# Appendix C — Single-Applicant Cost Model This appendix reproduces, in working form, the bottom-up cost model built in Chapter 10 for the report's illustrative single-applicant reference case of approximately €375,000 — a planning reference the model re-footed here exceeds in every column, including the lean one (C.7, C.8). It adds nothing to that chapter: every line, band and total below is drawn from the section cited in the right-hand column, and where a chapter qualifies a figure as reported, illustrative or requiring confirmation at the date of application, that qualification applies here too. The model is used by working down the six groups in order, replacing each banded line with a written quotation and each government charge with the schedule in force on the day of application, then re-footing the totals. It is not a quotation, a fixed price or a maximum, and it cannot become a client cost model without the selected property, the exact family composition and the current schedules of both jurisdictions (§1.5, §10.15, §17.9). **How to read the groups.** The model contains two kinds of money and they should never be added together as though they were one price (§10.1). Group 5 is **Kestrel Private's professional engagement fees** — the firm's own charges, each fixed and agreed in writing before work begins, and each charged per application. The firm charges that fee on the two programme applications only — the São Tomé and Príncipe citizenship application and the Greek investor residence application — so Group 5 carries two fee lines. A client instructing one programme alone pays one fee. Two is also the maximum: the optional company, banking and tax layer carries no Kestrel Private fee at all, its cost being entirely third-party, so the model contains two fees in total and never three (§10.11, §10.12). Groups 1 to 4, and every recurring line in §C.10, are **disbursements**: amounts payable to a government, tax authority, notary, land registry, admitted counsel, technical adviser, translator, insurer, bank or other provider, each in the amount that party charges, each paid by the client to that party. A disbursement is not part of the firm's fee, and the fee neither rises nor falls with it. Group 1 is different again: it is neither fee nor disbursement but the client's own capital applied to an asset they continue to own, retained at risk (§12.1–§12.3). On the reference case that means two fee lines totalling €18,000, roughly €107,000 of disbursements and investment-related charges, and €250,000 that remains the client's property. Any presentation that merges the three misdescribes the position. ## C.1 Group 1 — Capital applied to the property | Cost line | Amount or band | Basis | Section | | --- | ---: | --- | --- | | Qualifying Greek property, one property at the statutory minimum for the change-of-use category | €250,000 | Government schedule — statutory minimum acquisition value (Law 5038/2023, Article 100, as amended by Law 5100/2024, Article 64) | §10.5 | *Single applicant; one property in full ownership and possession, acquisition value at the statutory floor at the time of purchase. The €250,000 is a floor, not a market price: every percentage-based line in Groups 3 and 4 scales with the price actually paid. Whether a property priced at the floor is worth its price is a separate question from whether it qualifies (§8.3, §10.5). This line is retained capital rather than expenditure, but retained at risk — see §12.1–§12.3.* ## C.2 Group 2 — Contribution and programme fees | Cost line | Amount or band | Basis | Section | | --- | ---: | --- | --- | | São Tomé and Príncipe contribution to the National Transformation Fund, single applicant — US$90,000 | €78,261 | Government schedule — Decree-Law No. 07/2025, Anexo I; payable only after approval, within 90 days, and non-refundable once made | §10.3 | | Due-diligence and processing fee, per application — US$5,000 | €4,348 | Government schedule — Decree-Law No. 07/2025, Anexo I; non-refundable once the application is submitted | §10.4 | | **Subtotal, gazetted citizenship charges** | **€82,609** | — | §10.3–§10.4 | | Post-approval citizenship documents (certificate of registration, passport, national identity card), aggregate per applicant — US$750 | ≈€652 | Official programme-site schedule on the government domain cip.gov.st, read 4 August 2026; not in the gazetted Anexo I; requires confirmation at the date of application; sits outside the known base and inside the allowance | §10.4 | | Licensed submitting agent's retainer allowance — US$5,000 | €4,348 | Allowance carried in Kestrel