<!-- Appendix O — from "After the EU's Golden Passports", Kestrel Private, 6 August 2026. Canonical: https://kestrelprivate.com/research/after-the-golden-passports -->

# Appendix O — Important Legal, Tax and Investment Disclosures

These disclosures apply to the whole of this report and to every figure, table, scenario and statement in it. They are not a formality appended to a sales document; they describe the actual limits of what this report is and what Kestrel Private does.

## O.1 The status of this report

This report is general information about legal frameworks, government programmes and market conditions. It is not legal, tax, immigration, financial or investment advice. It is not directed to the objectives, financial situation or particular needs of any person, and it does not take account of the circumstances of any reader. Nothing in it constitutes a recommendation to acquire any citizenship, residence permit, property or financial product.

No professional relationship, engagement or duty of care arises between Kestrel Private and any person by reason of that person reading, receiving or relying on this report. A relationship with Kestrel Private arises only under a written engagement.

Before acting on any matter discussed here, a reader should obtain advice from a professional qualified and regulated in each relevant jurisdiction, addressing that reader's own circumstances.

## O.2 No offer, no solicitation and no endorsement

This report is not an offer to sell, or a solicitation of an offer to buy, any security, investment, property or financial instrument. It is not a prospectus, offering memorandum or listing particulars, and it has not been reviewed or approved by any regulatory authority in any jurisdiction.

No institution of the European Union, and no government of any state named in this report — including the Hellenic Republic and the Democratic Republic of São Tomé and Príncipe — has reviewed, approved or endorsed this report, its analysis, its conclusions or the reference structure it examines. No such institution or government has been asked to do so, and none has been consulted on the preparation of this report. The report is Kestrel Private's own work and states Kestrel Private's own assessment. Where this report cites legislation, judgments, official records or institutional publications, it cites them as sources for the propositions identified; citation is not endorsement of this report by the body that produced the source, and must not be represented as such.

Neither the citizenship programme nor the residence programme described in this report is a Kestrel Private product. Both are sovereign programmes established, administered and altered by the governments concerned. Nothing in this report is a statement of any government's view of its own programme, of the other programme, or of the coordinated implementation described here.

## O.3 Government discretion and the absence of guarantees

Citizenship and residence are granted by governments, not by advisers. Every application described in this report is decided by the responsible authority in the exercise of its own powers, according to its own criteria, on its own timetable, and subject to change without notice to applicants or advisers.

Kestrel Private does not and cannot guarantee: the approval of any application for citizenship, residence or a visa; the time any application will take; the opening of any bank account; the achievement of any tax position; the receipt of any rental income; the preservation, recoverability or appreciation of any capital; the liquidity or resale of any property; or the continuation of any programme, threshold, fee or condition described in this report. Where this report states that something "may" be available or "may" be provided, that word is used in its ordinary sense and is not a prediction.

Applications may be refused. Approvals may subsequently be reviewed, opposed or revoked in the circumstances described in Chapters 6, 7 and 14. Programmes may be suspended, restricted or closed, and thresholds and fees may be raised, in the ways described in §14.1 and §14.2.

## O.4 Figures, currency and dates

All figures are illustrative planning figures unless expressly identified as a published government charge, and all are stated as at 2 August 2026. Government fees, taxes, professional charges and market prices change.

Where amounts denominated in United States dollars are expressed in euro, the report applies a stated planning assumption of €1 to US$1.15. It is a planning assumption set below the prevailing market rate, adopted so that the euro figures in this report are not flattered by it: the European Central Bank's euro foreign exchange reference rate for the US dollar stood at US$1.1535 on 3 August 2026, and the assumption sits below that reference point (European Central Bank, euro foreign exchange reference rates (EUR/USD), daily series, rate of 3 August 2026 = 1.1535, https://www.ecb.europa.eu/stats/policy_and_exchange_rates/euro_reference_exchange_rates/html/eurofxref-graph-usd.en.html, accessed 4 August 2026; the reference rates are published for information purposes only and are not transaction rates). The assumption is not a market rate, is not a forecast, is not a rate available to any client, and will not be the rate at which any actual conversion occurs. The United States dollar amounts are the governing amounts; the euro figures derived from them move with the rate. Currency movement is a material risk borne by the client and is discussed at §14.13.

The reference figure discussed in this report is an illustrative single-applicant planning model. It is not a fixed price, an all-inclusive price, a guaranteed maximum cost, a family price or a quotation. Costs vary with the property selected, the composition of the family, the professional providers instructed, the exchange rate at the time of payment and the government schedules in force on the date of application. No figure in this report should be relied on as the cost of any actual engagement; a quotation requires the completed cost model described in Chapter 10.

