Citizenship Planning - Overview of Countries



Australia

It is possible to acquire Australian citizenship and a passport after 4 years of lawful residence. Anyone who became a permanent resident on or after 1 July 2007 must have been lawfully resident in Australia for 4 years immediately before applying, including 12 months as a permanent resident and absences from Australia of no more than 12 months, including no more than three months in the 12 months before applying. Most people are required to pass a test and meet general eligibility requirements before applying for citizenship. There are interesting conditions for investors and highly skilled professionals who wish to become resident. Australia certainly offers a very attractive passport, but also restrictive tax laws and high taxation during the time you are a tax resident. Please enquire for further information and advice.

Austria

The normal period of residence before a citizenship application can be made based on residence is 10 years. To qualify for a grant of citizenship without prior residence under the provisions of the Austrian Citizenship Act, Art. 10 (6), an applicant must provide scientific, cultural or economic benefits to the Republic of Austria. This must be confirmed by the Austrian authorities, who then grant citizenship by a decision of all Government Ministers. Under the citizenship-by-investment provisions, an applicant is required to invest actively in the Austrian economy, for example in the form of a joint venture or a direct investment in a business creating jobs or generating new export sales. A substantial minimum investment is generally required. Passive investments in Government bonds, real estate, etc. do not qualify. Each case is handled on an individual basis. Please click here for more information.

Belgium

Belgium amended its citizenship law in March 2000, and it is now possible to acquire Belgian citizenship after only 3 years of residence. For people with sufficient means, entrepreneurs, self-employed individuals and investors, Belgium offers a relatively easy path to resident status and eventually acquiring Belgian citizenship after 3 years of residence. The BRP Belgium Residence ProgramŽ (BRP) is a fixed-fee service package provided by Henley & Partners for non-EU citizens who are interested in obtaining a residence permit in Belgium. Please click here for further information.

Belize

Belize has terminated its Economic Citizenship program as of January 15, 2002. Under this program, citizenship and a passport could be acquired within approximately 1 month against a one-time contribution to the government. Under the Belize program it was possible to include dependent parents in a single application for a reasonable additional fee. The Belize program had numerous problems, the Belize passport is not well regarded internationally due to this history and only offers limited visa-free travel.

Bulgaria

The Republic of Bulgaria makes provision in its Citizenship Act for the acquisition of citizenship based on proof of Bulgarian origin without any prior residence requirement. Documentary proof to establish such a claim can include ancestry from a Bulgarian citizen or other evidence of ethnicity. Bulgaria has been a full member of the EU since January 1, 2006. Please enquire for further information and advice.

Canada

It is possible to acquire Canadian citizenship and a passport after 3 years of legal residence. However, it is generally no longer possible to spend a considerable part of this period outside of Canada. There are interesting conditions for investors and highly skilled professionals who wish to become resident. Residence in Canada allows you visa-free entry to the USA. Canada has one of the highest personal tax rates in the world, but wealthy individuals who take up residence in Canada can shelter income and assets that are kept outside Canada from Canadian taxation for up to 5 years. The Canadian passport is one of the best-regarded in the world and offers extensive visa-free travel. Please enquire for further information and advice.

Croatia

Croatian citizenship law makes provision for persons of Croatian descent ("emigrants") to be naturalized as Croatian citizens without the usual residence and language requirements. Proof of Croatian-born grandparents is required, along with appropriate supporting documentation. Furthermore, a foreign citizen who is married to such a person of Croatian descent who has acquired Croatian citizenship according to these provisions can also acquire Croatian citizenship without residence and language requirements. Children can acquire Croatian citizenship by naturalization only after both parents have acquired citizenship by naturalization. Please enquire for further information and advice.

Dominica (Commonwealth of Dominica)

Citizenship and a passport may be acquired within 5 - 14 months against a one-time contribution to the government, based on an Economic Citizenship program. Benefits include a Commonwealth passport which allows good visa-free travel to over 50 countries. However, the program is not as good as the Citizenship-by-Investment program of St. Kitts & Nevis, and the passport is less well regarded than other Caribbean passports. Please click here for more information.

Dominican Republic

It is possible to acquire Dominican citizenship and a passport after 6 months of legal residence in combination with an investment in a business or in real estate of at least US$ 50,000. Parallel to this legal way of establishing resident status and acquiring citizenship 6 months later, there is a constant practice of illegal sales of passport and citizenship documents by corrupt government officials, and therefore passports from the Dominican Republic have a bad reputation. Visa free travel is also limited. Acquisition of citizenship in the Dominican Republic will only be of interest in very special circumstances and is generally not recommended. Please enquire for further information and advice.

