JOURNAL OF COMPARATIVE POLITICS @ vol. 17 © no. 2 © 2024 66
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T H E G O L D E N V I S A : H O W C A N O N E A C C E S S T H E
E U A N D F O R W H A T P R I C E ?
Markéta P I T R O V Á and Caroline BINDAČOVÁi
The offer of a golden visa, also known as a residence by investment
(RBI) programme, is a wayfor EU member states to attract foreign
investment, yet there are also economic, political and security risks,
which is why EU institutions are critical of the practice. This study
compares the costs of all the RBI regimes in the EU-27 and
categorizes their models. Since 2018, when the European parliament
published an extensive study ofthe issue, some countries have limited
or abolished their programmes. However, despite the pressure, RBI
programmes are still offered by 14 EU countries as of2023. The text
outlines the current conditionsfor obtaining a golden visa in the EU
and identifies the countries with the lowest investment requirements.
With the exception of Cyprus, all ofthe options arefrom countries in
the Schengen area, which highlights the risks associated with free
movement ofinvestors.
Key words: golden visa; EU countries; residence by investment
programmes; investment migration.
i INTRODUCTION
The phenomenon of the so-called "golden visa", or giving residence permits to
investors (residence by investment programmes, RBI) is often discussed in
connection with the promotion of European values, but it is above all a security
risk, as the new resident's entry into one country allows them to move to others
within the Schengen Area, to which all but two EU countries belong. European
legislation does not regulate RBI and the arrangements by which it is offered are
within the competence of member states. The granting of golden visas is
insufficiently coordinated, the checks set up in the Schengen system are often
circumvented, and the information about the process - including rejected
applicants - is not shared. This ultimately encourages visa tourism. Although a
third-country citizen's application for a visa and their investment may be
1
Markéta PITROVÁ is an associate professor in the Department of International Relations and
European Studies at the Faculty of Social Studies, Masaryk University, Brno, Czech Republic.
Contact: pitrova(5>fss.muni.cz Caroline BINDAČOVÁ is Master's student at the Faculty of Law,
Masaryk University, Brno, Czech Republic. Contact: 510302(5)mail.muni.cz
JOURNAL OF COMPARATIVE POLITICS 67
legitimate, connecting investment with the offer of a residence permit increases
opportunities for money laundering, tax evasion, and corruption. According to a
European Commission report, most applications may be by individuals, but
organized crime is also involved, penetrating the EU from outside (EC 2019).
The war in Ukraine has given a new impulse to the effort to resolve the RBI issue,
with the European Parliament (EP) calling on member states "to stop operating
their CBI (citizenship by investment) and RBI schemes for all Russian applicants
with immediate effect" and subsequently to adopt a proposed "regulation of
various aspects of RBI schemes" (EP 2022a). Another reason for establishing RBI
rules is future EU enlargement, planned in the Balkans and potentially the postSoviet
republics. By opportunely timing their golden visa application in a
candidate country, RBI residents, after enlargement, would gain residency within
the whole EU.
This analysis of the RBIs on offer in the EU in 2023 was inspired by a study by the
European Parliamentary Research Service (Scherrer and Thirion 2018), which
aimed to identify schemes that minimized the demands on applicants and
maximized the rights they obtained in terms of mobility and tax advantages. The
EPRS study did not aim directly to identify the financially most accessible offer
but sought to make a comprehensive assessment of attractiveness to investors,
including the possibility of gaining a golden passport. The study listed the
following eight countries as having the most accessible RBIs in 2018: Bulgaria,
Cyprus, Estonia, Ireland, Italy, Latvia, Malta and Portugal.2
The empirical analysis presented here is based on the premise that the risks
connected with visa holders increase with their entry into the Schengen Area.
The study, therefore, does not consider the naturalization of visa holders or other
aspects linked with obtaining a golden passport. Nor does it investigate other
procedures for awarding visas, which may also involve risks. Rather, it
investigates the costs of every RBI regime in the EU-27 and reviews the positions
of European institutions concerned with the issue. The paper analyses how RBI
is set up in the various countries that offer it. It then categorizes the models and
documents the level of investment required by the various regimes. It does not
consider the administrative fees for legal transactions, which may differ
according to the applicant's place of origin and the number of people applying
(e.g., if family members are involved). Data come from primary sources, typically
the websites of state authorities, in particular of ministries (most often the
ministries of the interior, migration, asylum, or foreign affairs), as well as
immigration authorities and agencies authorized by the state. In some cases, the
initial data were obtained from direct communication with embassies and by
reviewing immigration legislation.
The text answers the following questions: What are the current conditions for
obtaining RBI in the EU, and which countries demand the lowest investment and
in which category? Which of the current offers provides a guarantee of movement
in the Schengen Area and, as such, offers the biggest advantages in terms of
mobility?
The search for answers to these questions faces many limitations. First of all, this
area is very opaque, as has been discovered not just by academic researchers but
2
Greece's strategy is much discussed. The country is not mentioned in the EPRS study because it
does not offer tax advantages. However, the study does confirm that it offers one of the "cheapest"
RBI programmes (Scherrer and Thirion 2018,16).
JOURNAL OF COMPARATIVE POLITICS 68
also by European institutions (EC 2019, 20). A study going beyond analysis of the
basic national legal set-ups is nearly impossible because many countries do not
publish their procedures or the numbers of applicants and rejected investors.
The agenda is also subject to rapid developments, not just due to pressures
exerted by international events but also the positions of various national and
European actors. The field can be chaotic, with a state offering multiple RBI forms
concurrently, or investment programmes may be withdrawn and new ones
launched, often differing only in name or with minor changes to the conditions
(Surak 2022, 9).
Initially, we will define the relevant terms, exploring their evolution and
significance. We will delve into the golden visa phenomenon, which is closely
linked to the golden passport, highlighting their similarities and differences.
Additionally, we will outline the risks associated with this phenomenon, which
have prompted the EU to take action. We will also touch upon the changes in
state-level strategies that have occurred. The central focus is on the situation in
the EU-27 in 2023. We categorize the various options available and detail the
required investment thresholds. Finally, we provide a clear and concise overview
of the most viable programmes in each category.
2 FROM GOLDEN PASSPORTS TO GOLDEN VISAS
As a research topic, golden visas were long overshadowed by the more serious
phenomenon of the sale of golden passports, also described as citizenship by
investment programmes (Brink 2017,1). The awarding of citizenship is seen by
states as "a core element of sovereignty" (Maas 2016, 533), and they have
traditionally taken various approaches to the subject. States may also have
special procedures.3
Such diversity was not a subject of dispute until the "talent
for citizenship" model was transformed into the "money for citizenship" model
(Brink 2017, 3). CBI was introduced in Malta in 2014, and its programme
received more attention than those of Cyprus and Bulgaria due to Malta's regular
Schengen member status (Carerra 2014; Parker 2017, 339; Maas 2016).
The Maastricht Treaty, signed in 1992, defined European citizenship in Article B
of the Treaty on EU and Article 8 of the Treaty on EC as a set of rights, but not
obligations (Kochenov 2014). It also left untouched the citizenship strategies of
individual member countries in its Declaration no. 2, which no longer granted
only national, but now, automatically, also European citizenship. Applying for a
golden passport was no longer an attempt to "obtain the privileges and shoulder
the burdens of that country, but instead to secure the economic benefits of EU
citizenship" (Moritz 2015, 232). Dzankic aptly illustrates the character of EU
citizenship applicants, noting that after 1993 the term "stakeholder" (Bauböck
2007) was replaced by "stockholder" (Magni Berton 2014). Unlike a stakeholder,
who has "a genuine interest in the future well-being and prosperity of the
community" (Dzankic 2015, 20), for the stockholder, citizenship is merely a
means "to the materialization of their personal interest" (ibid., 4). The meaning
of citizenship, which became a type of "insurance policy" (Moritz 2015, 260), was
3
There are two fundamental principles:jus soli andjus sanguinis. Originally, citizenship was linked
with a person's place of birth {jus soli) or parentage {jus sanguinis). Obviously either of these
principles is incompatible with a second citizenship (Moritz 2015, 236-237). States may often
apply non-transparent specific discretionary procedures and award citizenship to foreigners on
a case-by-case basis if it is a matter of "national interest", e.g., for merits in culture, science or
sports, or even the economy (EC 2019, 3).
