident Visa for people with skills, experience and qualifications needed in NZ
- Talent Work Visa for people with a special talent in arts, culture, sports
- Business Visitor Visa for business visits of up to 3 months
- Working Holiday Visa
- for studies of up to 4 years
- confirmation of enrollment from an approved education provider necessary
- enough money to support yourself
- Entrepreneur Work Visa for experienced business people who want to set up or buy their own business
- Global Impact Work Visa for innovative entrepreneurs who are selected by the Edmund Hillary Fellowship
- usually subsequent visas after a first visa in another field
- Parent Retirement Resident Visa for parents of NZ citizens/PRs, but annual income of NZ$ 60,000 and investment of NZ$ 1 Mio. necessary
- Family Visas for spouses of NZ/AUS citizens and permanent residents, for parents born in Australia...
- resident for min 5 years
- min. 1350 days of physical presence within those 5 years
- in NZ for min. 240 days each year within those 5 years
- intention to live in NZ in the future
- hold a basic conversation in English
- attend naturalization ceremony and take Oath
⏰ average time to citizenship: 6-7 years
- strong passport
- high living standards
- political & economic stability
- full economic and social rights
- No. 1 on the Ease-of-Doing-Business Ranking
- access to Trans-Tasman agreement with Australia
- possible CANZUK membership with Canada, Australia and the UK
- unlimited stay with both Investor Visas (possibility to apply for permanent residence with Investor 1 visa)
- possibility to apply for citizenship
- get back investment at the end of the term
Vanuatu 🇻🇺
⭐️ Program Type: Citizenship by Investment
✅ Dual Citizenship: allowed
✈️ Visa free entries: 135
- $130,000 donation to government investment fund
- completely remote process
- no language or residence requirement
- bank account balance of $250,000 required
⏰ Average time until citizenship: 1-2 months
- good passport complement to Germany (194 combined entries)
- very cheap & fast program
- completely remote
- no language or residence requirements
- long-term visas for the U.S. (B-1 / B-2 tourist visas immediately for 5 years)
- tax benefits
- attractive place to live
Thailand 🇹🇭
⭐️ Program Type: Residence by Investment
❌ Dual Citizenship: NOT allowed
✈️ Visa free entries: 79
- temporary residence through different investment options starting at ~16,000€ for 5 years
- very flexible program, choose from 7 different options
- no age, language or physical presence requirements
- fast and efficient processes (2-3 months)
- VIP service can be included (private Airport Transfers, personal concierge, 24/7 hotline)
- THB 600,000 (one time fee including VAT)
- 5-year privilege entry visa
- no annual fee
- THB 800,000 (one time fee including VAT) for a minimum of 2 people
- 5-year residence visa for each member
- able to include (step)parents, spouse, (step)children (extra charge)
- no annual fee
- THB 1 million (one time fee including VAT)
- 20-year privilege entry visa for individuals
- no annual fee
⏰ Average time until Residency: 2-3 months
non-immigrant visa to qualify for PR and citizenship
- applied for by the employer for a specific position
- becomes invalid with change of job or position
- for people older than 50 years
- min. monthly income of THB 65,000 (~1800€)
- efficient & fast application process
- very flexible
- no minimum residence requirements
- VIP services possible
- affordable and high standard of living
- territorial tax system
- attractive place to live
⚠️ Elite Residence Program does not lead to PR or citizenship
❌ Dual Citizenship is not allowed (rare exceptions are possible though)
Argentina 🇦🇷
⭐️ Program Type: Residence by Investment & Naturalization
✅ Dual Citizenship: allowed
✈️ Visa free entries: 170
- ARS 1,500,000 into productive, commercial or service enterprise of interest for the country
- showing the business has a high chance of success
- presenting track record, qualifications, and capability
- invest at least $50,000
- be a high-net-worth individual (assets > USD1,000,000),
- be a leader in your field, have a track record of success
- no language or residence requirements
- issued for 1 year, renewable for up to 3 years
⏰ average time to Residency: several months
- proof of identity necessary
- police clearance
- steady and guaranteed income ($2,000 / month)
- only for self-employed work
- proof of identity necessary
- police clearance
- steady and guaranteed income ($500 / month)
- 2 years of documented and uninterrupted stay
- sufficient means to support yourself (i.e. job contract)
- no formal language requirements but you need to talk in Spanish to a judge during the process
⏰ average time to citizenship: 2-3.5 years
- strong passport
- very fast and easy
- private and business access to South America (MERCOSUR)
- attractive place to live
- eligibility for citizenship after 2 years and permanent residence after 3 years"
Best Practices
Enhanced Freedom of Travel
✈️ the German Passport grants visa-free access to 190 countries
💪🏾 it’s currently one of the most powerful passports worldwide
👉🏼 enhancement of travel is possible by filling the gaps of the German passport
Work & Life Benefits
📈 several rankings in regard to work & life aspects available
🏆 overall winner: Portugal (followed by Canada and Singapore)
⚠️ BUT: it largely depends on the personal needs and preferences which aspect should be emphasized the most
👉🏼 aspects taken into account: cost of life, health care system, educational possibilities, labour market, security situation, possible language barriers and environmental and climate conditions
👉🏼 source 🔗
Tax Relief Schemes
👉🏼 5 strategies based on the 4 taxation systems
❗️important: legally lower your taxes
Discussion
👉🏼 according to the literature the programs can be divided into 2 main types according to the type of investment:
- contributions and donations to Governments, mostly used by smaller developing countries that offer Citizenship by Investment
- investments into the private sector, mostly used by industrial nations in the context of Residence by Investment
👉🏼 according to the literature the programs can be characterized by 3 major criteria:
- type and amount of investment
- obtainable status and residence requirements
- means to secure the integrity of the programs
- language and knowledge requirements
1 more criterion is identified:
👉🏼 both propositions can be confirmed ✅
🇮🇱 Israel is mentioned due to it’s unique characteristics although it does not offer any Investment Migration program
🌎 a global trend can be identified since supply and demand rise and more and more countries allow dual citizenship
🚧 limits arise due to the scope of the thesis, and especially interesting trends in the area of citizenships and residence permits cannot be covered, e.g.
- Digital Nomads and the Crypto-Community
- Remote Working
- Retirement Visas
Downloads & Contact
- Bachelor-Thesis 🔗
- PowerPoint Presentation 🔗
- Excel-Sheet with all countries in detail 🔗
- Infographic 🔗
tim.guenster@tum.de | LinkedIn 🔗