Germany

Germany has made it easier to qualify for citizenship through descent and naturalization. Since the introduction of its new Citizenship and Nationality Law on 1 January 2000, Germany grants citizenship to any child born on its territory to a foreign parent who, at the time of birth, had resided there lawfully for eight years and who also had either the right to unlimited residence or else had held a permanent residence permit for three years. It also grants citizenship to any child born either in Germany or overseas to a German parent. Foreign nationals who have permanent residence in Germany may now be naturalized after only eight years of lawful residence, subject to certain conditions including an adequate knowledge of German and financial self-sufficiency. This period is reduced to three years if a permanent resident is married to a German citizen. In addition, former German citizens deprived of citizenship between 30 January 1933 and 8 May 1945, on political, racial or religious grounds, may qualify for its restoration along with their descendants. Under Germany's Right of Return, refugees and expellees of ethnic German origin, admitted to its territory within the boundaries of the German Reich of 31 December 1937, may also apply for restoration of citizenship with proof of their ethnicity, along with their spouses and descendants. Please enquire for further information and advice.

Greece

Any person who is ethnically Greek may become a Greek citizen through naturalization, providing he or she can prove a parent or grandparent was born as a national of Greece. Every person born on Greek territory acquires Greek citizenship at birth if he or she does not acquire any foreign citizenship at birth or is of an unknown citizenship. Note that in the past there were several scandals based on creating fake Greek links, whereby many foreign persons obtained Greek citizenship in an illegal way. Documents issued under these scams, including passports issued correctly on the basis of fake documentation, are illegal and pose a significant problem to the persons who hold them. Please enquire for further information and advice.

Grenada

Grenada has terminated its Economic Citizenship program as of October 24, 2001. Under this program, citizenship and a passport could be acquired within approximately 2 - 3 months against a one-time contribution to the government.

Ireland

Irish law allows descendants of Irish grandparents to re-establish Irish citizenship. Ireland is also the only country within the European Union that continues to confer citizenship on all persons born within its territory, although since 1 January 2005 this has been restricted to persons with at least one parent who holds a permanent, unlimited residence permit for Ireland or the United Kingdom. However, the Irish Government has abolished the practice of granting entitlement to Irish citizenship through a substantial investment in the State. The 2001 Irish Nationality and Citizenship Act was passed on June 5 of that year. It amended the Irish Nationality Laws passed between 1956 and 1994 but made no reference to naturalization through investment, so this is no longer a means of obtaining Irish citizenship. However, Ireland allows financially independent persons to obtain a residence permit, and to apply for naturalization as an Irish citizen after five years of legal residence. Please enquire for further information and advice.

Israel

The Law of Return allows any Jewish person to take up residence in Israel and acquire Israeli citizenship. Although citizenship is acquired immediately upon touching Israeli soil and establishing residence in Israel, a full Israeli passport that is good for international travel is normally issued only after one year of residence. There are, however, exceptions, and in some instances it is possible to have a full passport issued immediately. Please contact us for further information and advice.

Lithuania

Lithuania joined the European Union along with nine other European countries in May 2004. It has changed its citizenship law with effect from January 1, 2003 to allow people who were citizens of Lithuania before 15 June 1940, and three generations of their descendants, to regain Lithuanian citizenship without having to give up their existing nationalities. Lithuania never had a specific Citizenship-by-Investment Program as such, but its Citizenship Law allows the naturalization of people who have invested money in the country, benefited the economy and created jobs there without the need to meet the normal requirements. However, this option is handled in an extremely strict way and is thus rarely of interest to international clients in view of the possibilities available in other countries, notably Austria. Please click here for more information.

Mauritius

Under the 1973 Immigration Act, a Permanent Resident Scheme (PRS) was introduced to attract foreign investors to Mauritius. Permanent residence is granted to foreigners (and their families) who invest a minimum of US$ 500,000 in a qualifying business activity. Anyone who has invested under this scheme and has remained resident in Mauritius for a continuous period of 2 years is entitled to apply for citizenship under the 1968 Mauritian Citizenship Act. Please contact us for further information and advice.

New Zealand

New Zealand permits the acquisition of citizenship after 5 years of permanent residence. If you have applied for and received permanent residence after 21 April 2005, you must have been present in the country for a total of at least 1,350 days during the 5 years immediately before making your citizenship application. Moreover, you must have been present there for a total of at least 240 days in each of those 5 years, have been issued with a Permanent Residence Permit by the New Zealand Immigration Service and fully met any conditions imposed by this Service in regard to this Permit. If you can show that there are exceptional circumstances that warrant a reduction, you may be considered as long as you have had a minimum presence in New Zealand of 450 days with a Permanent Residence Permit in the 20 months before making your application. Please contact us for further information and advice.

