Please note that as a general principle EEA citizens are free to move to other EEA countries. Switzerland is in the Schengen Area and as such EEA citizens can move there and vice versa. Unless specified, the residence schemes are therefore applicable to non-EEA individuals for all of the countries featured. St Kitts & Nevis is not in the EEA and therefore their scheme applies to EEA and non-EEA individuals.
Services Provided by Dixcart
- Staff resident in Cyprus, Guernsey, Isle of Man, Malta, Portugal (Lisbon and Madeira), St Kitts & Nevis, Switzerland and the UK
- Expertise regarding each jurisdiction: lifestyle, tax regime etc.
- Organising visits if required
- Sourcing of property
- Coordination of the application process
- Undertaking/coordinating requisite legal work
- Wealth management
- Assistance with relocation, concierge services
- Provision of personal and corporate professional services once relocation has taken place
PLEASE NOTE: In addition to the Financial Criteria detailed below Government Fees are payable which vary considerably depending on the particular Residence Scheme. Information is available on request.
|Country and Residence Scheme||Benefits||Financial/Other Obligations||Additional Criteria|
Citizenship by Investment
|A Cyprus passport will
be received a maximum of six months after the application.
Settlement in the EU.
Visa free travel to over 150 countries.
The Applicant's spouse/partner and children can apply without having to meet any financial criteria and their application can be submitted along with the investor's application, so that they will all be able to acquire Cypriot Citizenship simultaneously.
The applicant's parents may also apply by investing only a further €500,000 in a separate private permanent residential property.
High-ranking senior managers of companies that meet the financial criteria may also apply (subject to specific terms and conditions).
In July 2017, the Cyprus Government voted for an amendment, establishing a new "60 day rule". This new rule will apply to individuals who, in the relevant tax year:
If the applicant satisfies either the current "183 day rule" or the new "60 day rule" and becomes tax resident in Cyprus (but not domiciled there), the following sources of income enjoy a ZERO rate of tax (even if the income has a Cyprus source and is remitted to Cyprus):
|The minimum investment
is €2.5million (€500,000 of which must be in a
residential property – please see Additional Criteria).
Investments can be made in the following:
Investment in the Financial Assets of Cypriot Companies or Cypriot Organisations that are licensed by CySec
The applicant must purchase financial assets of Cypriot companies or Cypriot organisations with a minimum value of €2 million.
Purchase, Establishment or Participation in Cypriot Businesses or Companies
The applicant must make an investment of at least €2 million in the purchase, establishment or participation in businesses or companies that are based and operating in Cyprus. These businesses or companies must have a tangible presence in Cyprus and employ at least five Cypriot or EU citizens.
Investment in Real Estate, Land Development or Infrastructure Projects
The applicant must make an investment with a minimum value of €2 million in the purchase or construction of buildings or other land development projects.
If the investment is made ONLY in residential property and one property is worth at least €500,000 and is a permanent privately-owned residence in Cyprus, the Additional Criteria (A) does NOT need to be met.
Investment in Government Bonds
The applicant can purchase Cyprus state bonds up to a maximum value of €500,000. This investment option can only form part of the Combined Criteria detailed below.
A Combination of the Above Criteria
The applicant must meet a combination of the above criteria, with the total investment amounting to at least €2 million.
The applicant must visit Cyprus at least once for administrative reasons (collection of biometric data).
|A. The applicant must
own a permanent privately-owned residence in Cyprus, the purchase
price of which must be at least €500,000 (plus VAT), which has
to be maintained for life However, this property can be rented
B. The minimum amount of time for which the investment must be maintained is 3 years from the date of naturalisation.
C. The applicant must hold a residence permit for a period of at least 6 months in Cyprus prior to his/her naturalisation as a Cypriot citizen. For applicants that do not already have a residence permit, an application for a residence permit can be made at the same time as the application for naturalisation, without any additional criteria having to be met.