Private's own cost model: not published, not gazetted and not sourced to any instrument. A São Tomé and Príncipe application must be filed through the programme's designated application channel by a licensed agent, and the retainer that agent charges requires a written quotation before engagement and confirmation at the date of application. Sits outside the known base and inside the allowance | §10.4, §10.14 | *Single applicant; conversions at the report's planning assumption of €1 = US$1.15 (§10.2), which is a planning assumption and not a rate any client will obtain. It is set below the prevailing market rate: the European Central Bank's euro foreign exchange reference rate (EUR/USD, daily series) was US$1.1535 on 3 August 2026, so the planning assumption is about 0.3% below that reference point, the euro figures in this group are overstated by about 0.3%, and the allowance at C.6 to C.8 is correspondingly understated by about €250 (§10.2). The dollar figures govern; the euro figures are illustrative conversions only. The responsible ministers may alter the Anexo I amounts by joint order, an update not affecting processes already admitted, so the schedule current at the date of application must be confirmed (§10.3, §14.2). Whether the due-diligence report required by Anexo III is covered by the US$5,000 fee or charged separately is not stated in the decree and requires confirmation (§10.4). The domestic passport schedule published by the Migration and Frontiers Service is a different charge and must not be conflated with the programme fee (§10.4). Subtotal foots: €78,261 + €4,348 = €82,609.* *On the submitting agent's line. An application to the São Tomé and Príncipe programme cannot be filed directly: it is filed through the programme's designated application channel by a licensed agent, whose retainer the client bears in addition to the government charges above. The model carries that retainer as an allowance of US$5,000 — €4,348 at the planning assumption of €1 = US$1.15 — held in Kestrel Private's own cost model. It is not published, it is not gazetted and it is not sourced to any instrument read for this report, and it requires a written quotation before engagement and confirmation at the date of application; the retainer actually charged may differ from the allowance in either direction. Being dollar-denominated, it moves with the other dollar lines in this group rather than against them. It sits outside the known base and inside the allowance, and is carried in all three columns at C.7.* ## C.3 Group 3 — Government fees and taxes on acquisition | Cost line | Amount or band | Basis | Section | | --- | ---: | --- | --- | | Real-estate transfer tax (FMA) at an effective 3.09% of taxable value — a 3% main rate plus a municipal element of 3% of the tax (€7,500 at the main rate alone) | €7,725 | Main rate confirmed against Α.Ν. 1521/1950, Article 4 §1; the municipal element is reported and its instrument is not pinned, so the effective rate is reported, not verified. Base is the higher of contract price and objective value; buyer liable; paid before the deed | §10.6 | | VAT at 24% in the alternative, where the transfer falls within VAT scope | not modelled | Property-specific classification; the reference acquisition is expected to bear FMA, confirmed by lawyer and notary before signing; no continuation of the VAT suspension beyond 31 December 2026 can be assumed as at 2 August 2026 | §10.6, §10.15 | | Land registry / cadastre registration, ≈0.5% of taxable value plus fixed charges | ≈€1,250, plus unquantified fixed charges | Schedule-based; reported tier. The percentage element only: no source read for this report quantifies the fixed charges the same schedule adds, so this line — and every total built on it — is a floor (§10.15) | §10.6 | | Greek investor permit fee (παράβολο), type B.5, on issuance and again on each five-year renewal | €2,000 | Government schedule — Law 5038/2023, Article 171 | §10.7 | | Electronic residence card production charge | €16 | Government schedule — official administrative record (initial-issuance file priced at €2,016) | §10.7 | | Optional national D-visa entry route, consular fee | €180 | Government schedule — Joint Ministerial Decision 214926/2025 (Government Gazette B′ 6014/11.11.2025), which sets the national-visa consular fee; arises only where that entry route is used | §10.7 | *Single applicant; €250,000 price with taxable value assumed equal to price; €1 = US$1.15 where conversions arise (§10.2). FMA is modelled at the effective 3.09% so that the model does not understate a cost the client will be asked to