JOURNAL OF COMPARATIVE POLITICS 69
also strongly influenced by the phenomenon of dual citizenship. The legal
possibility of dual citizenship can play the role of CBI accelerator, or, by contrast,
shift applicants' attention to RBI.4
In the EU, this implied a shift from the free
movement of workers to the universal free movement of people (ibid., 245).
In 1997 the Treaty of Amsterdam anchored the so-called fundamental values of
the EU in Article 6 of the Treaty on EU, which refers to "liberty, democracy,
respect for human rights and fundamental freedoms, and the rule of law,
principles which are common to the Member States". The risks associated with
RBI and CBI, detailed below, primarily affect the value of the rule of law and the
principle of non-discrimination. As part of the communitization process, the
treaty transferred the intergovernmental agenda of the Schengen system under
Title IV of the Treaty on EC with a transitional period of five years. Article 34 of
the Treaty on EU introduced the principle of consultation and cooperation,
including "collaboration between the relevant departments of their
administrations" in building an area of freedom, security, and justice.
Following the European Council summit in Tampere in 1999, the status of legally
resident third-country nationals in the EU was strengthened, making the product
more attractive (Brink 2017, 12-13; EC Tampere 1999). Council Directive
2003/109/EC, concerning the status of third-country nationals who are longterm
residents, furthered the development of residents' rights (Council 2003).
Directive 2004/38/EC of the European Parliament and of the Council on the right
of citizens of the Union and their family members to move and reside freely
within the member states included family reunification (EP and Council 2004).
With this shift, the making of visa policy lost its original independence at the
member state level after 2004 and introduced mutual interdependence between
states and EU institutions in this area.
The golden passport was first introduced in the EU by Bulgaria in 2005, Cyprus
in 2007, and finally Malta in 2014. The programmes were based on investment
by third-country nationals as a new form of fast track to naturalization from EUR
1 million in Bulgaria and EUR 2 million together with property ownership in
Cyprus. In Malta, a sum of EUR 650,000 must be paid into a national investment
fund together with an additive investment of EUR 150,000 and property
investment in Malta (EC 2019, 3). In 2018 a discussion about CBI in Bulgaria was
launched. In March 2022, the parliament approved amendments to the
Citizenship Act that abolished "golden passports" - citizenship in return for
investment. The State Agency for National Security is responsible for checking
and eventually revoking any recently granted citizenships (Sofia Globe 2022).
After the Lisbon Treaty entered into force in 2009, we can observe
incompatibility of such national laws with the principle of sincere cooperation
among member states under Article 4(3) of the Treaty on EU, referring to the
necessity of compliance with citizenship Article 20 of the Treaty on Functioning
of EU (EC 2021, 23). The infringement raises the question of security risks and
threatens the cohesion of the single market (Fernandes et al. 2021, 20). These
4
Originally rejected, dual citizenship was definitively confirmed by the signing of the European
Convention on Nationality in 1997 (Moritz 2015, 237-240). Even when dual citizenship is
formally possible, people pursue various strategies to obtain it. For example, Macedonians have
been known to seek Bulgarian passports while emphasizing their independence from Bulgaria
(Paskalev 2014). By contrast, in China, where dual citizenship is banned, applications for
investment visas are popular (Brink 2017, 9).
JOURNAL OF COMPARATIVE POLITICS 70
arguments were part of an infringement procedure against Malta and,
subsequently, Cyprus over golden passports (EC 2022a).
Golden passports and golden visas are often discussed together, because of the
common risks stemming from the free movement of holders. As the European
Economic and Social Committee noted, "although the consequences of being
granted a passport or a visa differ significantly in terms of the rights they grant,
both types of scheme bear the same level of security risk" (EESC 2020).
We can distinguish fundamental differences between the two. When a member
State decides to grant citizenship by investment, it automatically bestows certain
rights upon the individual that also extend to other EU states. This is due to the
fact that anyone who becomes a national of a Member State is also a citizen of the
Union, entitling them to new privileges such as free movement and access to the
internal market, political rights (such as the right to vote in local and European
elections), and protection (such as consular and ombudsman support). For thirdcountry
nationals, the most desirable aspect of such programmes is the ability to
travel freely within the Schengen area.
As for golden visas, member states grant them to third-country nationals through
country-specific processes and, in an expedited procedure, "only" allow the
holder to travel freely in the Schengen Area for 90 days in any 180-day period.
RBIs may, but do not necessarily, result in obtaining citizenship; they are not
permanent in character. The difference between the two regimes may also
depend on what is on offer: some investment opportunities may be open only to
citizens and inaccessible to golden visa holders (Surak 2021a, 169).
EU countries started to offer residency by investment after the global economic
crisis, i.e., in 2007-2009 (Transparency International and Global Witness 2018,
8).5
In 2010, four EU countries offered RBI and the number was growing (Surak
2020, 151). Investors' motivations are directly linked to the stability of law and
financial legislation in the EU, not to mention access to the single market (Brink
2017, 10). The choice of a particular country is not always determined by the
conditions of its programme - other incentives may play a role. According to
Surak's study (2021a), obtaining mobility is a crucial consideration for applicants,
so they tend to choose countries that are members of Schengen.6
Investment can take the form of real-estate purchase, philanthropic giving, or
contributions to science and research or the arts. It can also be directed to the
country's budget by requiring the applicant to buy government bonds, or deposit
money in a bank account in the target country. Other examples include making a
financial contribution to a company in which the activity and physical presence
of the investor in the country is expected. Often, these deals are conditional on
spurring innovation or the use of technologies in a certain region or maintaining
employment (Surak 2020, 151-152). The rules do not necessarily require
5
The first option to obtain a residence permit in exchange for a monetary transaction was offered
in 1984 by Saint Kitts and Nevis. This was followed by schemes in Canada (1986) and the USA
(1990).
6
In a study of how people obtain CBI in 11 countries (including Cyprus and Malta), Kristin Surak
observed mobility as the fundamental motivation for the richest group of respondents. For
medium-rich applicants, it was a commercial opportunity, and geopolitical factors were
important for both groups (2021a). In general, however, Surak notes that investors tend to act as
"tourists and profit-oriented businesspeople, rather than as settlement-oriented immigrants"
(2021b).
JOURNAL OF COMPARATIVE POLITICS 71
applicants to spend time in the country where the investment is made (Scherrer
and Thirion2018,11-12).
2.1 The risks and impacts of granting golden visas
RBIs have been analysed from multiple viewpoints, not just from the perspective
of economic benefit for countries. Those who hold RBIs have the opportunity
obtain visa-free access to a greater number of countries, which can stimulate
global mobility. Investors can also access better healthcare, education, and social
services. Investing in RBI countries allows individuals to diversify their assets
and protect themselves against political or economic instability in their home
country. For states, the primary benefit is significant financial investment that
can stimulate economic growth, create jobs, and improve infrastructure. States
seek new revenue to help the country to get out of recession, for instance. We
know that investment programmes bring nearly €3.5 billion into the Union
annually (Surak and Tsuzuki 2021, 3384-3385). Only in Latvia and Portugal are
the financial investments big enough to make a significant contribution to foreign
direct investment (ca. 10 %) (Ibid., 3384-3385). However, in no EU country does
investment income represent a substantial part of GDP (at most around 0.3 %).
RBIs are not powerful enough to stabilize a state's macro-economy or provide
significant help in an economic downturn (Surak 2021b).
Investors mostly prefer the property sector (Surak and Tsuzuki 2021, 3385), but
this does not necessarily have the expected positive effect, as in their effort to
comply with the required level of investment investors may pay above market
value (Scherrer and Thirion 2018, 42). The increased demand for real estate may
have negative impacts on the property market and cause a housing crisis (Council
of Europe 2020, l ) . 7
Likewise, investment in companies may not be beneficial if
the enterprises chosen do not prosper, or if the requirements concerning job
creation are dysfunctional (Surak and Tsuzuki 2021, 3380).
