# Appendix L — Definitions and Terminology This appendix is the report's working glossary. It defines, in alphabetical order, every term the report uses with a precise meaning, states the distinction each term is drawing, and — where a term is commonly misused in the investment-migration market — states the correct position. It introduces no fact and no legal proposition that is not established in the body of the report: each entry closes with the section where the term is treated in full, and where the body qualifies a statement as requiring confirmation at the date of application, the entry carries the same qualification. Entries are written to be read by an intelligent non-lawyer; where a primary instrument governs, it is named inline. --- **Annex I and Annex II (the EU visa lists).** Regulation (EU) 2018/1806 lists in Annex I the third countries whose nationals must hold a visa to cross the external borders of the member states, and in Annex II those whose nationals are exempt for short stays. São Tomé and Príncipe is in Annex I, so the citizenship component provides no visa-free access to the Schengen states; nationals of Annex II states already hold visa-free short-stay access on their existing passports, and gain nothing on that front from a further passport. Annex status is amended from time to time and requires confirmation at the date of application. The visa-suspension ground for investor-citizenship schemes inserted by Regulation (EU) 2025/2441 applies only to Annex II countries. (Treated at §4.4, §4.8 and §7.10.) **Apostille.** A certificate issued under the Hague Convention by which a public document issued in one contracting state is accepted as authentic in another without consular legalisation. It appears at two points in the reference structure: the power of attorney permitting a proxy to file the Greek application before the applicant has entered Greece must be executed before a Greek consular authority or bear the apostille or equivalent legalisation (Article 10(11), Law 5038/2023), and the São Toméan decree requires foreign documents to be legalised by apostille or, in its absence, authenticated by the competent consular authority (Decree-Law 07/2025, Article 10(8)). An apostille certifies the origin and signature of a document; it says nothing about the truth of its contents. (Treated at §7.7; the São Toméan documentary requirements are treated in Chapter 6.) **Blue receipt (certificate of submission).** The certificate issued on filing a complete Greek application, valid until the decision, which certifies lawful residence in Greece and whose holder temporarily enjoys the rights flowing from the permit applied for (Article 10(8), Law 5038/2023). It is not the permit and not a residence card. Whether it supports short-stay movement in other Schengen states is not addressed by any official source located for this report; the prudent working assumption is that mobility under Article 21 of the Schengen Convention begins with the issued permit, and the point should be confirmed with Greek counsel at engagement. (Treated at §7.8.) **Centre of vital interests.** The place with which an individual's personal and economic ties are closest — family, home, employment, business and assets taken together. It is one of the tests by which Greece determines tax residence under Article 4 of Law 4172/2013, alongside permanent or main residence, habitual abode and the 183-day presence test, and it can produce Greek tax residence on facts alone, without any election and without regard to the residence permit. A dwelling permanently at the client's disposal is one of the ties from which such a centre may be constructed. The Greek tax propositions in this report are stated from professional summaries and require confirmation against the gazetted texts at the date of application. (Treated at §9.6 and §9.11; see also §4.6.) **Change-of-use category.** The restricted exception under Article 100(2) of Law 5038/2023, as amended by Article 64 of Law 5100/2024, by which a minimum investment of €250,000 supports an investor residence permit where the main spaces of a single property change use to residential; no minimum floor area applies, and the conversion may be effected by the buyer or the seller. It is not a general €250,000 threshold: the standard thresholds remain €800,000 and €400,000 by location, and a property qualifies only where the conversion conditions are satisfied in full and completed before the application. The administrative record requires completion after 5 April 2024, and Circular 1/2026 is reported to police substance — a property already in residential use on that date cannot be cycled out of and back into it, and a paper amendment to a building permit does not count; the circular text was not opened for this report and its contents are stated as reported. Marketing that presents the category as universally available, or that treats documentary conversion as sufficient, misstates the position. (Treated at §7.4 and §7.5.) **Citizenship by investment.** A statutory mechanism by which a state grants nationality on the basis of a qualifying payment or investment rather than residence, descent or marriage. Within the European Union, transactional investor citizenship has ended: the Court of Justice held in *Commission v Malta* (Case C-181/23, 29 April 2025) that granting nationality essentially in exchange for predetermined payments or investments amounts to the commercialisation of the status of national of a member state and, by extension, of Union citizenship. The citizenship component of the reference structure is a non-EU programme — São Toméan naturalisation under Decree-Law 07/2025 — and confers no status in EU law of any kind. (Treated at §4.1, §4.2 and Chapter 2, in particular §2.4 and §2.5.) **Common Reporting Standard (CRS).