pay; the 3% main rate is confirmed against the gazetted instrument, the municipal element is not, and if the burden is 3% alone this line is €7,500 and every total built on it falls by €225 (§10.6). Greek fiscal figures otherwise rest on convergent professional sources with the governing instrument identified, and are reported figures subject to confirmation at the date of application (§10.1, §10.6). If the objective value of the selected property exceeds the price, the FMA, notarial and registry bases rise with it (§10.15). No biometrics charge appears in the instruments read; the applicant must nonetheless enter Greece once within an exclusive twelve-month period to give biometrics, and the associated travel is a real personal cost not banded here (§10.7). Minors are exempt from permit fees; family-member fees and totals are modelled in Chapter 11 (§10.7, §11.8).* ## C.4 Group 4 — Professional and administrative costs | Cost line | Amount or band | Basis | Section | | --- | ---: | --- | --- | | Notary, 0.8%–1.2% of the higher of price and objective value, plus 24% VAT | €2,480–€3,720 | Statutory sliding scale, professionally charged; reported tier | §10.6 | | Greek conveyancing counsel, ≈1%–2% plus 24% VAT | €3,100–€6,200 | Quotable; market-set, scope-dependent | §10.8 | | Greek residence filing, where contracted separately from the conveyance | €2,000–€3,500 per investor | Quotable; single published firm schedule, a reported anchor and not a market tariff. May be contracted within the conveyancing retainer | §10.8 | | Buyer's estate agent, where instructed, 2%–4% plus 24% VAT | €0–€12,400 | Quotable; arises only where the buyer instructs an agent — each party customarily pays its own agent, and a direct or developer purchase may involve none | §10.6 | | Technical and engineering due diligence on a conversion property | €300–€1,500 | Estimate — this report's reasoned analysis in a market with no published tariff; never a market rate; written quotations required in every case | §10.8 | | Electronic Building Identity issue, indicative for an apartment (customarily seller-side) | €120–€250 | Estimate; indicative published figure | §10.8 | | Citizenship-side legal and professional work (file preparation, source-of-funds documentation, applicant-specific legal explanation) | no citable band | Quotable only; a real line the allowance must absorb | §10.8, §10.14 | | Certified translation into Greek | €15–€60 per page plus VAT | Quotable; published provider rates, reported band; scales per person and per document | §10.9 | | Apostille — United Kingdom (Foreign, Commonwealth and Development Office) | £45 standard; £35 e-apostille; £40 next-day for registered businesses; £100 restricted urgent, plus courier | Government schedule | §10.9 | | Apostille — South Africa (Department of International Relations and Cooperation) | no fee for public documents; private documents notarised first at market rates, then apostilled without charge | Government schedule | §10.9 | | Notarisation — United Kingdom | ≈£60–£200 or more per document | Quotable; published schedules, reported band | §10.9 | | Sworn translation into Portuguese for the citizenship file, where required | not banded | Quotable only | §10.9 | | Permit health insurance, per adult per year, minimum-compliance cover | €70–€300 | Quotable; reported band. Materially more for comprehensive cover; premiums load from age 65 and cover above 75 may be unavailable | §10.10 | | Property insurance | market-priced | Quotable; an insured residence also attracts an ENFIA reduction of 20% where the property's taxable value does not exceed €500,000 and 10% where it does, conditional on cover in the preceding year of at least three months, in force since ENFIA 2025 | §10.10, §10.13 | | Power of attorney, all-in per event (Greek notarial instrument published at €300 plus 24% VAT) | €150–€500 | Quotable; reported band, one instrument can often serve a couple | §10.10 | | Greek tax number (AFM), procurement | €400 plus VAT | Quotable; single published firm schedule, a reported anchor. An AFM is a practical precondition of purchase | §10.10 | | Bank-account application assistance | €300 plus VAT | Quotable; single published firm schedule. An application is not an approval (§9.4–§9.5) | §10.10 | | Currency conversion on approximately €335,000 of cross-border transfers — specialist 30–100 basis points; bank 200–400 basis points | €1,005–€3,350 (specialist); €6,700–€13,400 (bank) | Quotable; the exchange-rate margin, not the wire fee, dominates. Written quotes required | §10.10 | *Single applicant; percentage lines computed on a €250,000 price; VAT at 24% included where stated; currency-conversion figures computed on approximately €335,000 of transfers at the planning assumption of €1 = US$1.15 (§10.2). The health-insurance coverage minimums behind the premium band were fixed under the predecessor Code and are still applied in practice, subject to confirmation at the date of application (§10.10). Bands are reported unless marked as this report's estimate; each requires a written quotation before engagement (§10.1). Sources and instruments as cited in §§10.6–§10.10.