The practice of investment migration is gaining attention due to the potential
risks it may pose. In this view, the concerns of many international institutions
converge. The EP has called it "state-facilitated and mediated corruption and
money laundering" (EP 2018) and the Council of Europe mentioned it as a source
of funding for terrorism (Council of Europe 2020,1). Transparency International
warns of RBI being used by oligarchs (TI 2022) who in their home countries face
prosecution or seek to launder illegal profits and protect themselves from funds
being frozen or seized (Pavlidis 2021, 172). Proving the origin of the money
invested (Council of Europe 2020, 2-3) is hampered by a lack of comprehensive
risk assessment, limited control mechanisms, lack of financial resources to
conduct efficient in-depth checks and in some cases also deliberate laxness by
visa officials (Pavlidis 2021, 172; Fernandes et al. 2021, 30). The fifth EU AntiMoney
Laundering Directive of 2018 was expected to help with the vetting of the
origin of investors' money and described applicants as high risk, calling for
enhanced due diligence. A fundamental shortcoming was found to be that due
diligence checks are carried out only on economic entities and not governmental
organizations, offices, or agencies. The immigration authorities are, therefore,
7
An example of the impact of foreign investment is downtown Lisbon, where affordable real estate
has been pushed out of reach of Portuguese households and part of the city centre is owned by
foreigners (Fernandes et al. 2021, 38). Similarly, negative impacts are discussed in Greece, where
the programme accounts for a third of property transactions and has destabilized the market
(Surak and Tsuzuki 2021, 3369, 3385).
JOURNAL OF COMPARATIVE POLITICS 72
not bound by the directive and not obliged to carry out in-depth checks of
applicants (EC 2019,15)8
Lack of transparency in RBIs could provide an opportunity for corrupt practices
to spread in the offices of the national authorities, for example, that vet applicants
(Pavlidis 2021, 173). The problem concerns not just state institutions and
officials, but also policymakers. Politicians involved in the legislative process are
criticized for being influenced by private interests that lobby in favour of RBI. The
Council of Europe noted risks to the rule of law and democratic stability from this
practice (Council of Europe 2020, 2). This is accompanied by conflicts of interest,
as politicians, their staffers or family members may conduct business
transactions or have other private dealings with applicants (Pavlidis 2021,173).
As mentioned above, RBI may serve as a flexible strategy for investors who seek
to diversify their wealth and gain a foothold outside their home country (Surak
2021a). Tax evasion is, therefore, another possible RBI risk. States seeking to
attract as much financial capital as possible often offer a broad range of tax
advantages. A specific investment may disrupt the exchange of information
between the tax authorities of the home and target countries, and this could lead
to tax evasion (EC 2019,17; Pavlidis 2021,173; Scherrer and Thirion 2018, 41).«
The security risk posed by RBI could result from the free movement of people
across the Schengen Area, which includes most EU countries, except for Cyprus
and Ireland in 2024. Applicants are often subjected to insufficient background
checks and immigration officials are pressured to be lenient or not thorough in
vetting applicants. Although the granting of RBI does not give applicants the
permanent free movement and political rights citizenship does, applicants, who
may have criminal intentions, could misuse it to gain a safe haven to conduct
potential criminal activities in the receiving country (Scherrer and Thirion 2018,
44) and may threaten the security of another country (EP 2018).1 0
The social risks with potential political impact tend to be discussed more often
as consequences of awarding golden passports, but many overlap with RBI.
There is, for example, the issue of discrimination against external actors, or
privileged access for the rich. While the overwhelming majority of third-country
nationals who want to reside in an EU member state face limitations on the
labour market and, since 2010, stricter requirements, a minority of rich
foreigners in exchange for investment are offered the right of residence in the EU,
and often their family members as well (Scherrer and Thirion 2018, 20-21;
Fernandes et al. 2021, 26). Internal discrimination includes the alreadymentioned
tax advantages and tax breaks that apply only to residence permit
holders and not to the country's own citizens. These advantages include tax-free
foreign property ownership and income, a lump-sum tax on foreign income and
8
Concerning money laundering, in 2021 the EC proposed that national authorities should have
access to information in centralized registers. In 2023, the Council accepted a mandate to
negotiate an EU legal regulation on finances originating from criminal activities.
9
Fundamental for fighting tax evasion is the 1988 Convention on Mutual Administrative Assistance
in Tax Matters which was developed by the Council of Europe and OECD. It has been signed by
147 states including Russia and China, whose citizens account for over 75 % of golden visa
holders (Surak 2020,162-163; OECD 2023).
1 0
The EC notes incompatibility with the principle of sincere cooperation among member states
under Article 4(3) of the Treaty on EU and refers to the necessity of compliance with citizenship
under Article 20 of the TFEU (EC 2021, 23). The infringement of the principle is a question of
security risks and threatens the cohesion of the single market (Fernandes et al. 2021, 20) These
arguments form part of the infringement procedure against Malta and subsequently Cyprus over
golden passports (EC 2022a).
JOURNAL OF COMPARATIVE POLITICS 73
lower tax rates on pensions remitted to the country of origin (EP 2019). Both RBI
and CBI processes emphasize economic over human capital and are "seen as
corrupting democracy by breaking down the barrier that separates the spheres
of money and power" (Scherrer and Thirion 2018, 46). The process is
insufficiently transparent and this may lead to weakening public and political
trust in the state. This often occurs when scandals are uncovered in the awarding
of RBI and CBI (ibid., 45).
2.2 European institutions wake up
European institutions have responded in a phased approach. Initially, they began
a discussion by rejecting golden passports and later shifted their focus to golden
visas. In the third phase, they took definitive action against golden passport
schemes, including legal proceedings. The fourth phase, which is ongoing, aims
to affect persistent golden visa programmes and extract benefits to the EU budget.
The EP has been at the forefront of this process, having initiated the response to
Malta's CBI in 2014. The EP expressed concern that national regimes allowed the
"direct or indirect sale of Union citizenship for cash", undermining the idea of
European citizenship (EP 2014), and asked the EC to assess this problem from
the viewpoint of European values and EU legislation. In a plenary discussion, the
EC agreed to do this and through European Commissioner for Justice,
Fundamental Rights and Citizenship Viviane Reding asked "whether EU
citizenship rights should merely depend on the size of someone's wallet or bank
account" (Reding 2014). The EP and subsequently the EC then concentrated on
citizenship. In 2018, the EP broadened its scope to encompass RBI (EP 2018). In
a January 2019 report (EC 2019), the Commission listed not just the three
countries mentioned but 20 countries that offered various forms of RBI. The
European Economic and Social Committee, following a consultation, responded
to this document and fully supported the EP appeals (EESC 2020).
In 2020, the EP increased its pressure "to phase out all existing citizenship by
investment (CBI) or residency by investment (RBI) schemes as soon as possible"
(EP 2020). In the same year, the President of the European Commission included
the issue in her state of the Union address, in which she said: "be it about the
primacy of European law, the freedom of the press, the independence of the
judiciary or the sale of golden passports, European values are not for sale" (von
der Leyen 2020).n
In 2022, the EP not only used its indirect right to initiate legislation according to
Article 225 TFEU, but also directly quoted the commitment of EC President von
der Leyen in the Political Guidelines of the Commission for 2019-2024, in which
she promised to respond to EP proposals with a legislative act (von der Leyen
2019, 20). In a March 2022 resolution, the EP asked the Commission, before its
mandate ran out, to propose a regulation on RBI regime conditions in the EU to
1 1
In 2020, infringement procedures were launched against Cyprus and Malta concerning their
CBIs. Cyprus then announced that it would end its programme. This was accelerated by the
release of the Cyprus Papers. In August 2020, it was revealed that up to 1,400 people and their
family members bought Cypriot citizenship including, allegedly, at least 30 people who had been
prosecuted or sentenced, as well as 40 politically exposed people (TI 2020; EC 2020). In March
2022, Bulgaria announced that it was ceasing to issue golden passports and launched an
investigation (TI 2023; Euronews 2022). Thus the only CBI regime to remain was in Malta. In
March 2023, the EC brought action against this CBI (Case C-181/23).
JOURNAL OF COMPARATIVE POLITICS 74
limit risks and increase transparency.12
According to the EP, this should involve
a review of legislation on fighting money laundering and funding of terrorism and
the long-term residence directive. The impact on visa-free travel should also be
assessed. Considering that the risks of the golden schemes are shared by all
member states but the gains are individual, the EP responded by proposing the
establishment of a new category of the Union's own resources according to
Article 311 of the Treaty on Functioning of EU "that would place a levy of a
meaningful percentage on the investments made in member states as part of
CBI/RBI schemes" (EP 2022a). This would demonstrate "solidarity between the
member states" (Ibid.).