** The OECD standard under which financial institutions identify account holders' jurisdictions of tax residence and report account information for automatic exchange with those jurisdictions. It is keyed to tax residence, never to citizenship: the self-certification a client signs at onboarding asks for all jurisdictions of tax residence, and an institution may not rely on a self-certification it knows or has reason to know is incorrect or unreliable. A further passport therefore changes no reporting outcome; São Tomé and Príncipe has made no commitment to automatic exchange as at the Global Forum's status document of 27 July 2026, and that absence neither creates nor removes a reportable residence. Any suggestion of a "CRS benefit" from the citizenship component would be false, and using investment-migration documents to misdescribe tax residence is the abuse the OECD's guidance directs institutions to test for. (Treated at §9.14; see also §4.6 and §4.8.) **Contribution (as distinct from investment).** A contribution is a non-refundable payment to the state or a state fund made in exchange for consideration of an application; an investment is the acquisition of an asset that the client continues to own. In the reference structure the citizenship component rests on a contribution to the National Transformation Fund, payable only after approval and deposited within 90 days of the approval certificate (Decree-Law 07/2025, Article 14(4)), while the residence component rests on an investment — the €250,000 property, which the client owns and which must remain in full ownership and possession for the permit to be renewed. The two are not the same kind of money, and one vocabulary will not carry both: the contribution is spent, the property is held and carries market, liquidity and legal risk of its own. Ownership of the property is not a promise of value, and the report gives no assurance as to recoverability of either amount. (Treated at §6.5, §7.6 and §12.3.) **Controlled foreign company (CFC).** A home-country tax regime that attributes the income of a foreign company to its resident owners, whether or not the company distributes. South Africa's section 9D of the Income Tax Act 58 of 1962 is the verified example used in this report: a foreign company more than 50% held by South African residents is a controlled foreign company whose net income is imputed to the resident participants pro rata, unless an exemption applies. A company interposed between a resident client and passive income therefore rarely defers home taxation and often merely adds imputation and reporting; comparable regimes exist in other client jurisdictions and must be assessed by home-country advisers before any company is formed. (Treated at §9.12 and §9.14.) **Domicile.** A common-law concept of a person's permanent legal home, historically decisive for United Kingdom taxation and distinct both from nationality and from tax residence. Greek law does not operate it, so what the market calls the Greek "non-dom" regimes are not domicile rules at all but elective alternative-taxation regimes for persons transferring tax residence to Greece. The United Kingdom abolished the remittance basis and the domicile-based regime from 6 April 2025, and inheritance tax there is now residence-based. Nothing in the reference structure confers, preserves or alters any domicile position. (Treated at §9.8; see also §9.12.) **Due diligence; enhanced due diligence.** Due diligence is the identification and verification of a customer and any beneficial owner, understanding of the purpose of the relationship and ongoing monitoring, including, where necessary, establishing the source of funds (FATF Recommendation 10). Enhanced due diligence is the heightened version applied to higher-risk cases; under Regulation (EU) 2024/1624, from 10 July 2027, obliged entities must apply as a minimum, to third-country nationals applying for residence rights in exchange for investment, additional information on the customer and beneficial owner, additional information on source of funds and source of wealth, senior-management approval and enhanced monitoring, and Annex III lists such applicants as a higher-risk factor. On the citizenship side, the São Toméan decree builds its own gatekeeping: due diligence by independent external entities engaged by the responsible unit, a Review Committee including the financial intelligence unit, and a prior opinion of the Public Prosecutor. Due diligence is a process a client passes or fails, never a formality, and no outcome can be assured. (Treated at §9.4 and §9.5, and in Chapter 15.) **Entry/Exit System (EES).** The EU system that registers the entry and exit of third-country nationals crossing the external borders for short stays; it began progressive operations on 12 October 2025 and has been fully operational at all external border crossing points since 10 April 2026. Holders of residence permits within the meaning of Article 2(16) of the Schengen Borders Code are outside its scope, and Commission guidance confirms that residence-permit holders of EES-operating countries are exempt. That exemption is a genuine and citable convenience of the Greek permit; it is not a right of free movement and should not be described as one. (Treated at §4.4.) **ETIAS.