GLOBAL Residence and Citizenship - Cortelek Presentation-Oneword

GLOBAL RESIDENCE AND CITIZENSHIP

Contents

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Residence and Citizenship

Residence Programs

Citizenship Programs

Oneworld Group

2GLOBAL RESIDENCE AND CITIZENSHIP

Residence and Citizenship


Reasons Why Wealthy People Relocate (1)

Security

Quality

of life

• Safe alternative in times of political instability

• More privacy in investment and banking

• A defined legal environment is progressively sought after as more laws become increasingly vague

• Better quality of life, climate, personal security

• Cleaner environment and lower air pollution

• Better offering of healthcare and transport systems


Why Wealthy People Relocate (2)

Taxes• Often the only way to reduce the tax burden and regulatory restrictions legally and in a significant manner

is to relocate

Education

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• Graduation at a high ranking school and language skills are increasingly important as the basis for a

successful career


Citizenship by Investment

Several countries have programs in place to attract foreign investors in return for citizenship

The term ‘Citizenship by Investment’ describes


the policies of countries in which foreign persons can obtain citizenship

through capital investments or capital contributions in the country

Reasons for Alternative Citizenship (1)

Visa waiverOpens travel to countries previously restricted by time consuming visa application processes

Retirement The option to retire in a safe country

IndependenceBe able to travel or have the option to relocate after possible

political changes

MobilityFreedom of movement when some nationals are overly exposed to terrorists threats and other

hostility


Reasons for Alternative Citizenship (2)

Protection Protection against data abuse, identity theft and cyber crime

Tax Planning Citizenship can be relevant in tax planning and is one of the tie breaker rules in most double tax treaties

SecurityGuarantees a secure and truly permanent alternative place to go if needed


Dual Citizenship Restrictions

The acquisition of another citizenship can lead to the automatic loss of the current

citizenship

Half of the world´s countries

allow dual citizenship

Carefully check the legal situation prior to

taking any steps to acquire another citizenship


Residence Programs


Premier Residence Countries

Belgium UKHong Kong Portugal

MaltaCanada Singapore

SwitzerlandMonaco

US

Australia

We set out the most attractive countries with regard to

mobility, security, privacy, personal tax and lifestyle

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Cyprus



Australia

Australia – Introduction

Population 23 mn

Multi cultural society

Liberal approach to immigration - it welcomes people to work and invest

A good lifestyle is affordable


Australia - Significant Investor Visa

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• The applicant has to invest AU$ 5 mn for a period of 4 years in a complying investment

• Investment can be government bonds, managed funds or private companies

• Applicants will need to meet standard health and character requirements

• They will need to lodge an expression of interest and be sponsored by a state or

territory

No minimum age limits

No point test (so no minimum English requirement)

Relaxed residence requirement (the investor has to spend only 160 days in Australia

over 4 years)


Australia – Permanent Residence Status

Investors can extend their visa term by an additional 4

years bringing the maximum period on a Provisional

Significant Investor Visa to 8 years !After a minimum period of 4 years, the investor

can apply for a Permanent Significant Investor

visa


Australia – Citizenship

The applicant must:

• have been in Australia for 12

months as a permanent resident

• have had absences from

Australia of no more than ¼ of

the time in the previous 4 years

• be able to speak and understand

basic English

!

Applicants must pass the Australian

Citizenship Test, which focuses on

Australia’s values, history, and traditional

and national symbols


Australia – Taxation

• Progressive tax rates on income and

capital gains of up to 54% (50% discount

when capital assets have been held for

at least 12 months)

• no wealth tax

• no inheritance tax

Australian tax residents are taxed on their worldwide income and

capital gains


Australia – Summary

Advantages

• Multi cultural society and a good

place to live

• Excellent education system

• Low population density

• Acquisition of citizenship possible

after 5 years

Disadvantages

• High taxes



Belgium

Belgium – Introduction

Population 11 mn

Hosts the headquarters of the EU and NATO

Has a highly developed economy

One of the world’s largest trading nations


Belgium – Resident Permit

As a manager or

highly skilled

employee

As a self-

employed

individual

• Minimum salary of €64.000 (manager) or €38.000 (highly skilled employee) - this entails a higher

tax liability of 55%

• Processing time 2-3 months

• The applicant incorporates his/her own company

• No minimum salary level - tax liability will be less

• Processing time 2-3 months

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There are two main economic routes under which a person could qualify for

residence:

The applicant is not restricted to remain only in Belgium but has the freedom to operate abroad


Belgium – Citizenship

After 5 years, it is possible to apply for citizenship

The applicant must prove his/her social and

economic integration

After 10 years, the resident acquires the automatic right

to become a Belgian citizen

This is a unique feature that

provides significant security

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The applicant must secure appropriate accommodation. It must be at his/her disposal at all times during the residence period in the

country.


Belgium – Taxation

• Progressive income tax of up to 50%

(to be increased with local

surcharges)

• No wealth tax

• In principle no capital

gains tax on assets

Commonly known as a high-tax jurisdiction, Belgium is in fact a

discreet tax haven for affluent individuals and families who do not

live off employment income

Special tax rules for foreign employees temporarily residing in

Belgium: The employee is treated as a non-resident and therefore is

only taxed on Belgian source income


Belgium – Summary

Disadvantages

• Establishment of a company in

Belgium is required in most cases

• Pre immigration tax planning

required to take advantages of tax

system

Advantages

• Residence permit gives visa free access to all Schengen States

• Excellent infrastructure in the heart of Europe

• Attractive corporate and private taxation system

• Citizenship possible after 5 years of legal residence

+ 24GLOBAL RESIDENCE AND CITIZENSHIP


Canada

Canada – Introduction

Population 35 mn

Regularly voted as one of the best countries to live in

A good lifestyle is affordable

Globally admired for its multi cultural society

and tolerant foreign policies

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Canada - Federal Immigrant Investor Program

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• Created in 1986

• Specific intention of attracting wealthy individuals with business experience

• Structured as a 5 year, zero interest loan to the Government

• Amount was increased to CAD 800.000 and net wealth amount

to CAD 1.6 mn. The new regulations did not see a decrease in the number of applicants

Due to the exceptionally high volume of applications the program was closed in July 2011

The re-opening has not yet been confirmed as the Government is still considering various options for a major Federal IIP overhaul


Canada - Québec Immigrant Investor Program

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• The program is very similar to the Federal Program

• The yearly maximum number of applications accepted is 1,750

The submission period for 2014 has ended

An application can still be submitted if one has advanced intermediate knowledge of French



Cyprus

Cyprus – Introduction

Population 800.000

Major hub for international trade and member of the EU

Excellent quality of life with a year round climate of sunshine

No tax in Cyprus for any income earned abroad


Cyprus - Global Residence Program

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Purchase real estate property with total cost min €300.000 plus VAT

Pay at least two thirds of the purchase cost prior to Application

Stable means of annual income from abroad of at least €30.000 per year

Funds from abroad deposited in a bank in Cyprus in a 3-year fixed deposit account. The minimum deposit is €30.000


Cyprus - Advantages

No minimum residence stay required

Considered Non-Dom and any income received from abroad is exempt

Residency can be granted in 2 months

Applies to whole family

Can lead to Cyprus citizenship

Easier travel within the EU

Lower tuition costs within Europe



Hong Kong

Hong Kong – Introduction

Population 7.2 mn

Open economy with a free market and low taxation

Liberal approach to immigration policy


Hong Kong - Capital Investment Program

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• There are various categories for individuals to obtain residence in order to

work, live or study

• Individuals who make a substantial investment to the economy are welcomed with open arms

The Capital Investment Entrant Program requires

• an investment of no less than HK$10 mn (US$1.3 mn) into permissible

investments of financial assets (including equities, debt securities,

certificates of deposit or eligible collective investment schemes) for a

period of 7 years


Hong Kong – Timeframe

Upon completion of 7 years ordinary residence, one

may apply for Permanent Residence

!As a PR, one only needs to return to Hong

Kong once every 3 years to maintain status

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• Program has been in place since 2003