The attention of the European authorities intensified, with the Commission
urging member states to introduce strict background checks before residence
permits based on investment (EC 2022b) were issued. Although this was
primarily motivated by the desire to prevent Russians and Belarusians from
entering the EU, it was significant progress concerning RBI generally.
2.3 Impact of the EU pressure
The EP 2018 study was particularly critical of RBI regimes with passive
investment and evaluated the golden visas in Bulgaria, Cyprus, Estonia, Ireland,
Italy, Latvia, Malta and Portugal as particularly accessible. This was in
consideration of other motivations offered to investors. The creation of a
"naming and shaming" list, together with the pressure exerted by European
institutions, had the potential to make these visas less accessible over five years.
Ireland abolished its RBI programme in 2023. Did the process cause the
remaining seven countries to change their arrangements, to reform their
demands, leave them as they were, or even make golden visas more accessible?
Only Bulgaria and Estonia responded at least partially in line with the
expectations of European institutions. A simplified overview of the changes in
prices is given in Table 1.
The seven countries may be divided into three groups according to the
development of their visa price level: (1) The price for RBI decreased. These
countries reduced the cost of investment after 2018: Italy and Cyprus. For
investment in start-ups, Italy halved the requirement to €250,000. Cyprus
removed the accompanying payments in its real estate model, thus decreasing
the price to €300,000; (2) Little or no change: Latvia, Malta and Portugal. Latvia
simplified its RBI list but left the low-cost category unchanged. Malta did
something similar with its real estate visa. Portugal removed the real estate
investment-based visa from its offer, but left the cheapest special visa (for
€250,000) unchanged; (3) More expensive RBI: these countries responded in
accordance with the expectations of "naming and shaming", restricting their most
accessible offers and thereby increasing RBI price levels. This includes Bulgaria,
which abolished its real estate programme and thereby increased the minimum
level of investment to €500,000, and Estonia, which reduced its offer and kept
the model with a higher investment of €1 million.
1 2
The EP believes that the legislative rationale for an EC initiative including regulation could be
found in, for example, Article 79(2) and Articles 80, 82, 87 and 114 of the Treaty on the
Functioning of the EU (EP 2022a).
JOURNAL OF COMPARATIVE POLITICS 75
TABLE 1: CHANGES TO THE LOWEST OFFER IN THE MOST ACCESSIBLE RBI
PROGRAMMES - ORDERED ACCORDING TO MINIMUM INVESTMENT LEVEL
Country RBI offer in 2018 RBI offer in 2023 Change assessment
RBI from
f€)
Latvia
€250,000 investment in property (+ 5 % of the value of
immovable property into the national budget);
OR an investment of €50,000 or €100,000 (depending on
the number of employees in the company) invested in
equity capital of a Latvian company; + €10,000 to the
national budget;
OR €280,000 of subordinated liabilities with a Latvian
credit institution + €25,000 into the national budget;
OR €250,000 investment in interest-free state securities
dedicated to a specific purpose + €38,000 into the
national budget.
Only investment in
companies according
to size, levels
remained the same.
Little change.
Offer simplified by
decreasing options,
removing passive
models. The lowest
threshold has no
accompanying
conditions and
remained at a low level
of investment
60,000
Malta
Investment of €220,000 in property in the south of Malta
OR €250,000 in Gozo OR €275,000 elsewhere in Malta OR
rent property at minimum €9,600/year (€8,750 in the
south of Malta and Gozo).
Contribution of €1.15 million (consisting of €0.65 million
in net contribution + €0.35 million in property purchases;
and €0.15 million in investment in state bonds or
protects).
Models reduced,
second investment
programme removed.
Level for real estate
programme remained
same.
Little change.
The offer was simplified,
but the minimal
threshold is the same.
220,000
Portugal
Requires one of the following: a capital transfer of
minimum €1 million; OR the creation of at least 10 jobs;
OR property purchased for at least €500,000.
Other options include investments between €250,000
and €350,000 in capitalization of small/medium
enterprises, buying real estate in an urban regeneration
area, research activities, or artistic production or natural
heritage.
Removal of real estate
visa, change of levels
for special visa,
required investment
in companies
increased, new
demands on job
creation.
Little change.
Special visa remains at
the same low price level.
250,000
Italy
€2,000,000 investment in government bonds; OR
€1,000,000 investment in limited companies or
philanthropic donations; OR €500,000 investment in
innovative start-ups.
Models preserved,
threshold for start-ups
reduced to €250,000.
Price decrease.
Level of the smallest
investment lowered.
250,000
Cyprus €300,000 in property + deposit of €30,000 in a Cypriot
bank + income of at least €30,000 a year.
Real estate model
simplified by reducing
other payments; offer
expanded with
investment into
company.
Price decrease.
Real estate model
reduced, new option of
investing in a company.
300,000
Bulgaria
Investment of minimum BGN600,000 (approx. €300,000)
in real estate or company shares;
OR investment of BGN250,000 (approx. €127,000) in
poorer regions with the creation of at least 5 new jobs for
Bulgarian citizens.
Investment of BGN1,000,000 (approx. €510,000) in
shares in Bulgarian companies traded on a Bulgarian
regulated market;
OR investments in treasury bonds;
OR holding or shares in public companies;
OR investment in Bulgarian intellectual property/patent
protected inventions;
OR investment in a licensed credit institution in Bulgaria
under a trust management agreement
Other options include investment of BGN600,000
(approx. €300,000) in a Bulgarian company whose shares
are not traded on a regulated market.
Multiple options
preserved, real estate
model removed. All
options are more
expensive.
Price increase.
Low-cost RBI variants
abolished, thus
increasing minimum
level of investment
500,000
Estonia
Requires an investment of €65,000 in business activity in
Estonia. Applicants are required to be the sole proprietor
of the enterprise and must have a business plan.
Requires a direct investment of at least €1,000,000 in a
company on the Estonian Business Register.
Sole model with €1
million and no other
obligations preserved.
Price increase.
Decrease in the number
of programmes and
historically the most
expensive model
preserved.
1 million
Source: authors after Scherrer and Thirion (2018) and current data as of November 2023.
3 WHAT IS ON OFFER IN THE UNION IN 2023?
States adopt various RBI strategies. Richer countries set a higher minimum
amount to be invested to achieve a greater effect on their GDP (Dzankic 2018,77).
However, a higher price for a visa may attract less interest from applicants (Surak
and Tsuzuki 2021, 3370). Some countries never accepted the idea of RBI; others
which had a scheme have abolished it. Ireland announced the end of its
programme in February 2023, and the Netherlands by 2024 (Ireland 2023; IND
2023). States that do not offer RBI include Austria, Belgium, Croatia, Denmark,
Finland, France, Germany, Hungary, Poland, Slovenia and Sweden. There is a
decreasing availability of RBI schemes, but they continue to be offered by
Bulgaria, Czechia, Cyprus, Estonia, Greece, Italy, Latvia, Lithuania, Luxembourg,
Malta, Portugal, Romania, Slovakia and Spain. Currently there is discussion about
JOURNAL OF COMPARATIVE POLITICS 76
modifying or even abolishing RBI in Spain, and in February 2023 the Mas Pais
party introduced a bill to abolish the Spanish RBI programme or make it more
expensive (Euronews 2023; Rodriguez 2023).
3.1 Types of golden visa schemes
In line with the approach taken by Surak and Tsuzuki, we categorize golden visas
according to the measure of activity associated with the investment made by the
applicant (Surak and Tsuzuki 2021, 3368). The passive category includes
investment in real estate, funds deposited in a bank account, and purchase of
government bonds and investment funds. By contrast, we count investment in
companies, where there may be additional conditions, as active. Special kinds of
investment constitute a specific category. The distribution of the types across
countries is shown in Table 2. Investors have the privilege of choosing the offer
that best aligns with their preferences. There are three countries that provide all
three types of RBI programmes, making them an attractive option for clients
interested in real estate, business investments, or philanthropy. Meanwhile, five
states offer two categories, and the others typically only offer the active
investment choice. After making an investment decision, there may be more
specific options available depending on the location or nature of the business
plan.
