All EU member states have their own particular incentives to attract foreign investment from non-EU countries. Most are "golden passport" o "golden visa" processes, the most common names for the Citizenship by Investment and Residence by Investment (CBI and RBI) programmes.

These provide access to residency or citizenship in a country in exchange for the investment of a specific amount and a clearly defined process. CBI/RBI schemes vary greatly in terms of the requirements that are required and the rights that are granted, but they share common features.

Likewise, their challenges and the controversies they generate are similar.


Delimiting and classifying such schemes has required a systematic and cautious approach. In our case we consider one in particular.

For the purposes of the analysis, a specific methodology[1] has been used, which takes into consideration the following aspects:

  • Investment obligations: i.e. the levels of wealth and commitment to the member state that the scheme requires. One point is allocated to schemes that offer CBI/RBI in exchange for an active financial investment; two points to schemes that require an active or passive investment; three points to schemes that require only a high-level passive investment (over EUR 500,000) and four points for a low-level passive investment (under EUR 500,000).
  • Required physical presence in the territory: or the obligation for successful applicants to spend some time in the territory to maintain resident status. An extended residence requirement (more than six months) to maintain resident status is given one point; a presence of one to six months, two points; a light physical presence requirement (one day to one month), three points; and no physical presence requirement was given four points.

In addition, the following aspects were considered in assessing the advantages of the residency or citizenship process: 

  • Access to mobility: what access does EU status grant? Four points are awarded here for schemes granting citizenship; three for those granting a long-term residence permit in a Schengen member state (more than five years); two for those granting a temporary residence permit (five years) and one point for a residence permit granting access to a single EU (non-Schengen) state.
  • Access to a favourable tax regime: what are the tax incentives provided for in the statute? Here we assign four points to states that offer access to preferential tax regimes[2] that fully, or partially, exempt foreign income from taxation; three points to those that exempt low-tier personal income tax (between 10% and 19%), two points to mid-tier income tax (20-40%) and one to high-tier income tax (over 40%)[3].

Classifying the different CBIs and RBIs


Graph: CBI/RBI representing eligibility conditions as a function of rights granted. Source: EPRS | European Parliament Research Service

In the graph, the different CBIs/RBIs in the European Union are represented with the scores obtained.

In the upper right-hand corner are the most accessible programmes, which at the same time grant the most rights. Currently, these are Bulgaria, Cyprus, Estonia, Ireland, Italy, Latvia, Malta and Portugal.

The Estonian and Italian programmes are less frequently mentioned in specialised media, probably due to recent changes in their legal systems. On the other hand, subsequent research has identified the schemes in Austria, Belgium, Croatia, Greece, Spain, France, Hungary, Lithuania, the Netherlands, Romania and the United Kingdom as being of medium level.

The Spanish case

Although Spain is often presented as a typical 'Golden Visa' country, its RBI system only grants a relatively short stay permit compared to other countries: less than five years (after the initial authorisation, which is for two years in the case of investment residency). Moreover, such a permit does not necessarily grant access to a preferential tax regime.

Spain introduced an attractive tax regime in 2005 to attract highly skilled professionals, which exempts foreign income from taxation. But this initiative was not aimed at investors, but at highly skilled workers. It is known as the "Beckham Law", as the changes were introduced in 2015 after the regime was abused by footballers, including David Beckham.

Opting for this preferential tax regime is only possible for foreigners who come to work for a company located in Spain. Thus, the requirements to obtain this tax status are more oriented towards migrant workers and not towards investors seeking residence or citizenship. In any case, this regime is more restrictive than those in countries such as Portugal or Cyprus.


In recent years, and more so in recent months, news reports and/or new criminal investigations have shed light on dubious practices and scandals surrounding CBI/RBI schemes and have come to point out the vulnerabilities of these schemes. While criminal background checks are included in their legal framework, the accuracy of these is questionable. As questionable as some of the applicants and the source of funds invested by them.

In addition, the tax incentives offered by the CBI/RBI schemes are an important driver of demand. In this regard, schemes offering access to special tax regimes have been considered particularly risky[4]. Also, a driver of potential inequity in the EU.

Despite all this, the exchange of residence or citizenship for money has become normalised. Almost half of EU member states now use golden visa programmes with passive investors. The proliferation of these channels suggests that further progress is being made within the EU's neoliberal tendencies.

What is clear in 2021, however, is that migration policy can also be used to attract money rather than people. This is already an established way of diversifying strategies to boost the economy, using visa policies to attract investment, not just migrants.


  • [1] Parker O., 'Commercializing Citizenship in Crisis EU: The Case of Immigrant Investor Programmes', Journal of Common Market Studies, 55, 2, p.332-348, 2017; Džankić J., 'Immigrant investor programmes in the European Union (EU)', Journal of Contemporary European Studies, 26, 1, 2018, p.64-80. The underlying logic of the scale developed by Džankić is that under the lowest status obligation (1), the investor obtains citizenship almost directly; under the highest (5) the investor is bound to ordinary compulsory residence, which after several years could lead to citizenship.
  • [2] In countries that offer a "non-domiciled status", a person living in these countries may be considered resident for tax purposes but still have his or her domicile (i.e. permanent residence) in another country. This status allows a person not to pay tax on their foreign income and capital gains, unless the money is brought into the country of residence.
  • [3] Based mainly on Knobel A., Heitmüller F., Citizenship and Residency by Investment Schemes: Potential to avoid the Common Reporting Standard for Automatic Exchange of Information, March 2018.
  • [4] See, for example, in the Transparency International reports

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