Category: golden visa

Italy’s September Amendments to “La Dolce Visa” Finally Makes it a “Real Golden Visa”

When first announced in 2017 (and formally opened in 2018), Italy’s investor visa didn’t turn as many heads as the government had expected. In a December 2019 analysis of the program, we explained why:

The investment requirements are the chief cause of [the program’s lack of success].

The IIV offers four routes of investment, which are:

    • A €500,000 investment in an Italian “innovative startup”
    • A €1,000,000 investment in an Italian limited company
    • A €1,000,000 investment in a philanthropic initiative
    • A €2,000,000 investment in Italian government bonds

What instantly catches the eye of any potential investor or RCBI agent is that the capital required – for a temporary residency permit, mind you – is out of tact with the rest of Europe’s programs. 

Of the four options Italy offers, we can only classify one – government bonds – as low-risk. And even that is not obvious in 2019. The remaining three are all high-risk options.

In brief, higher prices and higher risk were to blame.

Then, this spring, at the height of the first Italian COVID-wave, the government made drastic changes to the program as part of the broader “Decreto Rilancio” (the Revival Decree), a set of legal amendments aiming to quickly bolster investment and job creation in Italy to help the economy recover from the pandemic.

The investment requirements for the program’s first two options were halved to EUR 250,000 and EUR 500,000, respectively. At the time, IMI described the changes as important but not sufficient to make the program a serious contender to Greece, Portugal, and Spain.

While a halving of investment requirements will certainly improve the program’s prospects, the scheme’s most significant obstacle is that only one of its four routes – that of government bonds, which requires virtually the same capital outlay as the direct route to EU citizenship in Cyprus, which would enable investors to reside in Italy in any case – is considered “low-risk”. Italy offers no real estate investment option.

Italy still offers no real estate option, but the latest round of amendments, first announced in September, included two crucial changes that will certainly bolster the program’s appeal:

“The Semplificazioni decree, of December,” explains Marco Bersani, founder of Bersani & Partners International Law, “exempted golden visa investors from the physical presence requirements until now imposed on holders of all categories of Italian residency visas.” Those rules, in effect, had obliged golden visa investors to physically remain in Italy for most of the year, a rarely-discussed but clear disadvantage in the golden visa market.

“This is a general rule applicable to all residence permits that states that the resident cannot stay outside of Italy for more than a half of the total duration of the permit,” clarifies Bersani. “So, for example, if you had a two-year permit [the initial duration for golden visa holders], you could not spend more than one year outside of Italy (except if you could prove you had valid reasons). That general rule, though still applicable for all other residence categories, no longer applies to golden visa investors.”

In effect, the change has reduced the physical presence day-count requirement for Italy’s investor visa to zero. The change has moved the Dolce Visa from a position of clear disadvantage compared to its competitors to having the most lax physical presence requirement among all EU golden visas.

Apply and invest through a company
The second impactful change introduced in September has to do with what juridical person makes the investment. Individuals can now apply and make qualifying investments through their companies, thereby significantly reducing the financial risk of private individuals.

“The applicant,” points out Bersani, “can be a physical person (the norm among golden visas) or, alternatively, the CEO/Legal Representative of a foreign company. This allows, technically, for the investment to be made through the applicant’s company.

Bersani highlights two additional competitive advantages for Italy.

Application-related risk to the principal investment, he illustrates, is effectively absent in Italy because, unlike in many other programs, the government does not ask for the investment to be concluded until after the visa has been approved. In other words, there is no risk of investing in vain.

For those willing to become tax residents in Italy, Bersani adds, the new EUR 100,000 flat tax on global earnings regime also offers considerable advantages to high-income individuals. Though this is a clear advantage over Spain’s golden visa, both Portugal (through the Non-Habitual Resident regime) and Greece (lump-sum tax offers for as little as EUR 25,000 a year) can boast of similar advantages.

One disadvantage that remains for the Italian program is that all Italian residence visas require that the applicant maintain a home in Italy.

“The law requires that the applicant have a ‘suitable’ house in proportion to the amount of people who will live there. So, for example, if you have declared to the consulate that you will be bringing four family members and your rental agreement shows you will be living in a studio apartment, that won’t be accepted.”

On the whole, however, the Italian Dolce Visa has come a long way in the short time since it was first introduced, and the government has consistently demonstrated a willingness to enhance it.

“In conclusion,” says Bersani, “the Italian program has evolved enormously since the beginning and is now ‘a real golden visa’.”

More From Europe

No more physical presence requirements and the possibility to apply and invest through a company rather than as an individual.

Turkish CBI providers report sharply increased demand from both remote and touring clients, which they expect to continue throughout 2021.

Presuming the COVID flare-up is the primary cause of the slowdown, golden visa investment volumes are unlikely to recover before 2021.


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4 Ways RCBI Agents Can Ensure a Smooth Due Diligence Process for Their Clients


Barely a day passes without some kind of scandal connected to the Citizenship by Investment (CBI) industry. Inevitably, a few bad apples ruin it, not only for people applying but also for the countries where this industry provides much-needed income and investment. However, the Caribbean nations of note, particularly Grenada, have worked and are working hard to correct this image. 

Having been in the CBI business for a number of years, we have inevitably drawn lessons from our own experiences, but the best lessons learned can surely come from others?