TABLE 2: TYPES OF RBI OFFERED BY COUNTRY (ORDERED ACCORDING TO
OCCURRENCE AND ALPHABETICALLY)
Country Passive investment Active investment Special investment
Bulgaria X X X
Italy X X X
Portugal X X X
Cyprus X X
Estonia X X
Greece X X
Luxembourg X X
Spain X X
Malta X
Czechia X
Latvia X
Lithuania X
Romania X
Slovakia X
Source: authors, as of November 2023.
3.1.1 Passive investment visas
We categorize the various options for passive investments into four distinct
categories. The best-known type of passive investment is the purchase of
property, an option offered by Cyprus, Greece, Malta and Spain. The levels of
investment required can be seen in Figure 1. In Greece and Malta we observe
efforts to support the development of lagging regions by lowering the level of
investment required in those places. A specific option in these two countries is
rental, which must meet a time test and a minimum value of investment.13
1 3
Depending on the location, Malta requires a rental agreement for one year (or more) and annual
rent of at least €8,750 (€9,600 in the main part of the island) (Malta 2020, 5). If the tenancy is
not locked in for a longer period, it constitutes the cheapest option of all, and, importantly, would
be of no significant financial importance for Malta. Because the tenancy length could not be
verified in official sources, rental will not be part of the final assessment. In Greece, rental must
take the form of a lease of accommodation for tourists, for at least 10 years duration and at a
value of at least €250,000 (€500,000 in more attractive localities). A license granted by the
National Tourism Organization is also required (Greece 2023).
JOURNAL OF COMPARATIVE POLITICS 77
FIGURE 1: INVESTMENT IN REAL ESTATE (€]
Malta B
Greece B
Malta A
Cyprus
Spain
Greece A
220.000
• 250.000
275.000
300.000
500.000
500.000
0 100.000 200.000 300.000 400.000 500.000 600.000
Source: authors, as of November 2023.
Category A in Malta corresponds to a standard investment of €275,000. To
incentivize investment in less prosperous regions in the south of Malta and on
Gozo island, the minimum real estate investment is lowered to €220,000 (Malta
B) (Malta 2020,4-5). Greece has adopted a similar system, doubling the minimum
required (to €500,000) for investments since August 2023 in Central and South
Athens regional units in Attica, on the islands Mykonos and Santorini and in
Thessaloniki (Greece A) (Rodriguez 2022). In other areas, the original threshold
of €250,000 continues to apply (Greece B) (Greece 2023). Cyprus and Spain do
not make territorial or other distinctions (Cyprus 2021; Spain 2023). Another
way to invest passively is to deposit funds in a bank in the country. The levels of
such investment required by Greece, Spain and Luxembourg are shown in Figure
2 (Spain 2023; Enterprise Greece 2023). In Greece and Luxembourg, there is the
additional condition of the deposit remaining in the account for a stipulated
period of time (Luxembourg 2023).
FIGURE 2: INVESTING BY DEPOSITING FUNDS IN A BANK ACCOUNT (€]
Greece 1 400.000
Spain 1 1.000.000
Luxembourg 20.000.000
1 5.000.000 10.000.000 15.000.000 20.000.000 25.000.000
Source: authors, as of November 2023.
Spain, Italy, Bulgaria and Greece offer the option of purchasing government
bonds. The required investment into the national budget is shown in Figure 3
(Italy 2023; Spain 2023; Bulgaria 2023, 6; Enterprise Greece 2023).
JOURNAL OF COMPARATIVE POLITICS
FIGURE 3: INVESTING IN GOVERNMENT BONDS (€]
78
Greece A
Bulgaria
Greece B
400.000
500.000
800.000
Italy 2.000.000
Spain 2.000.000
0 500.000 1.000.000 1.500.000 2.000.000 2.500.000
Source: authors, as of November 2023.
The final passive investment option, displayed in Figure 4, involves investing in
investment funds run by companies headquartered or operating in the target
country (Cyprus 2021; Spain 2023; Estonia 2023; Luxembourg 2023; SEF 2023;
Enterprise Greece 2023). The condition of a residual duration of three years
applies to Greece A, but there is no time limit for B.
FIGURE 4: INVESTING IN INVESTMENT FUNDS (€)
Cyprus 300.000
Greece 400.000
Portugal 500.000
Spain ^ ^ ^ ^ ^ B 1.000.000
Estonia
Luxembourg
1.000.000
3.000.000
500.000 1.000.000 1.500.000 2.000.000 2.500.000 3.000.000 3.500.000
Source: authors, as of November 2023.
3.1.2 Active investment visas
Investment in companies, in particular in shares or debentures, is a RBI model
offered by some EU countries. Beyond the investment itself, there may be
conditions such as a requirement to support innovation, job creation or a
company development plan. It's worth considering whether an investor's role is
truly active if their sole contribution is financial support. Without accompanying
conditions, they may simply participate as a financial partner and not be involved
in company growth. However, it's reasonable to assume that there is a closer
relationship between the investor and the company than in passive investment
in real estate. An overview of all types, including the main criteria and specific
requirements as well as the company's investment sans conditions, is provided
in Table 3. If job creation is required - the most common condition - the number
JOURNAL OF COMPARATIVE POLITICS 79
of new jobs is indicated. Latvia, Italy, Greece, Bulgaria, Estonia and Spain only
stipulate the minimum level of investment and impose no other conditions.
TABLE 3: OVERVIEW OF CONDITIONS FOR INVESTING IN COMPANIES BY MINIMUM
INVESTMENT SIZE
Country
Minimum level
of investment
(€)
Accompanying
conditions?
Job creation Focus and special requirements
Latvia A 50,000 NO - Small company + €10,000 into national
budget
Romania A 70,000 YES 10 Limited company + business plan
Romania B 100,000 YES 15 Joint-stock company + business plan
Latvia B 100,000 NO - + €10,000 into national budget
Italy A 250,000 NO - Start up
Cyprus 300,000 YES 5 Physical presence required
Greece A 400,000 YES - Shares have to increase capital stock and
bonds refer to a new bond loan
5 (within three
years] and
selection of
Luxembourg 500,000 YES employees in
cooperation with
the National
Employment
Agency
Investment duration five years or start-up
Italy B 500,000 NO - Established company
Bulgaria 500,000 NO - Joint-stock companies, or enterprises with at
least 50 % state or municipal ownership
Portugal* 500,000 YES 5
Jobs required if a start-up; if a company,
creating or maintaining jobs for at least three
years
Greece B 800,000 NO Spain**
1,000,000 NO Estonia
1,000,000 NO Investment
in a company listed in the
Estonian business register, which invests
mainly in the Estonian economy. The
investor does not have to be domiciled in
Estonia.
Lithuania A 1,448,000 YES Unspecified
Requirements concerning employee salaries
and company turnover
Czechia 3,000,000 YES 20
Business plan; if partner, must own at least
30 % share
Lithuania B 20,000,000 YES 150 Specific industries
Slovakia A 30,000,000 YES 50
Strategic territory, public interest,
environment
Lithuania
(Vilnius)
30,000,000 YES 200 Specific industries
Slovakia B 100,000,000 YES - Strategic territory, public interest,
environment
* Portugal also offers an option when at least 10 jobs are created (if investing in low-density
populated areas or low-GDP areas the requirement can be lowered by 20 %). In this case there is
no minimum investment stipulated and individual contracts signed by employees prove that the
requirement has been met.
** Spain does not stipulate a minimum amount if the business project creates jobs, has positive
socio-economic impacts or benefits technology and innovation.
Source: authors, as of November 2023.
Leaving aside the Spanish and Portuguese models (described in the notes to
Table 3 above) that do not require a particular size of investment, the lowest level
is required by Latvia at €50,000. This investment (Latvia A) must be linked to a
small company with up to 50 employees and an annual turnover under €10
million. An additional payment of €10,000 directly into the Latvian national
budget is also required. The second model (Latvia B) is for larger companies, and
the number of employees and turnover of subsidiaries is included in the total
(Latvia 2022). The legal form of the company may also influence the size of the
required investment. In Romania, there is a distinction between investing in
limited companies (Romania A) and joint-stock companies (Romania B)
(Romania 2023). In many countries, RBI is intended to support innovation. In
Italy, the required investment in a start-up included on an official list (Italy A) is
JOURNAL OF COMPARATIVE POLITICS 80
lower than that for an established company (Italy B) (Italy 2023). In Lithuania,
all programmes are based on the principle of a contract between the investor and
the government or an agency authorized by the government. In the low-priced
model (Lithuania A), the applicant pledges to create new jobs, the number of
which is not stipulated, but the salaries need to be at least 1.5 times the average
monthly salary in the region where the investment is made. Another condition is
a turnover of at least €2.5 million annually over the previous three years for
enterprises of which the investor is the controlling entity (Migris Litva 2023a).