* ## C.5 Group 5 — Kestrel Private's professional engagement | Cost line | Amount or band | Basis | Section | | --- | ---: | --- | --- | | Kestrel Private's professional engagement, São Tomé and Príncipe citizenship application, charged as a fixed professional engagement fee agreed in writing before work begins | €10,000 as published at the date of this report | Fixed fee, agreed in writing, charged per application | §10.11 | | Kestrel Private's professional engagement, Greek investor residence application, charged as a fixed professional engagement fee agreed in writing before work begins | €8,000 as published at the date of this report | Fixed fee, agreed in writing; the published rate for a second application instructed alongside the first | §10.11 | | **Subtotal, Group 5 — reference case, two applications** | **€18,000** | — | §10.11 | *The fee is charged per application, because each application is a separate body of work: a separate file, a separate set of counterparties, a separate schedule of disbursements and a separate government reaching a separate decision. The reference case instructs both programmes and therefore carries two fees; a client instructing the citizenship application alone, or the residence application alone, pays one fee of €10,000. The fee is charged on the two programme applications only, and there is no third fee anywhere in this model: the optional company, banking and tax layer carries no Kestrel Private professional engagement fee, its cost consisting entirely of third-party charges — corporate registrar and formation charges, corporate-service provision and the corporate team that performs the work — and it sits outside this reference case and is not modelled here (§10.11, §10.12, §10.15). Each fee is stated as a single line and is not decomposed, and each is fixed: it does not scale with the value of the investment or with the composition of the family. Every other line in Groups 1 to 4 is a disbursement payable to the government, authority, professional or provider entitled to it, paid by the client directly to that party and quotable in advance (§10.1, §10.11). Subtotal foots: €10,000 + €8,000 = €18,000.* ## C.6 Known base subtotal | Cost line | Amount | Basis | Section | | --- | ---: | --- | --- | | Qualifying Greek property | €250,000 | Government schedule | §10.5 | | São Tomé and Príncipe contribution, US$90,000 | €78,261 | Government schedule | §10.3 | | Due-diligence and processing fee, US$5,000 | €4,348 | Government schedule | §10.4 | | Greek main-applicant permit fee | €2,000 | Government schedule | §10.7 | | Greek residence-card production charge | €16 | Government schedule | §10.7 | | **Known base subtotal** | **€334,625** | — | §10.1 | *Single applicant; conversions at the planning assumption of €1 = US$1.15 (§10.2); statutory and published charges as at 2 August 2026, subject to confirmation at the date of application. Derived from §10.1, §10.3–§10.5 and §10.7. Foots: €250,000 + €78,261 + €4,348 + €2,000 + €16 = €334,625. Against a planning figure of approximately €375,000 this leaves €40,375 exactly, and that figure is carried as the allowance throughout this appendix. The planning assumption is about 0.3% below the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026; at that reference rate the known base would be about €334,374 and the allowance about €40,626, so the allowance used here is the conservative one (§10.2).* ## C.7 The variable lines — lean, heavy and top-of-band cases | Cost line (all measured against the €40,375 allowance) | Lean case | Heavy case | Top of every band | Basis | Section | | --- | ---: | ---: | ---: | --- | --- | | FMA transfer tax at an effective 3.09% (€7,500 at the 3% main rate alone) | €7,725 | €7,725 | €7,725 | Main rate confirmed to Α.