• 25.000 people have received the visa (2.500 per year)

• 8 months processing time

• No residence requirement


Hong Kong – Taxation

An attractive Tax System:

• No capital gains tax

• No sales/value added tax

• No wealth/net worth tax

• No tax on inheritance or

gifts

• No tax on interest income

• No withholding tax on

dividends paid by Hong

Kong companies

Taxation is based on the territorial source principle, only levied on

income sourced in Hong Kong

There are three separate income rates:

• profit tax - flat rate of 15% on

professional trade and business income

• property tax - flat rate of 15% (less

standard deduction of 20%)

• salaries tax - levied on net chargeable

income (either on progressive rate or

flat rate)


Hong Kong – Summary

Advantages

• Straightforward

• Well established legal system

• Freest economy in the world

• World-class medical facilities and

education institutions

Disadvantages

• High property prices

• Poor air quality

• High population density

• Citizenship of limited interest



Portugal

Portugal – Introduction

Population 11 mn

Lisbon, Oporto and Guimarães have been European Capitals of Culture

The Algarve is a scenic treasure with a long coastline of golden beaches, dramatic cliffs


Acquisition of real estate of

at least €500.000

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Transfer of capital

of at least

€1 mn

• Programme came into force in October 2012

• Allows non-EU nationals to be granted residence permits for certain investments. The options are:

Residence requirements for the 5 year programme:

• 7 days in the first year of residence, and

• 14 days for the two following two year renewals (1+2+2)

Portugal - Golden Residence Programme


Creation of

of at least

10 new jobs

Portugal – Permanent Residence Status

After the 5 year programme, Permanent Residence

(PR) status can be acquired

The qualifying investment can be sold

No residence requirement

anymore, but …

!

PR status can be revoked if

•

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holder is absent from Portugal for a period

of 24 months, or

• is absent in aggregate of 30 months for a

period of 3 years


Portugal – Citizenship

An application for citizenship can be made following

a

6 year residence period !

The application is subject to prevailing legal

criteria, which currently includes a language

test (European level A2)


Portugal – Taxation

• Progressive income tax of up to 48%

• Standard rate of VAT is 23%

A new, favorable tax treatment program for Non- Habitual Residents (NHRs) has

been designed to attract talented individuals and HNWI's

• Income derived from a Portuguese source: flat rate of 20% (surcharges were

announced recently)

• Income derived from a foreign source (relating to employment income,

pension income and business and professional income) can be subject to

exemption

Granted for a period of 10 years. To be a tax resident, the individual has to remain

in Portugal for 183 days and have a principal home which they intend to use as a

habitual residence


Portugal – Summary

Advantages

• Straightforward and quick process

• Free travel within the Schengen

Area

• Minimal physical presence

requirements to secure renewal

of residence permit

• A country with lifestyle advantages

Disadvantages

• Access to Permanent Residence

requires basic understanding of

the Portuguese language

• Requirements for citizenship

applications (including language

understanding)

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Singapore


Singapore – Introduction

Population 5.3 mn

One of the world’s best places to live

It is frequently voted best Asian city to live in

One of the wealthiest and safest countries in the world


Singapore - Global Investor Programme

To be eligible one:

• must possess at least 3 years

of entrepreneurial track record,

and

• have a company turnover at

least SGD 50 mn per annum on

average for the last 3 years (if in

real estate or construction-

related industry at least SGD

200 mn)

!

The Investor can choose one of the

following options:

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• Invest at least SGD 2.5 mn in a new business entity

(one must submit a 3 year business plan; within 5 years, one

must set up a business with 5 or more Singaporean

employees and must incur at least SGD 1 mn in total business

spending a year)

• Invest at least SGD 2.5 mn in a GIP fund that invests in

Singapore- based companies

The programme has been designed for investors who want to invest in Singapore and

receive Permanent Residence


Singapore – Citizenship

Following the first 5 years, the PR will be renewed for

another 5 years if the investor and his/her dependents

have resided in Singapore for more than half of the

time !