The second and third Lithuanian programmes (Lithuania B and Lithuania
(Vilnius)) are large investment schemes with impacts on employment; they apply
a geographical criterion. "Large projects" are understood to mean direct
investment in data processing, web servers (hosting) and related activities, or
manufacturing (Migris Litva 2023b).
In Slovakia, third-country nationals may obtain a residence permit if they
represent or work for a significant foreign investor, i.e., a legal entity based in
Slovakia certified by the Ministry of the Economy. A significant investment
according to the law (Slovakia 2021) is an investment in a project in a strategic
territory (not specified further) with at least €30 million expended on the
implementation of the project, 50 newjobs created in connection with the project,
compliance with certain environmental regulations and confirmation from the
government that the project is in the public interest (Slovakia A). In the second
model (Slovakia B), the jobs requirement is replaced by a larger required
investment. In both cases, the minimum investment can be halved if the
investment is in so-called less-developed districts (Slovakia 2023).
3.1.3 Special investment visas
The size of the investment required for a special investment visa in the countries
that offer such an option is indicated in Figure 5.
FIGURE 5: SPECIAL INVESTMENT (€]
Portugal B 250.000
| 1.000.000
0 500.000 1.000.000 1.500.000
Source: authors, as of November 2023.
This includes intellectual property investment in Bulgaria, such as articles
protected by copyright, patented inventions, industrial designs or trademarks.
The other option is acquisition of rights under concession contracts in Bulgaria.
Both types of investment must be of around €500,000 (specified in the national
currency; Bulgaria 2023, 6). A specific RBI option in Italy is investing in
philanthropy. A contribution of €1 million must be directed to support a public
JOURNAL OF COMPARATIVE POLITICS 81
interest project in culture, education, migration management, scientific research
or the protection of cultural or natural heritage (Italy 2023). Portugal also offers
RBI in exchange for supporting research activities (Portugal A) and cultural
heritage or philanthropy (Portugal B) (SEF 2023).
4 CONCLUSION: THE MOST FINANCIALLY ATTRACTIVE GOLDEN
GATE
This article analyses the RBIs on offer as of 2023 and categorizes them across the
EU. We note that, in 2023,14 countries offered an RBI regime, and the conditions
for obtaining visas were set at the lowest threshold (up to €500,000) in Latvia,
Malta, Cyprus, Greece, and Portugal. An overview of the most accessible visas for
each category of investment is provided in Table 4. Investors have the freedom
to choose not only their preferred country, but also the investment programme
that suits their economic potential and programme focus. This means they can
choose to purchase real estate or to make a bank deposit without any additional
conditions or to invest in a specific company or area, for example. Particularly
critical in terms of the security risks cited earlier is the intersection of the high
financial accessibility of golden visas and investor passivity or lack of
accompanying conditions. From this point of view, the passive and special
programmes are most risky. They require nothing but money to be realized.
Specifically, they start at an amount between €200,000 and €300,000. The most
accessible passive investment RBI in real estate is offered by Malta, followed by
investment funds in Cyprus etc. Of the special type of investment, the most
affordable option is offered by Portugal. We can expect that member states will
judge the benefit of the application on its merits. Of the broad gamut of active
investment models, Latvia offers the most accessible golden visa. The
programme is split according to the size of the company invested in, but there
are no accompanying conditions and it is the cheapest programme in the EU
overall. Romania is in second place, requiring an investment of €70,000 and a
business plan. This additional requirement could result in a greater focus on
activities within the target country and could be assumed to serve as a positive
boost for economic development.
TABLE 4: SUMMARY OF THE MOST ACCESSIBLE VISAS BY INVESTMENT CATEGORY
Investment visa type Specification
Most accessible (by
country)
Size of investment (€)
Passive
Real estate Malta 220,000
Passive
Investment funds Cyprus 300,000
Passive
Government bonds Greece 400,000
Passive
Bank deposit Greece 400,000
Active Company Latvia 50,000 f+ 10,000)
Special
Cultural heritage and
philanthropy
Portugal 250,000
Special
Intellectual property Bulgaria 500,000
Special
Concession contract Bulgaria 500,000
Special
Research Portugal 500,000
Special
Philanthropy Italy 1,000,000
Source: authors, as of November 2023.
We know that mobility appears to be as important a motivation for applicants as
other incentives. How attractive is the offer if it includes guaranteed movement
within the Schengen Area? Of the fourteenth countries offering RBI programmes,
only Cyprus is not a Schengen member and, therefore, may be less attractive to
investors. However, Cyprus is already involved in the Schengen Information
System. The membership of Bulgaria and Romania has been much discussed, and
JOURNAL OF COMPARATIVE POLITICS 82
both the EP and EC supported them joining Schengen (EP 2022b; EC 2022c). The
Council, in a unanimous decision, confirmed both countries as new Schengen
area members for persons crossing internal air and sea borders. Controls at the
internal land borders of both countries are expected to be lifted soon (EC 2023).
The expansion of the Schengen area has made the free movement factor less
limiting than one might expect. The most important factor is the accessibility of
the RBI programme. Therefore, Latvia remains the most financially attractive and
affordable option, and Malta is the easiest in terms of acquiring real estate. These
two countries require the lowest level of investment with no special conditions.
Both countries offer the opportunity to travel freely throughout the EU and this
might make these two countries more attractive to investors.
Although recently the shift in RBI policy has been very noticeable throughout the
EU, half of the member states still offer such programmes. The pressure - created
by the EP analysis and then the EC rhetoric - has met with very limited success
in discouraging RBI. As described, given the potential risks and benefits of RBI, it
is evident that the conditions states attach to awarding visas and the measures of
activity they require of applicants are crucial. Also essential is how thorough the
background checks on applicants are and the origin of the invested funds. Further
research in this area is limited by data inaccessibility, although that may not
necessarily be the case for analysis of EU institutions and the regulations and
pressure they are placing on member states. This is a fundamental influence
which may bring further developments and may manifest in a decrease in the
risks that a state awarding golden visas exposes other member states to particularly
in an era of security threats posed by Russia, and other potential
risks arising from conflicts that stimulate migration.
ACKNOWLEDGMENTS
This article is the outcome of the project Perspectives of European Integration in
the Context of Global Politics VI MUNI/A/1475/2023. We are grateful to Masaryk
University for their support.
REFERENCES
Bauböck, Rainer. 2007. "Stakeholder Citizenship and Transnational Political
Participation: A Normative Evaluation of External Voting." Fordham Law Review 75:
2393-2420.
Brink, van den Martijn. 2017. "Investment Residence and the Concept of Residence in EU
Law: Interactions, Tensions, and Opportunities." Investment Migration Working
Papers. IMC-RP2017/1. Available at
https://investmentmigration.org/academic/research-papers/.
Bulgaria. 2023. Issue of Residence Permits to Third Country Nationals. Ministry of Interior:
Migration Directorate. Available at
https://www.mvr.bg/migration/en/administrative-services/administrative-
servces/issue-of-residence-permits-to-third-country-nationals.
Carerra, Sergio. 2014. "How much does EU citizenship cost? The Maltese citizenship-forsale
affair: A breakthrough for sincere cooperation in citizenship of the union?" CEPS
Paper in Liberty and Security in Europe No. 64. Available at
https://www.ceps.eu/ceps-publications/how-much-does-eu-citizenship-cost-
maltese-citizenship-sale-affair-breakthrough-sincere/.
JOURNAL OF COMPARATIVE POLITICS 83
Case C-181/23. 2023. European Commission v Republic of Malta. 21 March 2023.
Available at https: //eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:62023CN0181.
Council. 2003. Council directive 2003/109/EC. 25 November 2003. Available at
https://eur-lex.europa.eu/legal-content/en/ALL/?uri=celex%3A32003L0109.
