# Appendix A — Rights and Limitations Matrix This appendix is the working form of the attribution discipline applied throughout the report: every right a client might expect from the reference structure is attributed to exactly one legal instrument, with the conditions that qualify it kept attached to it. It introduces no new material. Table A.1 extends the summary matrix at §4.9 and the consolidated matrix at §19.1 across the rights clients most often assume they are acquiring; §A.2 explains how the cells are to be read; §A.3 lists the rights the structure does not provide at all, each with its legal reason. Every cell carries the section of the body from which it derives, so that any line can be tested against the underlying analysis. Where the body states that a position requires confirmation at the date of application, the cell says so and does not resolve it. ## A.1 The master matrix | Right or capacity | Citizenship component — São Tomé and Príncipe | Residence component — Greek investor residence permit (type «Β.5») | Property component — ownership of the qualifying Greek property | Optional layer — company | |---|---|---|---|---| | Reside in Greece | **NO** — São Toméan nationality (Decree-Law 07/2025, implementing Lei 7/2022, Art. 10(2)) operates in São Toméan law and confers no status in Greek or EU law (§4.2, §19.2) | **YES** — Article 100, Law 5038/2023, as amended by Article 64, Law 5100/2024: lawful residence for five years, renewable for equal periods while full ownership and possession of the qualifying property continue; no physical-presence condition (Art. 100 §4) (§4.3, §7.4, §19.3) | **NO** — ownership is a property right acquired by notarial deed and registration; it is a qualifying condition of the permit, not a residence right (§4.5, §19.5) | **NO** — a company is a separate legal person and confers no personal status on its owner (§4.7, §19.6) | | Reside elsewhere in the EU | **NO** — no EU status arises from a third-country nationality (§4.2, §19.8) | **NO** — CISA Article 21 confers short-stay presence only; long-term resident status under Directive 2003/109/EC arises only after five years of legal and continuous residence and subject to further conditions, and is not conferred by the permit (§4.3, §4.4, §19.8) | **NO** — ownership confers no immigration status in any member state (§4.5) | **NO** — owning a Greek, Cypriot or other EU company gives no right to reside in the Union (§4.7) | | Work as an employee in Greece | **NO** — nationality of a third state confers no labour-market access in a member state (§4.2) | **NO** — Article 100 §9, Law 5038/2023: the permit does not establish a right of access to any form of employment; employment requires a separate title (§4.3, §19.1, §19.8) | **NO** — ownership carries no employment right (§4.5) | **NO** — company ownership is not a labour-market right (§19.1) | | Work elsewhere in the EU | **NO** — Regulation (EU) 2018/1806 governs entry only; no work right attaches to any third-country passport (§4.4) | **NO** — Article 21 CISA gives short-stay presence and nothing else; Directive 2004/38/EC applies to Union citizens who move between member states and their family members, not to third-country nationals in their own right (§4.4, §19.8) | **NO** (§4.5) | **NO** (§4.7, §19.6) | | Operate a business or hold shares | **NO** — in Greece or the Union; nationality of São Tomé and Príncipe confers no establishment right in a member state (§4.2) | **QUALIFIED** — the employment exclusion of Article 100 §9 stands; whether shareholder or board-member activity is permitted as a statutory carve-out is not established and requires confirmation at the date of application (§7.11, §19.1) | **NO** — and in the change-of-use category the property may not be used as the seat or branch of a business (Article 100, Law 5038/2023) (§4.5, §19.5) | **QUALIFIED** — a company may be established and shares held as a vehicle for holding, letting, administration or succession, assessed on its own merits; it confers no residence, tax or banking status (§4.7, §9.2, §19.6) | | Short-stay travel in the Schengen Area | **NO** — São Tomé and Príncipe is listed in Annex I of Regulation (EU) 2018/1806, whose Article 3(1) requires a visa to cross the external borders (§4.4, §19.4) | **YES** — CISA Article 21(1), as replaced by Regulation (EU) No 265/2010 and amended by Regulation (EU) No 610/2013: up to 90 days in any 180-day period on the permit and a valid travel document, subject to the entry conditions of Article 6(1)(a), (c) and (e) of Regulation (EU) 2016/399 and to absence from the national alert list; days spent in Greece under the permit do not consume the allowance; travel should be planned on the