D. The applicant and family members must have a clean criminal record from their country of origin and their country of residence (if different) and/or from the Cyprus Police.
E. The applicant's name must not be included on the EU list of individuals whose property has been frozen (sanctions list).
|Cyprus: Permanent Residence Permit||The applicant's
passport is stamped and a certificate provided that indicates that
Cyprus is a permanent place of residence for that individual.
Simplified process for acquisition of a Schengen Visa for holders of a permanent residence permit.
Ability to organise business activities in the EU, from Cyprus.
The procedure generally takes two months from the date of the application.
If the applicant becomes tax resident in Cyprus (i.e. they satisfy either the "183 day rule" or the "60 day rule" in any one calendar year) he/she will be taxed on Cyprus income and income from foreign sources. However, foreign tax paid can be credited against the personal income tax liability in Cyprus.
|A letter from a
financial institution in Cyprus must be obtained to confirm that a
fixed deposit of €30,000 has been transferred to Cyprus from
abroad and is pledged to be retained in Cyprus for at least three
years. There are no restrictions on how this money is used once
this three year period has elapsed.
The applicant, and his/her spouse, must prove that they have at their disposal a secure annual income of at least €30,000. This annual income needs to increase by €5,000 for every additional dependant. The income can be from pensions, overseas employment, interest on fixed deposits or rental income from abroad.
The applicant must purchase one or two new real estate properties in Cyprus (re-sale property is not acceptable) with a total purchase cost of at least €300,000 (excluding VAT). At least €200,000 must be paid as the Sale Contract is signed and prior to the application for the Permanent Residence Permit. The properties can be one house, or one house and one office, or one house and one retail outlet.
|The applicant and his
spouse must submit evidence that they have a clean criminal record
from their country of residence.
The applicant and his spouse must confirm that they do not intend to be employed in Cyprus.
The applicant and the family members included in the Permanent Residence Permit must visit Cyprus within one year of the permit being granted and from then on at least once every two years (one day is regarded as a visit).
Capital gains tax is imposed at the rate of 20% on gains from the disposal of immovable property situated in Cyprus, including gains from the disposal of shares in companies which own immovable property, excluding shares listed on a recognised Stock Exchange. Capital gains tax is imposed even if the owner of the property is not a Cyprus tax resident.
individuals are taxed on their worldwide income or they can elect
to be taxed on their Guernsey source income only and pay a standard
annual charge of £30,000 in 2016.
Individuals have a tax-free allowance of £9,675. Income tax is levied on income in excess of this amount at a rate of 20%, with generous allowances.
Individuals can pay 20% tax on Guernsey source income and cap the liability on non-Guernsey source income at a maximum of £110,000 OR cap the liability on worldwide income at a maximum £220,000.
individuals do not generally need permission from the Guernsey
Border Agency to move to the Bailiwick of Guernsey:
||An individual resident
in Guernsey for 182 days or more is considered principally resident
and taxable on their worldwide income
|Simple and very low tax
system based on:
1. Property tax on local property – based on size
2. Personal tax per resident adult (or having property available) for over 91 days:
|Please see Financial/Other Obligations above relating to Guernsey.||There are no specific residence requirements. Tax is payable if an individual resides in Sark or has a property there which is available to him/her for over 91 days per annum.|
|Isle of Man:
Tier 1 Investor Visa and
Tier 1 Entrepreneur Visa
|Please see UK section
below in terms of Benefits. In addition:
A successful applicant and his/her family are entitled to receive British Citizenship, if all of the relevant conditions are met. Subsequently an application can be made for a British passport.
The standard rate of personal income tax in the Isle of Man is 10%, with a higher rate of 20%. Annual personal income tax can be capped at £125,000 for a period of five years for Isle of Man tax residents. This annual tax cap of £125,000 is doubled for a married couple where they choose to be jointly assessed.
There is no restriction on purchasing property in the Isle of Man and there is a single housing market.
|Please see UK section below in terms of the Financial Criteria that need to be met.||Please see UK section below in terms of the Additional Criteria that need to be met.|
The Individual Investor Programme
receive Maltese citizenship.