## O.5 Property

The property described in this report is a real asset carrying real risk. Ownership does not mean capital preservation. Acquisition costs are substantial and are not recoverable on a subsequent sale. Property values fall as well as rise, and the Greek residential market has previously experienced a severe and prolonged decline, described at §12.9. Rental income is not assured; the property may stand vacant; letting on this category of investment is subject to the statutory restrictions described at §7.12 and §8.10. Resale may take time, may be at a price below acquisition cost, and may be constrained by the size of the buyer pool for the property in question.

Past performance of any market, index or property is not a guide to future performance. The scenarios in Chapter 12 are illustrations built on stated assumptions, not forecasts, and the outcomes shown will not be the outcomes obtained.

## O.6 Taxation

Taxation depends on the individual circumstances of each person and on the law of every jurisdiction with a claim on them. Tax law changes, sometimes retrospectively.

Nothing in this report is tax advice. In particular: a residence permit does not by itself create tax residence; a company does not create personal tax residence; property ownership does not confer any special tax status; and no favourable regime applies unless the person separately satisfies every statutory condition of that regime and continues to satisfy them. The client's position in their existing country or countries of tax residence, and their continuing obligations there, are unaffected by anything described in this report unless they separately change those positions with advice.

Readers who are, or may become, subject to tax in more than one jurisdiction should assume that they remain so, and take advice in each, before making any decision.

## O.7 Banking

References in this report to banking are references to the making of applications. An application is not an approval. Financial institutions decide whom to accept as a customer in the exercise of their own commercial judgement and their own obligations under anti-money-laundering law, and they are not obliged to give reasons. No account, facility or service described in this report is assured.

## O.8 Kestrel Private's role

Kestrel Private coordinates. It assesses suitability, structures and sequences the work, assembles and quality-controls the file, instructs and manages the regulated professionals engaged in each jurisdiction, and holds the client's timetable together. It does not practise Greek law, São Tomé law or the law of any other jurisdiction; it does not provide regulated legal, tax or investment advice; and it does not decide any application. Those functions belong to the regulated professionals and the government authorities identified in Chapter 18, and the client's relationship with those professionals is their own.

Kestrel Private's engagement is charged as a fixed professional engagement fee, agreed in writing before work begins. The fee is charged once for each programme application instructed: the reference case comprises two applications and therefore two fees, and the optional company, banking and tax layer, which is not a programme application, carries none (§10.11, §10.12). That fee is the firm's own charge. All other amounts described in this report — government contributions, taxes and statutory fees, the investment itself, and the charges of the notaries, admitted counsel, technical advisers, translators, insurers, banks and other providers engaged in each jurisdiction — are disbursements payable by the client to the party entitled to them, in the amount that party charges. They are not part of Kestrel Private's fee, and the fee does not rise or fall with them.

Kestrel Private applies its own acceptance standards. It may decline or defer a prospective engagement, including in the circumstances described in §13.14 and Chapter 15, and it is not obliged to give reasons for doing so.

The client is free to acquire a property from any source on the same engagement terms, and the property-without-immigration test at §8.15 applies to every property equally, whatever its source. The terms on which any particular property is presented are set out in the engagement letter before work begins (§18.1).

## O.9 Third-party sources and links

This report cites and links to legislation, judgments, government portals, institutional publications and market data produced by third parties. Kestrel Private does not control that material, is not responsible for its accuracy or availability, and does not adopt its contents beyond the specific proposition each source is cited for. Links and archived captures are access routes; the instrument identified by its gazette or case reference is the authority. Third-party material may be amended, moved or withdrawn after the access dates recorded in Appendix M.

## O.10 Forward-looking statements

Statements in this report about how programmes, markets, legislation or policy may develop are assessments made on the information available on 2 August 2026. They are inherently uncertain, they are not promises, and events may differ materially from them. Kestrel Private does not undertake to update this report.

## O.11 Distribution

This report is published from and prepared according to the standards described in Appendix N. It is not directed at any person in any jurisdiction where its publication or availability would be contrary to local law or regulation, and it is the responsibility of any person who receives it to observe any such restriction. Nothing in it is intended to constitute a financial promotion in any jurisdiction in which it would require authorisation or approval that has not been obtained.

## O.12 Copyright

© Kestrel Private, 2026. This report and its structure, analysis and compilation are the property of Kestrel Private. It may be read, quoted with attribution, and shared in its complete and unaltered form. It may not be reproduced in part in a manner that alters its meaning, and in particular no figure, right, benefit or conclusion in it may be reproduced without the conditions, limitations and risk statements attached to it in the text. The extraction of favourable statements from this report, separated from their qualifications, would misrepresent it.
