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In recent years many countries have
initiated programmes allowing high net-worth individuals to acquire citizenship
by means of investment. Certainly, one cannot deny that this process has been
influenced by destabilization of certain regions, globalisation and migration for
reasons of stability, prosperity and other personal reasons or financial
reasons that such persons may have.
The desire to attract new investors
and capital has for decades incentivised countries to conclude visa-free
travelling arrangements and offer residence and citizenship programmes. Indeed,
there is no doubt that citizenship by investment is one of the mechanisms that
can be used for such purposes and whilst several countries have previously
embarked on such programmes, Malta and Cyprus can nowadays be seen as two major
players in this field. Other comparable programmes are offered by Antigua and
Barbuda, The Republic of Austria, The Republic of Bulgaria, Grenada, St Kitts
& Nevis, and The Dominican Republic.
Since both Malta and Cyprus are
relatively similar in nature, being two islands in the sunny Mediterranean Sea,
being predominantly English speaking, having similar Mediterranean cultures and
offering similar lifestyle, the scope of this article has been restricted to
the comparison of the relevant Maltese and Cypriot citizenship for investment
Opportunities enjoyed by expats under Maltese and Cypriot citizenship for investment programmes.
Whilst Cyprus and Malta offer
wonderful climatic conditions with warm winters and hot summers that most
people residing in the sub-zero climates of the northern Eurasia states would
love to enjoy, undoubtedly, the weather is not the major reason that plays a
part in such life choices. Some of these are discussed hereunder.
The economies of both countries are
stable and offer interesting investment opportunities. To its credit, due to
its conservative financial services policies, Malta has masterfully weathered
the global financial crisis of the resent decade without a hint of a problem. Cyprus
on its part, although having suffered a traumatic economic meltdown, has started
to recover and is now
gaining international confidence as having a positive economic outlook.
International Travel Benefits
Both countries have developed a Double
Tax Treaty network and have concluded visa-free arrangements with several
countries for purposes of tourism as well as facilitating business development.
In particular, Malta enjoys a visa-free regime with about 173 states, benefits
from US Visa Waiver Programme (“VWP”) wherein Maltese citizens can stay in the
US up to 90 days, and to top this all up, Malta is a party to Schengen
Agreement, giving Maltese citizens and residents free movement in all Schengen
Member States without border control. Cyprus is slightly behind in this
regards, having a visa-free regime with approximately 169 states. It’s citizens
do not benefit from the US “VWP” and need to obtain a visa prior to visiting
the US. Most remarkably, Cyprus (as at date of publication of the present
article) is not a party to Schengen Agreement.
The corporate tax regimes adopted by
Cyprus and Malta are distinctly different. In Cyprus, companies are taxed at a
flat tax rate of 12.5%, whilst the Maltese corporate fiscal system taxes income
of companies depending on the nature of the income and the residence of the
ultimate beneficiaries. The result is that corporate taxation may vary between
35% and 5%, depending on the particular circumstance.
Some salient requirements introduced by the respective Citizenship Programmes
Having briefly analysed a few
interesting advantages that Malta and Cyprus have on offer, it is crucial that
attention is given to a number of crucial requirements that the applicants are expected
to satisfy to be eligible to obtain citizenship by investment, since there
would be no scope in applying should the applicant not be eligible in the first
place. Some noticeable requirements of the Maltese programme include the
The investor is expected to either
purchase or lease out an immovable property (Purchase value: €350,000 / Lease
value: €16,000/annum). He/she is entitled to substitute rent to purchase and
vice versa throughout a period of 5 years which is the minimum term wherein the
applicant is required to own or lease the property;
large circle of dependants is allowed to participate apart from the main
is no obligation imposed to hold property for a life time. After the term of 5
years expires, the
applicant can sell the property or terminate the lease.
Under the current rules, the maximum
number of participants under the IIP programme is limited to 1,800
participants. However, Identity Malta which is the competent authority
responsible for the programme has recently initiated consultations as to
whether the number of participants should remain capped or not.
A more comprehensive list of
requirements is contained in our Comparative Guide that may downloaded by
clicking the link hereunder.
Some main requirements established by
the Cypriot programme:
1. This programme offers the possibility
to choose one among a number of possible investment options;
2. It is marketed that the application
process should last 6 months;
3. The term applicable with respect to
the holding of investments is 3 years. However, there is an obligation to hold
a residential immovable property for a lifetime;
4. No maximum number of participants.
On a practical note, whilst technically
this may not be considered as a requirement, neither Cyprus nor Malta oblige
applicants to renounce to other nationalities prior to obtaining citizenship.
Although Malta was not the first country
to initiate a citizenship for investment programme, it has undoubtedly gained a
remarkable success. Stable economic growth coupled with an appropriate fiscal
policies, mild climate, political stability and visa-free arrangements are the
key factors that potential investors usually look for. Several of these
advantages are equally reflected in Cyprus.
The weakest feature of the Maltese
programme is the financial contribution required to be made by the principal
applicant consisting in a one-time contribution of €650,000 to the government’s
Social Fund. Unlike the Cypriot programme, there is however no life term
property holding obligation and the overall initial financial obligation
required under the Maltese programme is distinctly less than that of Cyprus. Furthermore,
the Maltese programme offers opportunity to investors to substitute property ownership
with rental and vice versa, thus offering a level of flexibility.
On its part, the Cypriot programme can
be obtained in shorter time and does not involve a hefty one-time contribution
but rather imposes a life time investment in immovable property of a minimum of
The above summarily discusses some
pros and cons of the two Citizenship Programmes as well as similarities and
differences. From a professional perspective however, it is fascinating to
compare the requirements adopted and question what really are the criteria that
ultimately draw a high net worth individual to select one jurisdiction over
another. Our guess is that it may be for a number of reasons coupled together;
someone else may feel that it may be purely a financial matter; affinity to one
jurisdiction over another could be another reason; for those who can afford to
do so, please take your pick!
For a better understanding of the topic, we have developed a more
comprehensive comparative, available by clicking: vl_malta_vs_cyprus_web_v4_copy_copy_copy
For more information kindly contact
Dr Mark Bencini or Mr Mikhail Botvinov
T: +356 2122 8340
F: +356 2122 8360