Settlement in the EU.
Visa free travel to over 160 countries.
|An applicant has to make
a minimum contribution of €650,000 to the Maltese
An additional contribution of €25,000 is required for a spouse and for each child under the age of 18. A contribution of €50,000 is required for each unmarried child between the ages of 18 and 25 years, and for each dependant parent over the age of 55.
A property must be purchased in Malta with a minimum value of €350,000 or a property rented for a minimum annual rental of €16,000. This must be maintained for a minimum of 5 years.
A minimum investment of €150,000 in eligible Government stocks, shares or debentures for a minimum of 5 years.
|The programme is
not open to individuals falling into the following
An Authorised Registered Mandatory in Malta must submit an application to the Commissioner of the Inland Revenue on behalf of the applicant. Dixcart Management Malta is an Authorised Registered Mandatory.
The Residence and Visa Permit Programme
receive a Maltese residence permit. After five years of residency,
the main applicant and dependents are eligible to apply for long
term residence in Malta.
Free movement within the Schengen Zone (26 European countries).
Individuals will be taxed on Malta source income and certain gains arising in Malta. They will not be taxed on non-Malta source income not remitted to Malta. In addition they will not be taxed on capital gains even if this income is remitted to Malta.
The following benefits were introduced in July 2017:
|An individual must make
a three-tier investment:
Children born or adopted by the main applicant after the initial application approval date can be included.
|Please see Additional
Criteria above, relating to the Malta Individual Investor
Programme. In addition an applicant must:
'Key Employee Initiative'
|Successful applicants receive a fast track work/residence permit within five working days from the date of application, valid for one year. This can be renewed for a maximum period of three years.||Applicants must provide
proof and the following information to the 'Expatriates
||The scheme is applicable to managerial and/or highly-technical professionals with relevant qualifications or adequate experience relating to a specific job.|
The Global Residence Programme
receive a Maltese residence permit.
Free movement within the Schengen Zone (26 European countries).
A flat rate of 15% tax is charged on foreign income remitted to Malta, with a minimum amount of tax payable of €15,000 per annum (income arising in Malta is taxed at a flat rate of 35%). This applies to income from the applicant, his/her spouse and any dependants jointly.
Foreign source income not remitted to Malta is not taxed in Malta.
Individuals may also be able to claim double taxation relief under the regime.
|An individual must pay
annual minimum tax in Malta of €15,000.
||Available to non-EEA
nationals and non-Swiss nationals.
Please see Additional Criteria above, relating to the Malta Individual Investor Programme. In addition:
An applicant must not spend more than 183 days in any other jurisdiction in any single calendar year.
The Highly Qualified Persons Scheme
|Income tax is set at a
flat rate of 15% for qualifying individuals (instead of paying
income tax on an ascending scale with a current maximum top rate of
No tax is payable on income earned over €5,000,000 relating to an employment contract for any one individual.
|The scheme is targeted towards professional individuals earning over €81,457 per annum and employed in Malta on a contractual basis.||The applicant can be a
national of any country.
Please see Additional Criteria above relating to the Malta Individual Investor Programme. In addition:
The scheme is available to EU individuals for 5 years and to non-EU nationals for 4 years.
The Retirement Programme
|An attractive flat rate of 15% tax is charged on a pension remitted to Malta. The minimum amount of tax payable is €7,500 per annum for the beneficiary and €500 per annum for every dependant. Income that arises in Malta is taxed at a flat rate of 35%.||An individual must own
or rent a property in Malta as his/her principal place of residence
worldwide. The minimum value of the property must be:
||Please see Additional
Criteria above relating to the Malta Individual Investor Programme.
At least 75% of the individual's income must derive from a pension, with a maximum 25% being "other income".
This programme is designed to attract nationals of the EU, EEA and Switzerland who are not in employment and are in receipt of a pension.