passport whose identity data, including nationality, match the permit (§4.4, §7.10, §19.4) | **NO** (§4.5) | **NO** (§4.7) | | Visa-free travel on the second passport | **QUALIFIED** — visa-free access to a limited number of states; verified examples are South Africa (90 days), Singapore and Hong Kong (14 days); no official aggregate count of the passport's travel access is published, and the position of individual states may change (§6.9, §19.1, §19.2) | Not applicable — the permit is not a travel document (§19.1) | **NO** (§4.5) | **NO** (§4.7) | | Enter the United Kingdom or the United States visa-free | **NO** — São Tomé and Príncipe appears on the United Kingdom's Immigration Rules Appendix Visitor visa national list (item 85), and is not a country designated under the United States Visa Waiver Programme (§6.9, §19.1) | **NO** — the Article 21 CISA right operates only among the member states and has no effect on admission to the United Kingdom or the United States (§4.4) | **NO** (§4.5) | **NO** (§4.7) | | Vote or stand for public office | **QUALIFIED — not verified in this report** — a matter of São Toméan constitutional and electoral law; requires confirmation at the date of application (§19.1) | **NO** — the permit confers no political rights at any level (§4.3, §19.1) | **NO** (§4.5) | **NO** (§4.7) | | Hold and let property in Greece | No bearing — ownership is acquired under Greek property law, not through nationality (§19.1) | **QUALIFIED** — the permit is conditioned on ownership and does not create it; long-term letting is expressly permitted (Article 100 §7) while short-term letting and sub-letting are prohibited for this category (Article 100 §7A), breach carrying revocation of the permit and a standalone €50,000 administrative fine; sale during the permit's validity revokes the seller's permit (§7.12, §7.14, §19.5) | **YES** — full ownership and possession (πλήρης κυριότητα και νομή) of one property with a minimum acquisition value of €250,000; the change of use of the main spaces must have been completed after 5 April 2024 and before the application, per the official administrative record for the category (§7.4, §7.6, §19.5) | **QUALIFIED** — where the property is acquired through a Greek or EU entity, evidence of 100% ownership forms part of the residence file (JMD 214926/2025, Article 2 §2.6); the property may not be the entity's seat or branch (§19.5, §19.6) | | Transmit status to children | **QUALIFIED** — a child born abroad after the parent's naturalisation is a national of origin only upon a declaration of the wish to be São Toméan and registration (Lei 7/2022, Arts. 5 and 21); the parent must still hold São Toméan nationality at the child's birth, and acquisition of a fourth nationality causes immediate loss (Art. 11(1)–(2)); no registry practice yet exists for a programme one year old — confirmation at the date of application (§6.10, §19.2) | **NO** — family members hold derived family-reunification permits (title O.1) that expire simultaneously with the sponsor's; a child reaching 21 receives an independent three-year permit (title O.2) (§7.9, §19.3) | **QUALIFIED** — the asset is heritable, subject to Greek inheritance tax on Greek-situs property regardless of the nationality or residence of deceased and heir (Law 2961/2001, Art. 3) (§4.5, §9.10) | **QUALIFIED** — shares pass by succession under the applicable succession law (§19.1) | | Transmit status to a spouse | **QUALIFIED** — the spouse may be included under Articles 10(4)–(5) of Lei 7/2022; the spouse limb requires cumulatively marriage of more than five years and the regime of community of acquired property (*comunhão de bens adquiridos*), or a court-recognised de facto union of more than three years, and post-approval addition is separately charged under Anexo I of Decree-Law 07/2025 (§6.3, §11.9, §19.1) | **QUALIFIED** — the spouse or cohabitation-agreement partner is included under Article 95 §2, Law 5038/2023, on a family-reunification permit that expires simultaneously with the sponsor's (§7.9, §19.3) | **QUALIFIED** — the asset passes by succession, subject to Greek inheritance tax on Greek-situs property (§4.5, §9.10) | **QUALIFIED** — shares pass by succession (§19.1) | | Access public healthcare and education | **NO** — no bearing in Greece or any member state (§4.2) | **QUALIFIED** — Article 8(ε), Law 5038/2023 makes full sickness insurance a condition of the title; because the permit carries no labour-market access, cover is evidenced by a private insurance policy at issuance and at each renewal, the coverage minimums having been fixed under the predecessor Code (KYA οικ. 53821/2014) and still applied in practice, subject to confirmation at