Cyprus: Obtaining The Cypriot Citizenship By Investing- Decision Of The Cypriot Council Of Ministers Dated 13.09.2016

Last Updated: 4 May 2017
Article by Chryssafinis & Polyviou LLC

As part of the Cypriot Government's continuous effort to maintain Cyprus' reputation as a global financial centre, the Cyprus' Council of Ministers issued a Decision on 15/04/13 whereby it was resolved that the Cyprus Government may grant the Cypriot Citizenship to foreign business persons and investors on the basis of exemption, provided that foreign applicants satisfy certain financial and other criteria. A successful application for the Cyprus Citizenship means that the applicant can enjoy all free movement benefits that apply to all European Union Citizens.

Within the above-mentioned framework, the Cyprus Government, taking into account the strong interest of investors, has revised through the recent decision of the Council of Ministers dated 13.9.2016, the criteria for the "Scheme for Naturalization of non-Cypriot investors by exception" (the "Scheme") on the basis of the Civil Registry Laws of 2002-2015, article 111A, subsection (2). 

On the basis of the Scheme, a non-Cypriot citizen, who meets one of the following economic criteria outlined in Part A below, either personally or through a company/ companies in which he/ she participates as a shareholder – in proportion to his holding percentage, or through investments done by his/her spouse or jointly with the spouse or even as a high-ranking senior manager of a company/ companies may apply for the acquisition of the Cypriot citizenship through naturalization by exception.

Also a high-ranking senior manager may apply, provided that he/she receives such a remuneration that generates for the Republic tax revenues of at least €100,000 over a three year period and provided that this tax has already been paid or prepaid.

It is important to note that the applicant should have made the necessary investments during the three years preceding the date of the application and must retain the said investments for a period of at least three years as from the date of the naturalization.

In addition, the applicant must fulfil the Terms and Conditions set out in Part B. In the case where, following a periodic inspection, it has been established that a criterion, term or condition of the Scheme has been breached, the granted naturalization may be revoked.

By virtue of the recent decision of the Council of Ministers, the amended criteria are applicable with immediate effect.

Investment Criteria

Namely, an applicant may acquire the Cypriot Citizenship through the Scheme, in one of the following ways:

Part A:

A1. Investment in Real Estate, land development and infrastructure projects:

The applicant must have made an investment of at least € 2.000.000 for the purchase or construction of buildings or for the construction of other land development projects (residential or commercial developments, developments in the tourism sector) or other infrastructure projects.

It is noted that investment in land for development is included in this criterion, provided that an investment plan for the development of the purchased land will be included in the application. It is understood that investment in land that is situated in a building zone of zero development rate, is excluded

A2. Investments in the purchase, incorporation or participation of Cypriot Companies or businesses:

The applicant should have proceeded with the purchase, incorporation or participation in companies or businesses established and operating in the Republic of Cyprus with investment costs of at least €2,0 million. The invested funds must be channelled towards the financing of the investment objectives of these companies or businesses exclusively and only in Cyprus, based on a specific investment plan.

The applications shall be evaluated to verify that the companies or businesses have proven physical presence in Cyprus, with significant activity and turnover and employ at least five (5) Cypriot or citizens of European Union member-states. The minimum number of employees shall increase, if more than one applicant invests simultaneously or almost simultaneously in the same business or company. In addition, the employees of the said companies need to have legally and continuously resided in Cyprus during the five years preceding the application submission date.  

A3. Investments in Alternative Investment Funds ( "AIFs") or financial assets of Cypriot companies or Cypriot organizations that are licenced by the Cyprus Securities and Exchange Commission ("CySec"):

The applicant should have bought units of at least €2,0 million from Alternative Investment Funds (AIF) established in the Republic of Cyprus, licensed and supervised by the CySec and whose investments are made exclusively in the Republic of Cyprus, and the said investments must meet the criteria of this Scheme or in areas approved by the Minister of Finance.

In order to confirm that the investments that meet the criteria of the current Scheme will be kept for at least three years, the manager or the auditor of the Fund shall inform in writing and on an annual basis, the Ministries of Finance and Interior with reference to the value of the initial investment.

The purchase of financial assets of Cypriot businesses or organizations of at least €2,0 million, such as bonds, bills and securities, issued with the approval of the CySec, by companies that have proven physical presence and substantial economic activity in the Republic of Cyprus, and have as a purpose the financing of the investment plans of these businesses or organizations exclusively in Cyprus, based on an investment plan, fall under this criterion.

It is noted that the purchase by an AIF of units of other AIFs is not considered an eligible criteria for the Scheme.

A4. Combination of the aforementioned investments:

The applicant may proceed with a combination of the investments mentioned in A1 to A3 provided that the total amount of the investments will amount up to at least €2,0 million.

Within this criterion (combination of investments) the applicant may purchase special government bonds of the Republic of Cyprus, up to €500.000, which will be issued by the Public Debt Management Office of the Ministry of Finance, on condition that the investor will retain these bonds for a three year period.

Investments in government bonds through the secondary market are not considered eligible.

Further to the above, the following Terms and Conditions must apply.


1. Clean Criminal Record: The applicant must submit a clean criminal record certificate from the Country of Origin certified by diplomatic means.

2. Residence in the Republic of Cyprus: The applicant must own a private residence of at least €500.000 (five hundred thousand euro) market value plus V.A.T which must be situated in Cyprus. It is noted that members of the same family, who apply separately as investors, can collectively acquire a residence, provided that the total value of this home-property covers the amount of €500.000 per each applicant.

Note: In case that the purchase value of the permanent privately owned residence in Cyprus exceeds the amount of €500,000, part of this additional amount can be used for purposes of supplementing the total amount of the investment made on the basis of the criteria of Part A above. Additionally, it is noted that if the applicant has invested in housing unit/units on the basis of the aforementioned criterion A.1, the purchase of another permanent residence in Cyprus will not be required, if at least one of these housing units is worth at least €500,000 plus VAT, provided that the applicant retains the possession of the residence for life.