Panama

Panama has no Citizenship-by-Investment program. You may apply for Panamanian citizenship only after 5 years of residence as a qualifying immigrant. Immigrant status as an investor can be acquired by investing a minimum of US$ 40,000 in a government approved project. Panama also offers residence permits without immigrant status (which do not lead to citizenship) if you invest approx. US$ 200,000 in a non-revocable fixed-term deposit for 5 years with the National Bank of Panama. Under this category, residents acquire the right to obtain a Panamanian (non-citizens) passport. However, this is only of limited use. Please click here for more information.

Poland

Poland joined the European Union in May 2004. Many of its former citizens did not return to their homeland after the end of the Second World War and their descendants acquired the citizenship of the countries in which they were born. However, an individual has an entitlement to Polish citizenship if his or her ancestors were Polish and did not acquire another citizenship voluntarily. Please enquire for further information and advice.

St. Kitts and Nevis

The Citizenship-by-Investment program of St. Christopher (St. Kitts) and Nevis was established in 1984. It is the oldest such program in existence. Benefits include a Commonwealth passport which allows visa-free travel to over 60 countries. To qualify for citizenship, the Government requires either an investment in designated real estate to a value of at least US$ 350,000, or a contribution to the Sugar Industry Diversification Foundation (a public charity) of at least US$ 200,000 (for a single applicant, but this includes all Government fees). The SIDF option is clearly the best Citizenship-by-Investment program available today. Please click here for more information.

Serbia

The Republic of Serbia makes provision in its Citizenship Law for the acquisition of citizenship based on proof of Serb origin, through documentary evidence of ancestry or ethnicity, without any prior residence requirement. This provision extends to the diaspora of ethnic Serbs overseas. Although Serbia is not a member of the EU, its citizens benefit from visa-free travel to several European countries including Greece. Please enquire for further information and advice.

Singapore

A person can apply for registration as a Singaporean citizen if he or she has been a Permanent Resident for at least 2 years. In exceptional cases, applications may be considered after 1 year of residence. While the Singaporean passport is one of the best in the world in terms of reputation and visa-free travel, it does have significant drawbacks. In particular, the Enlistment Act stipulates that all male Singaporean Citizens (and Permanent Residents) are liable for military service upon reaching 16 years of age. Moreover, Singaporean citizenship legislation does not allow dual citizenship. Singapore is a strict single-citizenship country and will require proof of relinquishment of all other citizenships held by the applicant. Please contact us for more information and advice.

Slovakia

Slovakia, which has been a member of the EU since May 2004, normally requires eight years of residence on its national territory as well as knowledge of the Slovak language to qualify for citizenship. However, there is an exception from this rule in the case of persons with Slovak ancestry up to three generations back. Such persons can obtain Slovak expatriate status. This can be granted to applicants over 15 years of age who are not citizens of the Slovak Republic but can prove Slovak nationality, ethnic origin as well as cultural and linguistic awareness. Persons who have been granted Slovak expatriate status and have received a Slovak expatriate card may then apply for citizenship. In certain cases it is also possible to apply for Slovak citizenship under the Citizenship-by-Investment provisions, which are similar like the ones in Austria. This can be available within a shorter period of time, or even within approximately one year, for qualified individuals who contribute significantly and in an extraordinary manner to the country's interests. Henley & Partners handles citizenship-by-investment applications for qualified investors on a case-by-case basis. Please contact us for more information and professional advice.

Spain

In certain cases it is possible to acquire Spanish citizenship after only 2 years of legal residence, namely if you are a citizen of and were born in a former colony of Spain (this includes most Latin American countries and the Philippines) or if you are a Sephardic Jew. The normal period of time required before you may apply for citizenship is 10 years. Please enquire for further information and advice.

United Kingdom

Residence in the United Kingdom can often be established quite easily, for example if you have a British ancestor and if you are also a Commonwealth citizen, if you are willing to start a business or invest GBP 1 million in the UK. You may apply for British citizenship after 5 years of legal residence, although a substantial strictly physical presence during that period is required. Normally, to qualify for citizenship, you cannot have been away from the UK for more than 90 days on average in each year before your citizenship application. Please enquire for further information and advice.

United States of America

After 5 years of permanent residence, it is possible to acquire US citizenship and obtain a passport which not only confers the protection of what is still the most powerful country in the world but also its taxation status. The US Virgin Islands, a US territory in the Caribbean, may be attractive for wealthy individuals and families interested in US naturalization, or for current US citizens wishing to relocate to a warmer climate while legally reducing their tax liability under the protection of the American flag. Please enquire for further information and advice.