Council of Europe. 2020. Investment migration: Resolution 2355. 4 December 2020.
Available at
https://pace.coe.int/pdf/78116dd459faf0dfcdee48182f7902cdc91b9c4623726d93
8aed34521680da74/res.%202355.pdf
Cyprus. 2021. Civil Registry and Migration Department Cyprus. Immigration Permits for
Investors. Civil Registry and Migration Department. Available at
http://www.moi.gov.cy/moi/crmd/crmd.nsf/all/8690459673E7A011C225878200
3A8AB4?opendocument.
Dzankic, Jelena. 2015. "Investment-based citizenship and residence programmes in the
EU." EUI Working Paper RSCAS 2015/08. Available at
https://cadmus.eui.eu/bitstream/handle/1814/34484/RSCAS 2015 08.pdf.
Dzankic, Jelena. 2018. "Immigrant investor programmes in the European Union (EU)."
Journal of Contemporary European Studies 26 (1): 64-80.
EC Tampere. 1999. Presidency conclusions Tampere European Council. 15 and 16 October
1999. Available at https://www.consilium.europa.eu/media/21059/tampere-
european-council-presidency-conclusions.pdf.
EC. 2019. Investor Citizenship and Residence Schemes in the European Union. Report from
the European Commission. 23 January 2019. Available at https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=COM:2019:0012:FIN.
EC. 2020. Investor citizenship schemes: European Commission opens infringements against
Cyprus and Malta for "selling" EU citizenship. Press release. 20 October 2020. Available
at https://ec.europa.eu/commission/presscorner/detail/en/ip 20 1925.
EC. 2021. Monitoring the application of European Union law 2020: Annual Report. 23 July
2021. Available at https: //eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52021DC0432.
EC. 2022a. Golden passport' schemes: Commission proceeds with infringement case against
MALT. 6 April 2022. Available at
https://malta.representation.ec.europa.eu/news/golden-passport-schemescommission-proceeds-infringement-case-against-malta-2022-04-06
en.
EC. 2022b. Commission urges Member States to act on 'golden passports' and 'golden
residence permits' schemes, and to take immediate steps in the context of the Russian
invasion of Ukraine. Press release. 28 March 2022. Available at
https://ec.europa.eu/commission/presscorner/detail/en/ip 22 1731.
EC. 2022c. Making Schengen stronger with thefull participation of Bulgaria, Romania and
Croatia in the area without internal border controls. 16 November 2022. Available at
https://eur-lex.europa.eu/legal -
content/EN/TXT/HTML/?uri=CELEX:52022DC0636.
EC. 2023. Bulgaria and Romania to join Schengen area starting with air and sea borders:
Commission welcomes landmark Council decision. 30 December 2023. Available at
https://ec.europa.eu/commission/presscorner/detail/en/ip 23 6861.
EESC. 2020. Opinion of the European Economic and Social Committee on 'Reportfrom the
Commission to the European Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions: Investor Citizenship and Residence
Schemes in the European Union'. 2 February 2020. Available at https://eur-
lex.europa.eu/legalcontent/EN/TXT/?uri=uriserv%3AOI.C
.2020.047.01.0081.01.ENG&toc=OI%3AC%
3A2020%3A047%3ATOC.
Enterprise Greece. 2023. Residence permits. Enterprise Greece S.A. The official
Investment and Trade Promotion Agency of Greece. Available at
https://www.enterprisegreece.gov.gr/en/greece-today/living-in-greece/residence-
permits.
EP. 2014. EU citizenship for sale. European Parliament resolution of 16 January 2014.
Available at https: //eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52014IP0038(01)&from=MT.
JOURNAL OF COMPARATIVE POLITICS 84
EP. 2018. Verbatim report of proceedings. European parliament. 30 May 2018. Available
at https://www.europarl.europa.eu/doceo/document/CRE-8-2018-05-30-ITM-
019 EN.html.
EP. 2019. Report onfinancial crimes, tax evasion and tax avoidance. European Parliament.
26 March 2019. Available at
https://www.europarl.europa.eu/cmsdata/162244/P8 TA-PROVf2019)0240.pdf.
EP. 2020. A comprehensive Union policy on preventing money laundering and terrorist
financing - the Commission's Action plan and other recent developments. European
Parliament. 10 July 2020. Available at
https://www.europarl.europa.eu/doceo/document/TA-9-2020-0204 EN.html.
EP. 2022a. Citizenship and residence by investment schemes. European parliament. 9
March 2022. Available at https://www.europarl.europa.eu/doceo/document/TA-9-
2022-0065 EN.html.
EP. 2022b. End discrimination and admit Bulgaria and Romania to Schengen, MEPs
demand. European parliament press release. 18 October 2022. Available at
https://www.europarl.europa.eu/news/cs/press-room/20221014IPR43207/end-
discrimination-and-admit-bulgaria-and-romania-to-schengen-meps-
demand#:~:text=In%20a%20resolution%20adopted%20on%20Tuesday%2C%20
MEPs%20say,internal%20borders%20for%20both%20countries%20in%20early%
202023.
EP and Council. 2004. Directive 2004/38/EC of the European parliament and of the Council.
29 April 2004. Available at https: //eur-lex.europa.eu/legal-
content/EN/TXT/HTML/?uri=CELEX:32004L0038.
Estonia. 2023. Politsei-ja Piirivalveameti Important information for the applicant of the
temporary residence permit for business. Available at
https://www2.politsei.ee/en/teenused/residence-permit/tahtajaline-
elamisluba/ettevotluseks/oluline-info-ettevotluseks-elamisloa-
taotlejale.dot#iduettevote.
Euronews. 2022. Bulgaria abolishes 'golden passport' scheme for wealthy foreigners.
Euronews, 24 March 2022. Available at
https://www.euronews.com/2022/03/24/bulgaria-abolishes-golden-passport-
scheme-for-wealthy-foreigners.
Euronews. 2023. What are 'golden visas' and which EU countries hand them out?
Euronews, 3 April 2023. Available at
https://www.euronews.com/travel/2023/04/03/what-is-a-golden-visa-and-why-
are-some-countries-giving-them-up-for-good.
Fernandes, Meenakshi, Cecilia Navarra, David De Groot and Maria Garcia Munoz. 2021.
"Avenues for EU action on citizenship and residence by investment schemes."
European Parliament, Research Services. Available at
https://www.europarl.europa.eu/RegData/etudes/STUD/2021/694217/EPRS STU
(2021)694217 EN.pdf.
Greece. 2023. Golden Visa. Hellenic Republic: Ministry of Migration & Asylum. Available
at https://migration.gov.gr/en/golden-visa/.
IND. 2023. Residence permitfor foreign investors. Immigration and Naturalisation Service,
Netherlands. Available at https://business.gov.nl/coming-to-the-
netherlands/foreign-investors/foreign-investors/.
Ireland. 2023. Department of Justice Ireland. FAQs - Closure of the Immigrant Investor
Programme. Available at https://www.irishimmigration.ie/faqs-closure-of-the-
immigrant-investor-programme-iip/.
Italy. 2023. Investor Visa for Italy. Ministry of Enterprise and Made in Italy. Available at
https://investorvisa.mise.gov.it/index.php/en/.
Kochenov, Dimitry. 2014. "EU Citizenship without Duties." European Law Journal 20 (4):
482-498.
Latvia. 2022. Share capital investor. Office of Citizenship and Migration Affairs Republic
of Latvia. Available at https://www.pmlp.gov.lv/en/share-capital-investor-
0?utm source=https%3A%2F%2Fwww.google.com%2F.
Luxembourg. 2023. Government of the Grand Duchy of Luxembourg. Conditions of
residence for investors from third countries. Available at
https://guichet.public.lu/en/entreprises/creation-developpement/projet-
creation/entree-sejour/investisseur-pays-tiers.html.
JOURNAL OF COMPARATIVE POLITICS 85
Maas, Willem. 2016. "European Governance of Citizenship and Nationality." Journal of
Contemporary European Research 12 (1): 532-551.
Magni-Berton, Raul. 2014. Citizenship for those who invest into the future of the state is
not wrong, the price is the problem. In Should Citizenship be for Sale?, eds. Shachar,
Ayelet and Rainer Baubock, 11-12. EUI Working Paper RSCAS.