the date of application. Access to the Greek public health and education systems is not established in this report and requires confirmation at the date of application (§7.7, §19.9) | **NO** (§4.5) | **NO** (§4.7) | | Establish tax residence | **NO** — citizenship is tax-inert; São Toméan personal taxation is reported to be residence-based, with no taxation by reason of citizenship alone, and this requires confirmation at the date of application (§4.6, §19.7) | **NO** — immigration residence is not tax residence, and the permit imposes no presence at all; Greek tax residence arises, as reported under Article 4, Law 4172/2013, on presence exceeding 183 days cumulatively in any twelve-month period or where Greece is the permanent or main residence, habitual abode or centre of vital interests, and the elective regimes apply only where the client separately qualifies (§4.6, §9.12, §19.7) | **NO** — ownership creates Greek obligations attached to the asset (holding taxes, tax on rental income, inheritance tax on Greek-situs property) without creating tax residence or any non-dom status (§4.5, §8.12, §9.10) | **NO** — no company makes its shareholder tax resident in the company's jurisdiction; conversely, a company managed from Greece may itself become Greek tax resident on place of effective management (Article 4, Law 4172/2013), and home-country attribution rules may tax its income in the owner's hands (§4.7, §9.14, §19.7) | | Obtain a bank account | **NO right to an account** — a second nationality does not create banking access, and from 10 July 2027 Article 22(1)(a) of Regulation (EU) 2024/1624 requires the collection of all nationalities held (§6.11, §4.9) | **QUALIFIED** — no right to an account with any chosen institution; legal residence in the Union engages the basic-payment-account framework of Article 16(2), Directive 2014/92/EU, subject to its conditions (§9.4, §19.6) | **NO** — a Greek tax number is a practical precondition of purchase, but no account right follows from ownership (§8.12, §9.4) | **NO** — a corporate application is a compliance decision of the institution; under Article 13, Law 4557/2018 an institution that cannot complete customer due diligence must decline or terminate the relationship (§9.5, §19.6) | | Naturalise in Greece | **NO** — Greek naturalisation runs on residence titles, not on the applicant's other nationality (§7.13, §19.7) | **QUALIFIED** — under the official administrative record for naturalisation (last updated 30 July 2026) the investor permanent residence permit sits on the seven-year residence track, but the citizenship examination, evidenced economic and social integration and Greek tax returns for the residence years presuppose an actual life in Greece; naturalisation remains a discretionary state decision and there is no investor fast-track in Greek law (§4.8, §7.13, §19.7) | **NO** (§4.5) | **NO** (§4.7) | | EU citizenship | **NO** (§2.4, §19.8) | **NO** (§4.3, §19.8) | **NO** (§4.5) | **NO** (§4.7) — no component of the structure is capable of conferring the nationality of a member state, and transactional investor citizenship in the Union has ended (Court of Justice of the European Union, *Commission v Malta*, C-181/23, 29 April 2025) (§2.4, §4.1, §19.8) | Table A.1 — Rights and limitations by instrument. Assumptions: a single main applicant who is a third-country national of a state listed in Annex I of Regulation (EU) 2018/1806, not resident in the European Union and not relocating; the residence component obtained under the €250,000 change-of-use category of Article 100 §2(γ) of Law 5038/2023 as amended by Article 64 of Law 5100/2024; the property held in the client's own name; the company layer optional and established, where at all, for holding, letting, administration or succession purposes; status stated as at 2 August 2026. No cell is cumulative across columns, and every affirmative cell is subject to the conditions of the instrument named in it. Greek tax propositions are stated from convergent professional summaries pending confirmation against the gazetted text (§4.6). The table contains no computed figures; the statutory amounts it repeats (€250,000, €50,000) appear unchanged from Chapters 7 and 10. Derived from §4.9 and §19.1, and from §§4.2–4.8, 6.3, 6.9–6.11, 7.4–7.14, 9.2–9.16, 12.3, 17.11 and 19.2–19.9. ## A.2 How to read this matrix 1. **Read down a row, not across it.** Each right is created by one instrument. Holding all four columns at once merges nothing: each instrument keeps its own authority, conditions and failure modes (§5.7, §19.1). 2. **YES means a right exists under the instrument named, on that instrument's conditions.