An applicant must reside in Malta for a minimum of 90 days in each calendar year, averaged over any 5-year period. In addition he/she must not reside in any other jurisdiction for more than 183 days in any calendar year.
|Gives an immediate right
to reside in Portugal.
Residence in Portugal.
Individuals who have been resident in Portugal for 5 years can apply for permanent residence. This is usually granted, if they can demonstrate that they have held a residence visa for the last 5 years.
At the end of the 5th year of being classified as resident in Portugal an individual can apply for Portuguese nationality and therefore a Portuguese passport.
Settlement in the EU.
Visa-free travel to approximately 170 countries, including free movement within the Schengen Zone (26 European countries).
|In order to qualify for
a Golden Visa an individual must meet and maintain, for at least 5
years, one of the following investment options:
Requirements in Portugal:
The Non Habitual Residents Regime
|Tax exemption on
foreign-source income when certain conditions are met. This
includes income from pensions, dividends, work and provision of
services, and royalties and interest, for ten consecutive
Income derived from employment or independent personal services in Portugal is taxed at a special flat rate of 20% for ten consecutive years, as above.
28% flat rate of withholding tax on interest, dividends and/or capital gains relating to Portuguese source income.
No capital gains on the sale of a permanent residence in Portugal as long as the gains are re-invested in another permanent residence in Portugal or another EU or EEA country.
|Portuguese employment income must be derived from high value-added activities of a scientific, artistic or technical nature.||This regime is available
to EU and non-EU individuals who become resident for tax purposes
in Portugal, provided they have not been resident in Portugal for
the previous five years.
Individuals can enjoy non-habitual status for a ten year period, after which they will be taxed under the standard personal income tax rules in Portugal.
|St Kitts &
Citizenship by Investment
|Individuals and families
can obtain a second passport and residence, if required, through
the St Kitts & Nevis Citizenship by Investment Programme.
St Kitts & Nevis passport holders enjoy full Schengen privileges (free movement to 26 European countries), can travel to approximately 120 countries worldwide (either on a visa free basis or visa on entry basis) and do not require a visa to visit the United Kingdom.
A number of attractive tax advantages are available to individuals who choose to become resident in St Kitts & Nevis:
It is now possible for an application to be fast tracked via the accelerated application process (AAP). Applications, submitted with the correct documentation, will be approved within 60 days and may be approved within as little as 45 days.
Citizenship can be passed on to future generations by descent.
|There are three options
Applicants can make an investment in real estate via two routes:
1. Five-year hold period
Investment of a minimum US$400,000 per main applicant in a property in an approved property development area in St Kitts & Nevis. The investment must be maintained for a minimum of five years.
2. Seven-year hold period
Investment of a minimum US$200,000 in new luxury developments in St Kitts & Nevis. The investment must be maintained for a minimum of seven years.
Sustainable Growth Fund (SGF)
A single applicant can make a contribution of US$150,000 to the Sustainable Growth Fund (SGF). The contribution for a family of up to four will be US$195,000.
|It is not necessary for
the applicant to have visited St Kitts & Nevis but the
application must be made by a Registered Agent resident in St Kitts
& Nevis, such as Dixcart.
Common law partners are accepted for sponsorship.
Standard due diligence items are required including:
Lump Sum Tax Regime
|The Swiss Lump Sum
System of Taxation is based on an assumed income, generally
approximately seven times the annual rental value of the property
occupied in Switzerland.
Liability to inheritance tax varies from canton to canton. A few cantons do not apply inheritance tax. The majority do not levy it between spouses or between parents and children, and levy only a modest tax of below 10% for other descendants.
Individuals taxed under the Lump Sum Regime are able to manage their worldwide investments from Switzerland.
|Swiss tax is paid on an
assumed income, generally approximately seven times the annual
rental value of the property occupied in Switzerland. The precise
taxation liability will depend upon the canton and the area of
residence within the canton.