** The European Travel Information and Authorisation System, a travel authorisation intended for visa-exempt third-country nationals. It is not in operation as at 2 August 2026 and no launch date is published; once operational it will not apply to holders of residence permits within the meaning of the Schengen Borders Code, nor to holders of uniform or national long-stay visas. A traveller relying on the São Tomé passport alone stands outside ETIAS for a different reason: as an Annex I national he requires a full Schengen visa, not a travel authorisation. (Treated at §4.4.) **Exceptional or merit-based naturalisation.** Discretionary naturalisation granted by a state for exceptional services or merit, where its national law provides for it. It is decided case by case, is never guaranteed and cannot be purchased; it is not a programme, has no price and no timetable, and must never be presented as a product. It is categorically distinct from transactional citizenship, which the Court of Justice has held incompatible with Union law. (Treated in Chapter 2, in particular §2.7; the boundary is drawn at §4.1 and §4.8.) **Grandfathering.** The legislative practice of preserving the position of permits already granted when conditions change. Permits granted under the predecessor Greek provision (Article 20B of Law 4251/2014) or under earlier conditions remain in force and are renewed provided the conditions in force at the time of their grant continue to be met (Article 64(3) of Law 5100/2024), and each Greek threshold change to date has been accompanied by transitional provisions. That is the pattern to date; it is not a guarantee, and nothing prevents a future legislature from raising thresholds, closing the change-of-use category, altering renewal conditions or ending the programme. (Treated at §7.2 and §7.14.) **Investor residence permit ("golden visa").** The formal description of the Greek permanent investor residence permit, type «Β.5», created by Article 100 of Law 5038/2023 as amended by Article 64 of Law 5100/2024. This report uses the statutory description; "golden visa" is the market's historical name, and it appears in the title of the official administrative record itself. The term "visa" in that nickname is a misnomer with practical consequences: the instrument is a residence permit, and the difference is set out under *Residence permit versus visa* below. (Treated at §7.2; the market's use of the phrase is discussed at §4.8.) **Long-Term Residence Directive.** Council Directive 2003/109/EC, which confers EU long-term-resident status on third-country nationals after five years of legal and continuous residence in a member state, subject to further conditions including stable resources and sickness insurance. The status is not conferred by the investor permit and does not accrue automatically with it: a holder who maintains the permit from abroad does not accumulate the continuous residence the Directive requires. Neither the permit nor that status is EU citizenship, and neither confers residence or employment rights across the Union as of right. (Treated at §7.13; see also §4.3.) **Naturalisation.** The acquisition of a nationality after birth by decision of the granting state, on conditions that state sets, and as an exercise of its discretion. In Greece the official administrative record structures the required period of prior lawful residence as three, seven or 12 years by residence title — the investor permit falls on the seven-year track — with the further requirements of the PEGP examination, evidenced economic and social integration including Greek tax returns for the years of residence, and the prescribed fees. In São Tomé and Príncipe the citizenship component is itself a special naturalisation, under Article 10(2) of Law 7/2022 as implemented by Decree-Law 07/2025, with the residence and language requirements capable of waiver for that ground. In both systems naturalisation remains a discretionary act of the state, never guaranteed even where every condition is met. (Treated at §7.13 and Chapter 6, in particular §6.2.) **Non-dom regime.** The market label for the three elective alternative-taxation regimes of Articles 5A, 5B and 5C of Law 4172/2013, available only to persons who transfer tax residence to Greece. None is available to a non-resident, none is engaged by property purchase or by the residence permit, and property ownership does not create non-dom status. Article 5A — the regime most often wrongly attached to the permit — requires non-Greek tax residence in seven of the eight preceding years and a qualifying Greek investment of at least €500,000, of which the €250,000 reference property is half, and consists of paying a flat tax of €100,000 per tax year (plus €20,000 per included relative) for at most 15 years: it is a tax, not an exemption. The regime terms are stated from professional summaries and require confirmation at the date of application. (Treated at §9.8; the marketing claim is dissected at §4.8.) **Objective value (Greek property).** The administratively determined value of Greek immovable property, derived from the tax authority's zone-price system and used as a tax base where the law so provides; it appears in this report in the property-tax treatment and in the deemed-income rules, where zone prices uplift the imputed amounts. It is neither the market price nor the figure that qualifies a property under Article 100 of Law 5038/2023: the €250,000 condition is a minimum acquisition value at the time of purchase, paid in full through the statutory banking channels before the application and recorded with every payment detail in the notarial deed. A property is therefore not made eligible by its objective value, and a low objective value is not evidence of a sound purchase. Objective values are administratively set and may be revised; any figure requires confirmation at the date of application. (Treated at §8.6 and §8.12; the acquisition-value condition is at §7.6, and the deemed-income interaction at §9.10.) **Obliged entity.