** The conditions are part of the cell, not a qualification bolted on to it. Where the condition fails, the right fails with it — most visibly in the property row, where sale during the permit's validity revokes the permit (§7.12, §19.5). 3. **QUALIFIED means one of two things:** either the right exists only on stated conditions or where the client separately qualifies, or the position is not established at the date of this report. The two are distinguished in the cell wording. 4. **Statements requiring confirmation are carried, not resolved.** The report states uncertainty rather than closing it. The confirmation points visible in Table A.1 are: the political rights of naturalised São Toméan citizens; whether shareholder or board-member activity is permitted alongside the Article 100 §9 employment exclusion; access to the Greek public health and education systems; the insurance coverage minimums fixed under the predecessor Code; whether Greece re-keys a permit to a newly acquired second nationality while the original subsists (§4.4, §19.4); the Greek tax propositions, taken from professional summaries pending gazette confirmation (§4.6); the reported residence basis of São Toméan personal taxation (§4.6); registry practice on transmission declarations, for which no practice can yet exist (§6.10); and the visa position of individual destination states, which is amended from time to time. 5. **The mobility row contains exactly one affirmative cell.** Short-stay Schengen mobility arises from the Greek residence permit under Article 21 CISA and from nothing else; it is not conferred by the São Tomé passport, which is that of an Annex I state (§4.4, §19.4). The Entry/Exit System and, when it enters operation, ETIAS do not apply to residence-permit holders — a documented administrative convenience of the permit, not a right of free movement (§19.4). 6. **The matrix is a checking instrument, not advice.** It states general legal positions as at 2 August 2026 for the reference structure; it is not legal, tax, immigration or investment advice to any person, and each position must be confirmed by regulated professionals in the relevant jurisdiction at the date of application (Foreword; Appendix O; §18.9). ## A.3 Rights the structure does not provide at all These are set out in full at §19.8. Each is given here with the legal reason for it, because the reasons are the point. - **EU citizenship and an EU passport** — transactional investor citizenship in the European Union has ended, and neither component is capable of conferring the nationality of a member state (§2.4, §19.8). - **Immediate Greek citizenship** — naturalisation runs on the 3/7/12-year residence structure with examination, integration and tax-return requirements; the investor permit sits on the seven-year list and confers no fast-track (§7.13, §19.8). - **Unrestricted residence throughout the European Union** — Article 21 CISA gives short stays only, and Directive 2004/38/EC applies to Union citizens and their family members, not to third-country nationals in their own right (§4.4, §19.8). - **Unrestricted employment** — Article 100 §9 of Law 5038/2023 states expressly that the permit does not establish a right of access to any form of employment (§4.3, §19.8). - **Visa-free Schengen entry from the second passport** — São Tomé and Príncipe is listed in Annex I of Regulation (EU) 2018/1806, whose Article 3(1) requires a visa for crossing the external borders (§4.4, §19.8). - **Automatic tax residence or non-dom status** — no immigration instrument in the structure imposes presence, and tax residence is a matter of each jurisdiction's own domestic law (§4.6, §19.7). - **Bank-account opening as an entitlement** — account opening is an institutional credit and compliance decision, and an institution that cannot complete customer due diligence must decline (§9.5, §19.8). - **Approval of the citizenship or residence application as an entitlement** — both are government decisions taken after due diligence on statutory grounds that include refusal; the São Toméan file additionally requires the Public Prosecutor's prior visto, and refusal causes the process to lapse (§18.9, §19.8). - **Rental income, appreciation or resale liquidity** — these are market outcomes rather than legal entitlements, and the letting restrictions in Table A.1 narrow the tenant pool (§12.3, §12.10, §19.8). - **Protection from future legislative or policy change** — both programmes rest on instruments their legislatures and ministers may amend; the São Toméan fee schedule is alterable by joint order, though an update does not affect processes already admitted (Decree-Law 07/2025, Art. 22), and the Greek thresholds have been amended since 2013 (§7.14, §14.1, §19.8).