Every applicant is different and none are wholly without risk. The key factor in making a fair assessment is to understand the real and potential risks to an applicant and to identify any mitigating action that could be undertaken to lower those risks.  This makes the due diligence process not only more comprehensive but also more open and transparent. In turn, this allows the countries offering citizenship programmes the flexibility to confidently say yes to more applicants, whilst also ensuring any unsuitable applicants are weeded out and robustly rejected. 

This article aims to be a helpful insight into the world of due diligence and what you can do to help your applicants move smoothly through the process. 

Due diligence can be costly and time-consuming; governments, banking institutions, and good due diligence providers reiterate that it is crucial to identify genuine applicants with legitimate funding behind them.  

Don’t pretend you know how long due diligence will take
The applican’ts jurisdiction will affect this. Having a fixed timescale for the turnaround of due diligence is sometimes unhelpful, and experience tells us that a guideline timespan may be more useful. There are some jurisdictions that turn enquiries around very quickly and, for the more straightforward applicants, a lower turnaround date can be very effective. The more complex cases and/or jurisdictions may require a slightly longer timeframe. That does not necessarily mean that these applicants are problematic or are associated with red flags, but they may have multiple companies spanning many jurisdictions (legitimately) and, in order for due diligence process to take place, a little more time is necessary. 

Agents: Spend a little more time upfront to save a lot of time later
A lot of time can be saved if the agents can take a little more time and provide a little more advice to applicants. Often, applications can come through with key documents missing; if there is a valid reason for the non-availability of such documents, provide a reason. This is will save the provider/client/agent the back and forth communication requesting these missing documents and, ultimately, holding up the application.  

Corporates: Declare even minor holdings
Often, undeclared business affiliations are revealed for applicants, raising red flags where they do not need to be raised. If an applicant has business affiliations with small shareholdings, they could provide a statement within their application saying that they have x number of additional business affiliations with less than 50% shareholding. This caveat would again save the provider raising red flags under lack of transparency which, again, would save time. 

Five questions that will save you a headache
Another commonality surrounds the financial viability of the applicant.  The crux of understanding an applicant is to understand their financial means and the rules for investment within each programme.  

For example, key questions the agent can ask the applicant are:

  1. Where are the funds coming from? 
  2. Is the source of funds commensurate with the applicant’s lifestyle/earnings?
  3. Has the source of funds been evidenced?
  4. Six months of personal banking statements are a requirement – are these complete and present? Are there any significant credits featured that are not traceable?
  5. Does the applicant have a salary? If so, this needs to be evidenced. 

These basic know your customer (KYC) elements are all factors that due diligence providers will look through and, if any of these are missing, red flags may be raised. Other factors looked at from an anti-money laundering (AML) perspective will be to note if there are any unexplained significant deposits and whether the account has been inflated for the purposes of the application.

Most crucially, it should be remembered that agents have the power to reject applicants before they go through this costly and time-intensive scrutiny. 

Finally, we are wise to the practice of ‘fronting’ of the main applicant the spouse who has little involvement in the investments and finances in order to avoid scrutiny. This is a common practice and just delays applications. It may even get the applicant awarded a red flag. Our advice is to be open and transparent, avoiding these types of shortcuts. 

Working together, we can ensure the correct applicants are encouraged to apply, maintain the integrity of the programmes and, ultimately, protect the future of citizenship and residency by investment.  

More Opinion

Martin Dubbey, a globally recognized due diligence provider to RCBI programs, shares four strategies to help RCBI agents with vetting.

Roderick Cutajar asks: International banks are used for money laundering. Will the European Commission demand a “phase-out” of banking?

“Since the start of our fiscal year – April 1st, 2020 – we have already recorded 154 applications received,” writes CIU-boss Nestor Alfred.


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After Raising AED100 Billion in 1st Year, UAE Extends “Golden Visa” to Doctors, Computer Scientists

The UAE’s introduction of a 10-year “golden visa” to investors, entrepreneurs, and company owners last year was reportedly an instant success: Sheikh Mohammed announced yesterday that “6,800 investors and residents, worth an estimated Dh100 billion, and from 70 countries, were chosen to receive the visa,” according to The National.

Initially, the visa was made available to foreigners who deposited at least AED10 million in a UAE-based investment fund, owned at least AED 10 million in shares of a local company, and entrepreneurs whose ventures were in a “certified field” and were valued at a minimum of AED 500,000.

The visa was also open to executives who received a minimum monthly remuneration of AED 30,000, as well as outstanding scientists and students.

Now, the UAE government is extending the welcome under the golden visa to all doctors, computer engineers, and a wide range of scientists as well, no longer requiring the highly skilled to be “exceptional”.

Though the program expansion was announced yesterday, it will not take effect until in December.

The UAE is not alone in its region in offering long-term visas to skilled professionals. Last year, Saudi Arabia also introduced a “golden visa”, starting at €187,000 for permanent residency and with one-year renewable residencies are available from €23,000. A similar but more limited scheme also exists in Qatar.

More Policy Updates

The UAE government is extending the welcome under the golden visa to all doctors and a wide range of engineers and scientists.

Starting tomorrow, children born to a foreign parent who has lived in Portugal for a year will be eligible for citizenship at birth.

The Kittitian policy, however, differs from those of other regional CIPs in certain key respects, notably on age requirements.


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