** A person or firm on whom anti-money-laundering law imposes customer due-diligence, record-keeping and reporting duties. In Greece today the lawyers, notaries and estate agents in the transaction chain are obliged entities under Law 4557/2018, and the credit institution through which the funds move carries its own refusal duty; from 10 July 2027 Regulation (EU) 2024/1624 makes "investment migration operators" obliged entities and applies enhanced due diligence to applicants for residence rights in exchange for investment. The client's file therefore passes through statutory gatekeepers regardless of who coordinates it. (Treated at §9.4; the direction of EU policy is at §7.14.) **Place of effective management.** The test by which a company is attributed tax residence: under Article 4 of Law 4172/2013 a legal person is Greek tax resident if its place of effective management is in Greece at any time in the tax year, judged on facts including day-to-day management and strategic decision-making, the place of board and general meetings, where the books are kept and where the directors reside. The rule runs the opposite way to the sales pitch: a company cannot give its owner tax residence, but an owner managing a foreign company from Greece may give the company Greek tax residence, with Greek corporate tax and filing obligations to match. A registered-office address cannot manufacture management in one place or conceal it in another. (Treated at §9.11; see also §4.7 and §9.3.) **Politically exposed person (PEP).** An individual entrusted with prominent public functions, together with family members and close associates; the FATF glossary states that the definition is not intended to cover middle-ranking or more junior individuals. For foreign PEPs, FATF Recommendation 12 requires risk-management systems to identify them, senior-management approval of the relationship, reasonable measures to establish source of wealth and source of funds, and enhanced ongoing monitoring. The FATF–OECD joint report of November 2023 records the circumvention typology directly relevant to this market — that it is common for high-risk individuals to gift wealth to a spouse or other family member who then makes the lead application. PEP status is not a disqualification; it is a trigger for enhanced due diligence and senior-management decision. (Treated in Chapter 15; the banking consequences are at §9.5.) **Reference structure.** The two-jurisdiction structure examined in this report, with an optional third layer: the citizenship component (São Toméan naturalisation), the residence component (the Greek investor residence permit), the property component (the qualifying €250,000 property that supports the permit), and the optional layer (company, banking and tax elements). The components are complementary parts of one coordinated position, each assessed on its own legal terms; they are not alternatives to one another, and holding all of them merges nothing — each keeps its own authority, conditions and failure modes. (Treated in Chapter 5, in particular §5.7 and §5.8; the rights attribution is at §4.9.) **Residence permit versus visa.** A visa is a permission, normally issued by a consulate of the destination state, to travel to and seek entry for a stated purpose and limited period; a residence permit is an authorisation issued by the state of residence to reside in its territory on the statutory conditions. The distinction is practical as well as formal: under the Schengen Borders Code a residence permit substitutes for a visa at the external border, and under Article 21 of the Schengen Convention it carries short-stay movement in the other member states, neither of which a short-stay visa of another state provides. A permit is also revocable on failure of its conditions and must be renewed; it is best understood as a renewable, revocable licence whose continuation the holder must keep earning. Despite its market nickname, the Greek instrument is a residence permit, not a visa. (Treated at §4.3, §4.4 and §7.10.) **Schengen Area, European Union and eurozone.** Three overlapping but distinct groupings. The Schengen area — 29 countries as at 2 August 2026, comprising 25 EU member states plus Iceland, Norway, Switzerland and Liechtenstein — is the area without internal border controls in which short-stay movement under Article 21 of the Schengen Convention operates; Bulgaria and Romania became full members on 1 January 2025, Ireland has opted out, and Cyprus participates in Schengen cooperation but is not yet part of the area without internal border controls. The European Union is the legal order that confers Union citizenship and free movement under Directive 2004/38/EC, which applies to Union citizens and their family members and to which a third-country permit holder is not a beneficiary. The eurozone is the group of member states that have adopted the euro as their currency; it is not otherwise treated in this report, and euro membership carries no immigration consequence. Describing a Greek permit as conferring "EU residence" conflates the first two and is wrong. (Treated at §4.4; the Cyprus position is at §4.4 and §7.10.) **Short-stay rule (90 days in any 180-day period).** The limit on short stays in the Schengen states, substituted throughout the acquis by Regulation (EU) No 610/2013 in place of the former "three months in any six-month period". In the counting, the entry date is the first day of stay and the exit date the last, and periods of stay authorised under a residence permit or long-stay visa are not taken into account — so days spent in Greece under the permit do not consume the allowance for the rest of the area. The rule governs presence only: it confers no employment, establishment or long-stay right in any other member state, and stays beyond it require that state's own visa or permit. (Treated at §4.4 and §7.10.) **Source of wealth versus source of funds.