3. Residence Permit in Cyprus: The applicant, prior to his/her naturalization as a Cypriot citizen must hold a residence permit in Cyprus. If the applicant does not already hold a residence permit, he/she may apply for an immigration permit on the basis of Regulation 6 (2) of the Aliens and Immigration Law, simultaneously with the application for naturalization. If the application for acquiring an immigration permit is made solely for purposes of acquiring the Cypriot citizenship, in accordance with the provisions of this Scheme, there are no other conditions than those stated in both Part A and Part B of this Scheme.

Note:  All of the above also apply for the adult members of the family of the investor, who will apply for naturalization. In case the application for naturalization is rejected for any reason, the immigration permit, obtained in accordance with the provisions of this Decision, will be cancelled immediately.


In order for the applications to be processed (application type M127) the following supporting documents must be deposited depending on each case. Namely:

1. Clean Criminal Record: Certificate of Clean Criminal Record from the country of origin and the country of residence (if different).

2. Residence in the Republic of Cyprus:

  1. Contract of Sale.
  2. Title Deeds or proof of registration of the contract with the Lands and Surveys Department.
  3. Proof of payment of the agreed purchase price.
  4. Copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the seller's company.
  5. An evaluation certificate from an independent registered land surveyor, if required by the Ministry of Interior or the Ministry of Finance.

3. Criteria regarding the investment (when applicable):

  1. Certificate of Registration of the company/ companies by the Registrar of Companies.
  2. Certificate of shareholders by the Registrar of Companies or certificates evidencing that the applicant is the beneficiary owner of the company/ companies.
  3. Audited accounts of the company (or companies) for the last three years preceding the year of the application.
  4. If the applicant is a high-ranking senior manager, the submission of the employment contract and the receipt from the Department of Inland Revenue is additionally required.
  5. If the investment is made by the spouse of the applicant or jointly, a marriage certificate is required.

Furthermore, depending on the case, the following are required:

1. Investment in real estate, land development and infrastructure projects:

  1. Contract of sale.
  2. Title Deeds or proof of registration of the contract with the Lands and Surveys Department.
  3. Proofs of payment of the agreed purchase price.
  4. Copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the seller's company.
  5. An evaluation certificate from an independent registered land surveyor, if required by the Ministry of Interior or the Ministry of Finance.

2. Investment in financial assets of Cypriot companies or Cypriot organizations:

  1. Contract of sale.
  2. Proof of payment of the agreed purchase price.
  3. Certificate of shareholders by the Registrar of Companies.
  4. Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization.
  5. Specific investment plan.
  6. Copies of the employment contracts of the Cypriot or European Union citizens employed by the company in which the applicant has invested.
  7. Confirmation from the Social Insurance Department as to the insurable income of the Cypriot or European Union citizens employed in the company.
  8. Copy of the Social Insurance Contributions for every Cypriot or European Union citizen employee.
  9. Registration Certificate (MEU1) or Permanent Registration Certificate of Union Citizen (MEU3) for employees that are European Union citizens.

3. Investment in Alternative Investment Funds or financial assets of Cypriot companies or Cypriot organizations that are licensed by CySec:

  1. Title/Titles and other relevant documents of the financial assets / units purchased.
  2. Copy of the wire transfer to a Cypriot commercial banking institution in the name of the company or the organization.
  3. Specific investment plan.
  4. Confirmation by the CySec.

4. Investment in government bonds:

  1. Proof from the Public Debt Management Office for the purchase of special government bonds.
  2. Copy of the wire transfer into a bank account of the Treasury of the Republic of Cyprus.

Members of the Family of the investor who obtains the citizenship (the "Investor")
The spouse, cohabitee, parents and children above the age of 18 but who are financially dependent on the Investor who has obtained the citizenship may obtain the Cyprus citizenship by filing an application to the Ministry of Internal Affairs (Form M 127).

In order to facilitate the procedure for the spouse and the cohabitee of the Investor they can apply for citizenship simultaneously with the application of the Investor when he files his own application.

The parents and the children of the Investor above the age of 18 but who are financially dependent on the Investor must file their application for citizenship be exception (Form 127) once the Investor has obtained his citizenship.

The parents of the Investor must own residential property in Cyprus of at value of at least €500,000 plus VAT. However the Investor and his parents can jointly buy a property of a total value of at least €1 million plus VAT.

Financially dependent children above the age of 18 are those that:

  1. Are students until the age of 28 and who study at a university - thein main activity being their studies for obtaining a university degree, certificate, diploma, Bachelor or Mater. Studies for professional qualifications do not satisfy these requirements (such as Certified/Chartered Accountants, Barristers etc.);
  2. Persons with serious physical or mental disability which renders them unable to work.


The designated Cypriot authority which approves the application is the Cyprus Council of Ministers which, notwithstanding compliance with the above conditions exercises absolute discretion in the approval.

Our services and support for the duration of the application's approval procedure

Our offering of services and support will cover a variety of steps and stages. Namely:

  • Advice to the applicant in face to face meetings with him/her on meeting the required criteria including discussion and advice on actions that may be deemed necessary;
  • Thorough examination of the required documents in order to ensure that all the necessary requirements are met and that all the required documentation is of the appropriate standard;
  • Submission of a letter by Chryssafinis and Polyviou LLC addressed to the Minister of Interior accompanying the application by means of which our professional opinion would be presented and arguments will be stressed as to why approval of the particular application would constitute a benefit to Cyprus;
  • In addition to the above we are committed to a continuous monitoring for the duration of the approval procedure and briefing of the applicant.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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