An investor who is granted PR for 2 years is

eligible to apply for Singapore citizenship

Maximum of 1 year absence from Singapore out

of the 2 years prior to the date of application

Singapore does not allow dual citizenship


Singapore – Taxation

Singapore has a mild tax regime:

• Progressive personal income tax rate of up to 20%

• Standard corporate tax

rate of 17%

• No capital gains tax (very limited exceptions)

• No gift taxes

• No income tax on dividends

Taxation is based on the territorial source principle - only levied on income

sourced in Singapore


Singapore – Summary

Advantages

• Safe and orderly with an

excellent education system

• Favourable tax laws

• International financial center

• Acquisition of citizenship possible

after 2 years of PR

Disadvantages

• Property prices are relatively high

• Population density is very high

• Dual citizenship is not allowed

• It becomes difficult for foreign

persons to get a work permit and

renew the resident and PR status



United Kingdom

UK – Introduction

Population 63 mn

One of the most attractive places in the world to live and do business

International business environment - London is the financial capital of the world

World renowned schools and universities

Well connected with direct flight connections to almost all major cities in the world

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UK - Immigrant Investor Program

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• Part of the points based system, the Tier 1 Investor category is for high net worth individuals who want to make a financial

investment in the UK

• Quick processing time of 4 to 8 weeks

• No requirement on English language for the first 5 years

• No health check required

Investor Programs:

• GBP 10 mn or more may apply for PR after 2 years




UK – Permanent Residence Status

Conditions to apply for PR - also known as Indefinite

Leave to Remain (ILR)

!

No more than 180 days spent outside the UK in any

12 month period (this only applies to the principal

applicant)

English language requirement

All applicants must pass a simple 'Life in the UK'

test (easy multiple choice)

• PR, once granted, has no expiry date

• PR will remain in force as long as the holder does not spend more than 2 years consecutively outside the UK


UK – Citizenship

Each applicant must maintain an average of 9 months

or more per year in the UK for 5 years

!Unlike PR, each individual is

on their own time clock


UK – Taxation

• Progressive income tax up to 45%

• Capital gains tax up to 28%

• No wealth tax

• Inheritance tax at 40%

The obligation of personal UK taxes is based around the

concepts of residence and domicile

It is possible to be resident in the UK for tax purposes but non

domiciled. This can provide many tax benefits


UK – Summary

Disadvantages

• Requirement for minimum

physical presence

• Citizenship only after minimum

5 years of residence

Advantages

• London is among the financial

capitals of the world

• World renowned schools

• Attractive tax system for

wealthy individuals (resident,

non-domiciled rules)

• Straightforward investor

immigration program with fast

processing time



Citizenship Programs

St. Kitts & Nevis Antigua & Barbuda

There are currently only six countries which offer citizenship programs that provide a direct, legal route to citizenship based on

investment and sound due diligence

Other countries have similar provisions. However, in those countries there

is no established or clear practice and/or the programs are not transparent

Program Focus

Malta

Antigua & Barbuda Cyprus

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Malta

St. Kitts & NevisAustria Dominica



Antigua & Barbuda

Antigua and Barbuda – Introduction

Population 80,000

Some of the most beautiful beaches in the world

Visa free travel to 129 countries

Tourism generates around 60% of the island’s income


Antigua and Barbuda – Citizenship Investment Program

Announced in November 2012

To qualify for citizenship, the Government

requires either:

A contribution to the National Development Fund of

US$200.000 (usually US$250.000) for a single applicant

An investment in an approved real estate project with a value of

at least US$400.000

An investment into a business, known

as the ‘Direct Investment’ route

Additional Due Diligence fees of US$ 7.500 and Government fees of

US$ 50.000 apply (for up to 4 people)


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Cyprus

Cyprus – Introduction

Population 800.000

Major hub for international trade and member of the EU

Excellent quality of life with a year round climate of sunshine

Tax burden is low


Cyprus – Citizenship Investment Program (1)

An express procedure, it takes only 3 months to be approved

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The investment is as low as €2.5 mn