Ν. 1521/1950 Art. 4 §1; municipal element reported, instrument not pinned | §10.6 | | Notary, 0.8%–1.2% plus 24% VAT | €2,480 | €3,720 | €3,720 | Statutory scale | §10.6 | | Land registry / cadastre, ≈0.5% (fixed charges additional, unquantified) | €1,250 | €1,250 | €1,250 | Schedule-based | §10.6 | | Conveyancing lawyer (lean 1%; heavy 1.5%; top 2% plus 24% VAT) | €3,100 | €4,650 | €6,200 | Quotable | §10.8 | | Buyer's estate agent (lean none; heavy 2.5%; top 4% plus VAT) | €0 | €7,750 | €12,400 | Quotable | §10.6 | | Technical due diligence, conversion property | €300 | €1,500 | €1,500 | Estimate | §10.8 | | Power of attorney, all-in (lean one Greek instrument; heavy and top two events) | €372 | €600 | €1,000 | Quotable | §10.10 | | Translations and apostilles, single applicant | €150 | €900 | €900 | Quotable | §10.9 | | Greek residence-filing professional fees (lean: contracted within the conveyancing retainer) | €0 | €3,000 | €3,500 | Quotable | §10.8 | | Property and permit health insurance, first year | €350 | €800 | €800 | Quotable | §10.10 | | Greek tax number (AFM), €400 plus 24% VAT | €496 | €496 | €496 | Single-firm reported anchor | §10.10 | | Bank-account application support, €300 plus 24% VAT | €372 | €372 | €372 | Single-firm reported anchor | §10.10 | | Currency conversion on ≈€335,000 (lean specialist 0.3%; heavy bank 2%; top bank 4%) | €1,005 | €6,700 | €13,400 | Quotable | §10.10 | | Post-approval citizenship documents, aggregate per applicant — US$750 | €652 | €652 | €652 | Official programme-site schedule, not in the gazetted Anexo I; requires confirmation at the date of application; carried in all three columns | §10.4 | | Licensed submitting agent's retainer allowance — US$5,000 | €4,348 | €4,348 | €4,348 | Allowance carried in Kestrel Private's own cost model, not a quoted retainer and not published; carried in all three columns | §10.4, §10.14 | | Kestrel Private's professional engagement, two applications (citizenship €10,000, residence €8,000) | €18,000 | €18,000 | €18,000 | Fixed fee agreed in writing, charged per application | §10.11 | | **Total against the allowance** | **€40,600** | **€62,463** | **€76,263** | — | §10.14 | | **Headroom against €40,375** | **−€225** | **−€22,088** | **−€35,888** | — | §10.14 | *Single applicant; €250,000 property bearing FMA with taxable value equal to price; €1 = US$1.15 (§10.2); the client assumed to fund from a currency other than the euro and the US dollar, so that the whole ≈€335,000 converts (§10.10). Lean case: no buyer's agent, conveyancing counsel near the bottom of the band with the residence filing contracted inside the retainer, specialist-rate currency conversion, South-Africa-route document legalisation. Heavy case: buyer's agent at 2.5% plus VAT, counsel at 1.5% with separate immigration filing, bank-rate conversion at 2%, United-Kingdom-route documents with notarisation. Top-of-band case: every banded line at the upper figure Chapter 10 states. Derived from §10.14; bands and anchors as cited in §§10.6–§10.11; arithmetic exact within the stated assumptions. The AFM and bank-account lines are single-firm reported anchors and are carried in all three columns; the submitting agent's retainer and the post-approval documents are dollar-denominated allowances rather than quotations and are likewise carried in all three (C.2); the registry line carries the percentage element only, and the fixed charges the same schedule adds are unquantified, so all three totals are floors. Columns foot: lean 7,725 + 2,480 + 1,250 + 3,100 + 0 + 300 + 372 + 150 + 0 + 350 + 496 + 372 + 1,005 + 652 + 4,348 + 18,000 = €40,600; heavy 7,725 + 3,720 + 1,250 + 4,650 + 7,750 + 1,500 + 600 + 900 + 3,000 + 800 + 496 + 372 + 6,700 + 652 + 4,348 + 18,000 = €62,463; top of every band 7,725 + 3,720 + 1,250 + 6,200 + 12,400 + 1,500 + 1,000 + 900 + 3,500 + 800 + 496 + 372 + 13,400 + 652 + 4,348 + 18,000 = €76,263. Where the 3% FMA main rate alone is the true burden (§10.6), the first row is €7,500 and each column falls by €225 — €40,375, €62,238 and €76,038, with headroom of €0, −€21,863 and −€35,663: on that reading the lean case meets the allowance exactly. The exchange-rate assumption does not move the answer either. At the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026 the known base is about €334,374 and the allowance about €40,626; the lean allowance items are about €40,585, so the lean case sits about €41 below the €375,000 reference rather than €225 above it, a lean all-in of about €374,959. The heavy and top cases exceed the allowance on either rate (§10.2).