The Swiss Government confirmed its commitment to maintaining the Lump Sum System of Taxation in November 2014.
|This regime applies to
foreigners who move to Switzerland for the first time, or after an
absence of ten years, and who will not be employed or commercially
active in Switzerland.
Please note there are 26 Swiss cantons.
Only the three Swiss cantons of Appenzell, Schaffhausen and Zurich abolished the Lump Sum System of Taxation in 2013.
|Settlement in the
Visa-free travel to over 170 countries once British passport obtained.
Individuals resident but not domiciled in the UK are eligible to pay tax on a remittance basis.
There is no tax on the gains and income that arise from funds retained outside the UK, as long as the income and gains are not brought into or remitted to the UK.
In addition, clean capital (i.e. income and gains earned outside of the UK before the individual became resident, that have not been added to since the individual became resident in the UK) can be remitted to the UK with no further UK tax consequences.
If unremitted foreign income is less than £2,000 at the end of the tax year (6 April to the following 5 April), the remittance basis applies automatically.
If unremitted foreign income is over £2,000 then the remittance basis can still be claimed, but at a cost (depending on circumstances costs are £30,000 or £60,000 or £90,000 from 6 April 2015).
Anyone who has been resident in the UK in more than 15 of the previous 20 tax years, will not be able to enjoy the remittance basis and so will be taxed in the UK on a worldwide basis for income and capital gains tax purposes.
|This is formally known
as the Tier 1 (Investor) visa. Under this visa category, an
individual from outside the EEA can apply for Entry Clearance (EC)
for an initial UK residence visa which will be valid for up to 3
years and 4 months by bringing £2 million to the UK and
investing these funds in permissible investments.
As long as the provisions continue to be satisfied, after an initial 3 year period the individual can apply for Leave to Remain (LTR) (an extension) for a 2 year visa and, following this, can then apply for Indefinite Leave to Remain (ILR) in the UK. The rules allow for accelerated ILR after 3 years if an individual has invested £5 million and after 2 years if £10 million has been invested.
|In terms of the
Indefinite Leave to Remain (ILR), the main applicant must not be
absent from the UK for more than 180 days in any single year.
An individual will usually be eligible for citizenship once they have been resident in the UK for 5 years, and have had ILR for at least one year. In a standard situation, it will usually take 6 years before an individual is eligible to become a British citizen. To meet the citizenship requirements an applicant must not be absent from the UK for more than 450 days in the 5 year qualifying period, and for not more than 90 days in the final 12 months of that 5 year period.
If an individual is married to or in a civil partnership with a British citizen, then they will usually be eligible to apply for citizenship once they have been resident in the UK for 3 years, and have ILR. In a standard situation, it will usually take 5 years before an individual is eligible to become a British citizen. To meet the citizenship requirements an applicant must not be absent from the UK for more than 270 days in the 3 year qualifying period, and for not more than 90 days in the final 12 months of that 3 year period.
|Please see Benefits above relating to the UK Investment Visa.||This is formally known
as the Tier 1 (Entrepreneur) visa. Under this visa category, an
individual from outside the EEA can qualify for a UK Entrepreneur
Visa if they invest a minimum of £200,000 in a new, or
existing, business in the UK and create new employment. In certain
circumstances the initial investment can be reduced to a minimum of
£50,000. The visa allows an individual to enter and reside in
the UK for up to 3 years and 4 months.
After 3 years, an individual can apply for LTR in the UK for an additional 2 years, as long as the individual remains engaged in the specific business activity detailed by the visa and the business has created at least two full time jobs for settled workers in the UK.
After 5 years the individual can apply for Indefinite Leave to Remain (ILR) in the UK. Similar to the UK Investor visa, the UK Entrepreneur visa allows for accelerated ILR after 3 years if the business has created 10 full time jobs for settled workers in the UK, or has an income from business activity of £5 million.
|Please see Additional Criteria above relating to the UK Investment Visa.|
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.