Citizenship granted to spouse and minor children

No requirement to reside in Cyprus

Visa free travel to over 150 countries


Cyprus – Citizenship Investment Program (2)There are two schemes available to qualify for Citizenship by Investment:

•Individual scheme with threshold of €5 mn

•Collective Scheme with threshold of €2.5 mn

Individual Scheme with threshold

of

€5 mn

• Investment min €5 mn in Cyprus government bonds, or

• Investment min €5 mn in financial instruments of companies and shares,or

• Investment min €5 mn in real estate, or

• Investment min €5 mn in Cyprus businesses/companies, or

• Deposit in Cyprus banks amount to €5 mn

Collective Scheme with threshold

of

€2,5 mn

Reduced amount of €2.5 mn on the basis that they participate in a collective investment scheme with a

total value min €12.5 mn:

• Investment in government bonds, or

• Investment in financial instruments, or

• Investment in real estate and land developing, or

• Investment in Cyprus businesses and companies



Malta

Malta – Introduction

Citizenship gives right of work and establishment in all 28 EU countries

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Population 418.000

Among the earliest settlements in the world, 7.500 years of history

EU member since 2004, member of the Schengen area since 2007

Visa free travel to more than 160 countries


Malta - Citizenship Investment Program

Contribution to the National Economic and

Social Development Fund

• For main applicant €650.000

• For spouse €25.000

• For dependents under / over 18 years

€25.000 / €50.000 each

Annual publication of all naturalised citizens

Due Diligence fees for main applicant €7.500 for spouse €5.000 for dependents under / over 18 years: €3.000 / €5.000

each

A residence in Malta for

at least 5 years

• Purchase of a property: value over €350.000, OR

• Leasing of a property: annual rent over €16.000

Investments into approved

financial instruments

• €150.000

•

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St. Kitts & Nevis

Population 54,000

Unrivalled natural beauty

Visa free travel to 131 countries

Direct daily flights from Miami and by weekly

direct flights from New York and London


St Kitts and Nevis – Citizenship Investment Program

It remains the world’s most

successful program

To qualify for citizenship, applicants have

two investment options:

A contribution to the Sugar Industry Diversification Foundation

of

US$250.000 (for a single applicant)

An investment in designated real estate with a value of at

least US$400.000

Additional Due Diligence fees of US$7.500 and Government fees of US$50.000 apply for the real estate option


St. Kitts & Nevis Vs. Antigua & Barbuda

Processing time

Residence

requirement

Applicant to swear an

oath of allegiance

Access to countries

visa free

Established program which usually takes 6-8

months for approvals to be granted

No

No

131 countries - visa free travel to Tonga, Israel,

Bangladesh and Argentina (Antigua & Barbuda does

not)

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New program so will potentially be processed more

quickly

Requires the applicant to spend an average of a week

per year (35 days over 5 years) over the length of the

program

Yes, either on the island or at an embassy or consulate

around the world

129 countries - visa free travel to Ukraine and South

Africa (St.

Kitts and Nevis does not)


Similar citizenship and residence privileges, although important differences:

St. Kitts & Nevis

Antigua & Barbuda


Oneworld Group

Citizenship and Residency

Residence planning and related tax planning for private clients involves finding solutions for individuals and families who move

internationally, own property in different countries and who often have complex international situations and requirements

For many individuals the option of a second or even third citizenship is very attractive. The freedom which is granted to them is

unparalleled

Our citizenship and residence advisory for private clients involves fiduciary solutions for individuals and families who move

internationally, possibly own property in different countries and who often have international situations and requirements


EnquiriesYou can direct your enquires concerning Private Client Services to:

Oneworld ltd

75 Prodromou Avenue Savvas Shiatis

Oneworld House [email protected]

Nicosia, Cyprus

[email protected] Theodoros Theodorou

www.oneworldweb.net [email protected]

Oneworld MidEast ltd

Bayswater Tower, floor 18 Costas Ioannou

Al Abraj South Street [email protected]

Business Bay

Dubai, UAE Alexandros Philippides

[email protected]

[email protected]

www.oneworldmideast.net

or contact our chairman George Philippides

[email protected] 77

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