* The allowance is exceeded in every column — by €225 in the lean case, and materially in the other two. The heavy case is not the ceiling: its inputs sit inside, not at the top of, the bands Chapter 10 reports, and the third column prices that ceiling (§10.14). The two professional engagement fees together, at €18,000 — €22,348 once the submitting agent's allowance is added, 55.4% of the allowance — are the largest committed block inside it in all three columns, ahead of the currency-conversion route at its upper figure of €13,400, the buyer's agent at €12,400, the FMA charge at €7,725 and the submitting agent's allowance at €4,348. Lines the allowance must also carry are not in the table above because no source will band them before selection: citizenship-side legal work (§10.8), the compulsory-entry travel and accommodation of the applicant (§10.7, §17.11), the fixed element of the land-registry charges (§10.6, §10.15), property furnishing or completion, and any genuine reserve for the unforeseen (§10.14). The swing items, in order of magnitude, are the buyer's agent (€0 to €12,400), the currency-conversion route (€1,005 to €13,400), separate residence-filing counsel (€0 to €3,500), the conveyancing percentage (€3,100 to €6,200) and technical due diligence (€300 to €1,500) (§10.14). ## C.8 Totals | Position | Amount | Section | | --- | ---: | --- | | Known base subtotal | €334,625 | §10.1, C.6 | | Variable lines, lean case | €40,600 | §10.14, C.7 | | **Total, lean case** | **€375,225** | — | | Known base subtotal | €334,625 | §10.1, C.6 | | Variable lines, heavy case | €62,463 | §10.14, C.7 | | **Total, heavy case** | **€397,088** | — | | Known base subtotal | €334,625 | §10.1, C.6 | | Variable lines, top of every band | €76,263 | §10.14, C.7 | | **Total, top of every band** | **€410,888** | — | *Single applicant; €1 = US$1.15 (§10.2); all assumptions as stated in C.6 and C.7. Foots: €334,625 + €40,600 = €375,225; €334,625 + €62,463 = €397,088; €334,625 + €76,263 = €410,888. On the 3% FMA main rate alone (§10.6) each total falls by €225, to €375,000, €396,863 and €410,663. Headroom is measured in C.7 against the allowance of €40,375, which added to the known base gives exactly €375,000; the report preserves the executive summary's language of "approximately €375,000" as the planning reference, while recording that the model re-footed here exceeds it in all three columns (§10.1, §12.1). The totals move only modestly with the exchange-rate assumption: at the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026 the dollar-denominated lines are lower and the lean all-in is about €374,959, which remains above the reference figure (§10.2, C.7). Exit-side costs are excluded here and priced at §12.4 and §12.10.* What the arithmetic now shows is that the €375,000 formulation does not hold in any modelled case. Earlier statements in this report that the reference figure survives in a tightly controlled lean case rested on a model that omitted the retainer of the licensed submitting agent through which a São Tomé and Príncipe application must be filed — a cost the client genuinely bears. With that line carried at the €4,348 allowance described at C.2, the lean column exceeds the allowance by €225, about 0.6% of the reference case, and the lean all-in total is €375,225. The figure is exceeded by about €24,100 where the heavy end of each band applies, and by about €37,900 where every band is at its upper figure. The honest conclusion is that €375,000 is a planning reference which even the lean case narrowly exceeds once every real cost is counted, and that a defensible planning figure is approximately €376,000 — a figure that clears the lean column by about €775 and no more. That €775 is not a margin. It stands before any of the lines the allowance must also carry but which no source will band before selection: citizenship-side legal work, the compulsory-entry travel and accommodation of the applicant, the fixed element of the land-registry charges, property furnishing or completion and any reserve for the unforeseen are each unquantified and each payable in addition (§10.7, §10.8, §10.15). The model remains an illustrative planning model, not a universal package price, and on any assumptions less favourable than the lean column it is exceeded by a substantial margin (§10.14). The heavy case is not an extreme — each of its inputs sits inside an ordinary reported band, and the top-of-band column above prices what those bands reach at their upper figures (§10.14). ## C.9 Character of the capital deployed | Component | Amount | Character | Section | | --- | ---: | --- | --- | | Qualifying Greek property | €250,000 | Retained — invested in an asset the client owns, at risk | §12.1–§12.3 | | Known programme charges (contribution €78,261, due-diligence fee €4,348, permit fee €2,000, card charge €16) | €84,625 | Spent — non-recoverable once paid | §12.1 | | Allowance for