** FATF's guidance draws the distinction precisely: source of wealth is the origin of the person's entire body of wealth — total assets — while source of funds is the origin of the particular funds or assets that are the subject of the relationship or transaction. Both are required in this market: the FATF–OECD joint report of November 2023 recommends assessing source of wealth in addition to source of funds, because a criminal actor may fund an application from legitimate money while wider wealth is not, and Regulation (EU) 2024/1624 requires additional information on both as part of the minimum enhanced due diligence for residence-by-investment applicants. Evidencing the two is a documentary exercise begun early, not a form completed late. (Treated at §9.5; the workstream is Chapter 15.) **Tax residence versus immigration residence.** Immigration residence is a permission to be present, granted under a state's immigration statute on its conditions; tax residence is a fiscal status concluded from facts — presence, home and the centre of a person's interests — under each jurisdiction's own law and, where two jurisdictions both claim it, under the tie-breaker of any applicable treaty. The two are independent in both directions: the Greek permit carries no presence requirement and does not create tax residence, and tax residence can arise from how a client actually lives without any election or permit. Neither the permit nor a further citizenship removes a home-country liability; that changes only where the client genuinely emigrates and separately requalifies under the destination's rules. "Tax-free residency" confuses an immigration permission with a fiscal status, and a special regime with an exemption. (Treated at §9.6 and §9.7; see also §4.6 and §4.8.) **Tekmiria (deemed income).** The Greek rules that impute income from objective living expenses and from asset-acquisition expenditure, including the purchase of real estate, and tax the difference where the imputed total exceeds declared income (Articles 30 to 34 of Law 4172/2013). The non-resident carve-out has two limbs on different conditions: the living-expense presumptions never apply to a foreign tax resident, while the acquisition presumption is disapplied only where the non-resident has no Greek-source income — so a non-resident who earns Greek rent in the year of an acquisition falls within it, with documented funds imported from abroad as the statutory cover. A client who becomes Greek tax resident loses the carve-out entirely. The provisions are read from consolidated texts and remain subject to confirmation at the date of application. (Treated at §9.10.) **Third-country national.** In EU instruments, a person who is not a citizen of the Union. The client of the reference structure is a third-country national before the structure and remains one after it: São Toméan citizenship is a non-EU nationality, and the Greek permit is a permission granted to a third-country national, not a step towards Union citizenship. The term carries operative consequences — it is the category on which Article 21 of the Schengen Convention, the Long-Term Residence Directive and the enhanced-due-diligence rules of Regulation (EU) 2024/1624 all operate. (Treated at §4.2, §4.3 and §7.10.) **Transactional citizenship.** The grant of nationality essentially in exchange for predetermined payments or investments (*Commission v Malta*, Case C-181/23, 29 April 2025, ¶99). Within the European Union it has ended: the Court of Justice held in that judgment that such a scheme amounts to the commercialisation of the status of national of a member state and, by extension, of Union citizenship, and that Malta had failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU. For third countries the same characteristic now carries a distinct EU consequence: Regulation (EU) 2025/2441 inserted into Regulation (EU) 2018/1806 a ground on which a visa exemption may be suspended where a visa-exempt third country operates an investor citizenship scheme granting nationality for predetermined payments or investments without a genuine link — a lever that cannot apply to São Tomé and Príncipe, which is visa-required. No lawful structure repackages what the judgment ended. (Treated at §4.1 and §4.8; the EU-level policy position is at §7.14 and in Chapter 2.) **Uniform-format residence permit.** A residence permit issued as a stand-alone card in the EU uniform format under Regulation (EC) No 1030/2002, whose prescribed entries include nationality as a mandatory printed field (Regulation (EU) 2017/1954, Annex) and which carries an electronic storage medium. The Greek investor permit is such a document under Article 14 of Law 5038/2023, and is therefore a "residence permit" within Article 2(16)(a) of the Schengen Borders Code, with full effect under Article 21 of the Schengen Convention. Because the card records nationality, document pairing matters in a two-passport structure: EU law prescribes no matching standard, but the only published national rule located — Belgian border guidance — requires a 100% match of five identity parameters between passport and permit, and a client should in practice continue to travel on the passport whose details match the permit. Whether Greece would re-key a permit to a newly acquired second nationality while the original subsists is not addressed in any published rule and requires confirmation with Greek counsel at engagement. (Treated at §7.10; see also §4.4.)