Malta. 2020. Office of the Commissioner for revenue. Global Residence Programme
Guidelines: Version 2.0-2020. Available at
https://cfr.gov.mt/en/inlandrevenue/itu/Documents/Guidelines%20GRP.pdf.
Moritz, D. Michael. 2015. "The Value of your ancestors: gaining „back door" access to the
European Union through birth right citizenship." Duke journal od comparative &
international law 26. Available at
https://scholarship.law.duke. edu/cgi/viewcontent.cgi?article=1479&context=djcil.
MIGRIS Litva. 2023a. / am coming under an investment agreement with special conditions
for investment and business (collective relocation). Migris: Electronic Migration
Services. Available at https://wvw.migracija.lt/atvykstu-pagal-investiciju-sutarti-
kurioje-nustatytos-specialios-investavimo-ir-verslo-salygos.
MIGRIS Litva. 2023b. / am coming under a major project investment. Migris: Electronic
Migration Services. Available at https://www.migracija.lt/atvykstu-pagal-stambaus-
projekto-investiciju-sutarti.
0ECD. 2023. Jurisdictions Participating in the Convention On Mutual Administrative
Assistance in Tax Matters. Oecd.org. Available at
https://www.oecd.org/ctp/exchange-of-tax-information/Status of convention.pdf.
Parker, Owen. 2017. "Commercializing Citizenship in Crisis EU: The Case of Immigrant
Investor Programmes." JCMS: Journal of Common Market Studies 55 (2): 332-348.
Paskalev, Vesco. 2014. If you do not like selling passports, give them for free to those who
deserve them. In Should Citizenship be for Sale?, eds. Shachar, Ayelet and Rainer
Baubock, 25-26. EUI Working Paper RSCAS.
Pavlidis, George. 2021. "A case of insufficient safeguards or state-enabled money
laundering? 'Golden Passport' and 'Golden Visa' investment schemes in Europe."
Journal of Investment Compliance 22 (2): 170-179.
Reding, Viviane. 2014. Plenary Session debate of the European Parliament on 'EU
citizenship for sale'. Strasbourg 15 January 2014. Available at
https://ec.europa.eu/commission/presscorner/detail/en/SPEECH 14 18.
Rodriguez, Cecilia. 2022. New Rush For Greek Golden Visas As Minimum Investment
Required Doubles To €500,000. Forbes, 31 December 2022. Available at
https://www.forbes.com/sites/ceciliarodriguez/2022/12/31/new-rush-for-greek-
golden-visas-as-minimum-investment-required-doubles-to-
500000/?sh=15c3cc984abb.
Rodriguez, Cecilia. 2023. Spain's Golden Visa Dilemma: End The Program Or Double The
Minimum Investment To €1 Million? Forbes, 11 May 2023. Available at
https://www.forbes.com/sites/ceciliarodriguez/2023/05/ll/spains-golden-visa-
dilemma-end-the-program-or-double-the-minimum-price-to-1-
million/?sh=386710835a65.
Romania. 2023. Ministry of Internal Affairs: General Inspectorate for Immigration.
Available at https://igi.mai.gov.ro/en/business-activities/.
SEF. 2023. Residence Permitfor InvestmentActivity. ARI - Autorizacao de Residencia para
Atividade de Investimento. Available at https://www.sef.pt/pt/pages/conteudo-
detalhe.aspx?nID=62.
Scherrer, Amandine and Elodie Thirion. 2018. Citizenship by investment (CBI) and
residency by investment (RBI) schemes in the EU - State of play, issues and impacts.
Brussels: European Parliament.
Slovakia. 2021. Law 371/2021, §3 about significant investments. Available at
https://www.slov-lex.sk/pravne-predpisy/SK/ZZ/2021/371/20211101.
Slovakia. 2023. Information for foreigners. Ministry of the Interior. Available at
https://www.minv.sk/7residence-of-an-foreigner.
Sofia Globe. 2022. Bulgaria's Parliament abolishes 'golden passports'. The Sofia Globe, 24
March 2022. Available at https://sofiaglobe.com/2022/03/24/bulgarias-parliament-
abolishes-golden-passports/.
Spain. 2023. Ministry of Foreign Affairs, European Union and Cooperation Spain. Investor
Visa. Ministerio de Asuntos Exteriores, Union Europea y Cooperation. Available at
JOURNAL OF COMPARATIVE POLITICS 86
https://www.exteriores.gob.es/Consulados/sanfrancisco/en/ServiciosConsulares/
Paginas/Consular/Visado-de-inversor.aspx.
Surak, Kristin. 2020. "Who wants to buy a visa? Comparing the uptake of residence by
investment programs in the European Union." Journal of Contemporary European
Studies30 (1): 151-169.
Surak, Kristin. 2021a "Millionaire mobility and the sale of citizenship." Journal of Ethnic
and Migration Studies 47: 166-189.
Surak, Kristin. 2021b. "Are golden visas a golden opportunity for economic
development?" LSE Business Review. Available at
https://blogs.lse.ac.uk/businessreview/2021/05/26/are-golden-visas-a-golden-
opportunity-for-economic-development/
Surak Kristin. 2022. "The Economics of Investment Migration: The Citizenship and
Residency Industry and Economic Outcomes." The Centre on Migration, Policy &
Society, University of Oxford: Working Paper. No. 158. Available at
https://www.compas.ox.ac.uk/wp-content/uploads/WP-2022-158-The-Economics-
of-Investment-Migration-The-Citizenship-and-Residence-Industry.pdf.
Surak, Kristin and Yusuke Tsuzuki. 2021. "Are golden visas a golden opportunity?
Assessing the economic origins and outcomes of residence by investment
programmes in the EU"'. Journal of Ethnic and Migration Studies 47 (15): 3367-3389.
TI. 2020. Cyprus axes corruption plagued golden passports scheme. Transparency
international. 13 October 2020. Available at
https://www.transparency.org/en/press/cyprus-axes-corruption-plagued-golden-
passports-scheme.
TI. 2022. Cyprus papers: Golden visa schemes are broken beyond repair, EU must act.
Transparency international. 24 August 2020. Available at
https://www.transparency.org/en/press/cyprus-papers-golden-visa-schemes-are-
broken-beyond-repair-eu-must-act.
TI 2023. Abuse of Golden Visa. Ending corrupt abuse of EU Golden passports & visa.
Transparency international. Available at
https://www.transparency.org/en/campaigns/ending-corrupt-abuse-european-
union-golden-passports-visas.
Transparency International a Global Witness. 2018. European Getaway: Inside the murky
world of golden visas. Transparency International Berlin. Available at
https://images.transparencycdn.org/images/2018 report GoldenVisas English.pdf.
von der Leyen, Ursula. 2019. Political guidelines of the Commission 2019-2024. 16 July
2019. Available at https://commission.europa.eu/system/files/2020-04/politicalguidelines-next-commission
en O.pdf.
von der Leyen, Ursula. 2020. European values are not for sale. State of the Union. 16
September 2020. Available at
https://ec.europa.eu/commission/presscorner/detail/en/SPEECH 20 1655.
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0
ZLATÍ VÍZUM: KAKO IN ZA KAKŠNO CENO ĽAHKO VSTOPAMO V EU?
Ponudba zlatega vizuma, znanega tudi kot program prebivanja z naložbo (RBI),je
náčin, s katerim državě članice EU privabljajo tuje investicije, vendar na drugi
stráni obstajajo tudi gospodarska, politična in varnostna tveganja, zato so
institucije EU pogosto kritične do tovrstne prakse. Příspěvek primerja stroške vseh
režimov RBI v EU-27 in kategorizira njihove modele. Od leta 2018, ko je Evropski
parlament objavil obsežno študijo o tem vprašanju, so nekatere državě tovrstne
programe omejile ali povsem ukinile. Toda kljub omenjenim pritiskom leta 2023
programe RBI še vedno ponuja kar 14 držav EU. Příspěvek opisuje trenutne pogoje
za pridobitev zlatega vizuma v Uniji in opredeljuje državě z najnižjimi naložbenimi
zahtevami. Z izjemo Cipra so vse druge ponudbe iz držav schengenskega območja,
kar poudarja tveganja, povezana s prostim pretokom vlagateljev.
Ključne besede: zlata viza; državě EU; program prebivanja z naložbo;
investicijske migracije.