transaction taxes, professional fees, translations, insurance and other implementation costs, including Kestrel Private's two professional engagement fees of €18,000 and the submitting agent's retainer allowance of €4,348 | €40,375 | Spent — non-recoverable once incurred | §12.1 | | **Total reference case** | **€375,000** | — | §12.1 | | Amount by which the modelled lean case exceeds that allowance, and so the reference case | €225 | Spent — non-recoverable once incurred | C.7, C.8 | | **Modelled lean all-in** | **€375,225** | — | C.8 | *Single applicant; €1 = US$1.15 (§10.2), a planning assumption about 0.3% below the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026, so at that reference rate the €84,625 "spent" component would be about €250 lower and the allowance about €250 higher; on the planning assumption the first three components sum exactly to the stated reference of €375,000 (§12.1), and at the reference rate the lean case sits about €41 below the reference figure rather than €225 above it (C.2, C.7). Foots: €250,000 + €84,625 + €40,375 = €375,000, where €84,625 = €78,261 + €4,348 + €2,000 + €16. The allowance is a residual of the known base and does not move with the fee, but its composition does: of the €40,375, €18,000 is Kestrel Private's two professional engagement fees (C.5) and €4,348 is the submitting agent's retainer allowance (C.2), leaving €18,027 for every transaction tax, professional fee, translation, apostille, insurance premium, currency margin and unbanded implementation cost the reference case must also absorb. On the lean column at C.7 those remaining costs are €18,252, which exceeds the €18,027 available by €225 — the amount by which the lean case exceeds the reference figure, and the reason the two closing rows of the table above are shown. Foots: €40,375 − €18,000 − €4,348 = €18,027; €40,600 − €18,000 − €4,348 = €18,252; €18,252 − €18,027 = €225; €375,000 + €225 = €375,225. Ownership of the property is real, but retained does not mean preserved or readily recoverable: acquisition friction — transfer tax, notary, registry, conveyancing counsel, any buyer's agent and technical due diligence — of roughly 5.9%–13.1% of the €250,000 is consumed on day one (§12.4). Chapter 10 states the same stack excluding technical due diligence at about 5.8%–12.5% (§10.6); the two are the same lines measured on different baskets, not a discrepancy. The scenario range at §12.11 runs from meaningful gain to a loss of between a quarter and a half of the property-side outlay, depending on how much of any entry premium survives (§12.11).* ## C.10 First-year and recurring ongoing costs | Recurring line | Reported band, per year | Basis | Section | | --- | ---: | --- | --- | | ENFIA, illustrative for a €250,000 Athens apartment below the €500,000 surcharge threshold | ≈€300–€700 | Government schedule, computed per property by the tax administration; illustrative, before the insured-residence reduction of 20% at taxable values up to €500,000 (10% above), which requires cover in the preceding year of at least three months | §10.13 | | Municipal property duty (TAP), 0.25‰–0.35‰ of assessed value, via the electricity account | ≈€63–€88 | Government schedule; computed here on an assessed value of €250,000. The assessed value of the selected property is a property-specific figure established during due diligence, and the charge follows it (§10.13, §10.15) | §10.13 | | Non-resident tax compliance (return where required, ENFIA handling, tax-representative arrangements) | ≈€250–€500 | Quotable; a single market source's basic tier — rental filings sit in higher tiers of roughly €1,000–€2,500 | §10.13 | | Permit health insurance, per adult, minimum-compliance band | ≈€70–€300 | Quotable | §10.13 | | **Quantified subtotal** | **≈€683–€1,588** | — | §10.13 | | Building common charges (κοινόχρηστα) | building-specific; no statutory scale | Established from the building's own charge history during due diligence | §10.13, §10.15 | | Municipal refuse and lighting charges, via the electricity account | municipality-specific tariff | Established from the municipal tariff | §10.13, §10.15 | | Property insurance | market-priced | Quotable; earns the ENFIA discount | §10.13 | | Letting and management, if instructed | market-contracted | Quotable | §10.13 | *Single non-resident owner, the property unlet and held personally, as at 2 August 2026; reported figures subject to confirmation at the date of application. Derived from §10.13. Subtotal foots at both ends: €300 + €63 + €250 + €70 = €683; €700 + €88 + €500 + €300 = €1,588. TAP computed at 0.25‰ and 0.35‰ of €250,000 (€62.50 and €87.50, shown rounded). To avoid double counting, note that first-year property and permit health cover is already carried inside the implementation allowance at C.7 (€350–€800 combined): the table above is the recurring stack, and the two are not additive in year one without adjustment. Where the property is long-let, Greek tax on the rent and management costs are added (§9.10, §12.5–§12.6). From 1 January 2027 TAP is replaced by a Local Development Fee of 0.30‰–0.70‰, up to about €175 a year at a €250,000 assessed value (§10.13). The E9 property declaration is due by 31 January of the year following the deed (§10.13). At each five-year renewal the cycle adds the €2,000 permit fee again, the card charge, a fresh insurance policy and the definitive registration certificate where registration proof was deferred at initial issuance (§10.13).* ## C.11 Lines that cannot be modelled before selection Each of the following is set out at §10.15, and each must be resolved in the client-specific cost model before a quotation can be produced. 1. The VAT-versus-FMA classification of the selected property, and whether the VAT suspension is extended beyond 31 December 2026 (§10.6). 2. The objective (tax-assessed) value, where it exceeds the price (§10.6). 3. Technical findings and the cost of remedying them (§10.8, §8.5). 4. Furnishing and completion (§10.15). 5. Building and municipal charges (§10.13). 6. Insurance premiums, which are age-, cover- and property-specific (§10.10). 7. Professional quotations — the lawyer's percentage, the instruction of a buyer's estate agent, technical scope, citizenship-side legal work, and the retainer of the licensed submitting agent, which no source read for this report publishes and which is carried here only as a stated allowance of US$5,000 (C.2, §10.4, §10.8, §17.9). 8. Execution-date currency costs: the rate, the margin and the route on each payment day (§10.2, §10.10). 9. Government schedules in force at the date of application in both jurisdictions, including São Tomé and Príncipe's power to alter its amounts by joint ministerial order and the possibility of Greek legislative change, and confirmation of the US$750 document aggregate (§10.3, §10.4, §14.1–§14.2). 10. Family composition, which scales every per-person line — contribution supplements, permit fees, documents, translations, insurance (Chapter 11, §11.8). ## C.12 What this figure is, and what it is not > The figure modelled in this appendix is an illustrative planning model for a single modelled case, on the stated assumptions. It is not any of the following. > > - **A fixed price.** Every banded line resolves only against a written quotation for the selected property and the actual family; the total moves with them (§10.14, §10.15). > - **An all-inclusive price.** Costs that no source will band before selection sit outside the table and remain payable in addition to it (§10.14, §10.15). > - **A maximum.** It does not cap what the position will cost: the top-of-band column at C.7 prices the upper figure of each reported band, not a ceiling (§10.14). > - **A family price.** Contribution supplements, permit fees, documents, translations and insurance all scale with family composition (Chapter 11, §11.8). > - **A figure the modelled case comes in under.** Once the licensed submitting agent's retainer allowance is carried, the lean column exceeds €375,000 by €225, the heavy column by €22,088 and the top-of-band column by €35,888; €375,000 is a planning reference the model exceeds in every column, and a defensible planning figure is approximately €376,000 (C.7, C.8). > - **A price for an assured outcome.** Approval cannot be guaranteed in either jurisdiction, and decision-making authority rests with the two governments (§18.9). > - **A promise that the €250,000 will remain fully recoverable.** The capital is retained in an asset the client owns, but retained at risk: acquisition friction — transfer tax, notary, registry, conveyancing counsel, any buyer's agent and technical due diligence — of roughly 5.9%–13.1% is consumed on day one, and the scenario range runs to a substantial loss (§12.1–§12.4, §12.11). > > The same discipline governs the executive summary and §10.1. Nothing in this appendix's arithmetic supports any of the seven descriptions. A quotation becomes possible only once the full cost model has been completed using the selected property, the exact family composition, the government schedules current at the date of application and written quotations from the relevant legal and professional providers (§1.5, §10.15, §17.9).