# 3. What Clients Were Really Trying to Achieve Chapter 2 records how the European Union's investor-citizenship era ended. This chapter examines the demand that has outlived it — what international families were actually seeking when they bought the former programmes, and where each of those objectives now sits in law. The demand was not marginal. The European Parliament, drawing on its research service's estimates, recorded 42,180 approved applications under investor citizenship and residence schemes in EU member states between 2011 and 2019, admitting more than 132,000 people and attracting €21.4 billion of investment, of which the citizenship arm accounted for 8,769 people and €7,497 million.[^3-1] Nor was it benign by default. The FATF and the OECD, in their joint 2023 review of such programmes, find substantial evidence of abuse: criminals have exploited these programmes to "perpetrate massive frauds and launder proceeds of crime and corruption reaching into the billions of dollars"; an applicant can acquire a passport under a different name or with slightly altered particulars, defeating database screening; portfolios of visas and citizenships can enable the evasion of travel bans and alerts; the OECD's parallel work identifies schemes that potentially pose a high risk to the integrity of the Common Reporting Standard; and many marketing agents in the sector "work with little oversight or accountability". The same review records that these programmes "attract an array of clients, many of whom have gained their assets legitimately and have benign intentions".[^3-2] Both findings are load-bearing in this report. Nor did demand end with the EU citizenship schemes: as at March 2026, Greece alone had 30,439 investor residence permits in force, together with 56,917 family-member permits — nearly two family permits for every investor permit. Nationals of China (48.4% of initial investor permits) and Türkiye (16.6%) lead that register — both visa-required nationalities for the Schengen Area.[^3-3][^3-4] The executive summary (§1.2) identifies eight objectives behind that demand, running from an additional nationality and passport, through resilience, residence, mobility, property and family objectives, to a possible future tax-residence position where the client relocates and separately qualifies. They are distinct objectives, and they do not all arise from the same legal instrument. Sections 3.1 to 3.8 examine those objectives grouped by the instrument that bears on each, rather than in the executive summary's order; one of the eight — a tangible family base that can be used if circumstances change — turns on the usability of the property component and is examined at §7.12 and §8.8–§8.10, and is noted here only where it meets the others. Section 3.9 sets out why no single programme now lawfully available to an ordinary private client delivers all of them. ## 3.1 Additional nationality Additional nationality is an objective of status, not of travel convenience: a second legal bond with a sovereign state, from which a passport, consular access and — subject to nationality law — transmission to later generations follow. Citizenship is the only component of the reference structure that is not renewal-dependent, although it can be lost on defined statutory grounds (see §6.8). In the reference structure this objective is addressed by naturalisation in São Tomé and Príncipe under Decree-Law No. 07/2025 (see Chapter 6).[^3-5] Whether the objective is available at all is determined first by the client's existing nationality law. South African citizens may, as at 2 August 2026, acquire a second citizenship without losing South African citizenship and without any prior ministerial permission: the Constitutional Court declared the automatic-loss provision of the Citizenship Act invalid from its promulgation, in a unanimous judgment of 6 May 2025 — a material change for the primary client market.[^3-6] United Kingdom law permits dual citizenship without application or permission,[^3-7] and United States citizens who naturalise abroad do not automatically lose US citizenship.[^3-8] By contrast, an Indian citizen who voluntarily acquires another citizenship ceases to be an Indian citizen upon that acquisition,[^3-9] and the People's Republic of China does not recognise dual nationality for any Chinese national.[^3-10] Other nationality laws sit between these poles — permission regimes, birth-citizen distinctions and listed-country exceptions — and §13.2 assesses each client nationality individually. The acquiring state imposes limits of its own: São Toméan law does not permit a grant of nationality to a person who already holds more than two foreign nationalities (see §6.3).[^3-11] "An additional nationality" is therefore not an objective every client can lawfully pursue, and the assessment must begin with the nationality the client already holds. ## 3.2 Passport and consular diversification Passport and consular diversification is an objective of resilience: reduced dependence on a single state for the documents and protections of ordinary life. A client whose passports, renewals and consular assistance all depend on one government carries a single point of administrative failure. A second nationality may provide an alternative document-issuing authority and a second sovereign and consular relationship — in the reference case, with a state that has been a United Nations member since 16 September 1975.[^3-12] Two limits define this objective's scope. First, the diversification value of any second passport is measured against the passport the client already holds: for nationals of the United Kingdom, the United States, the United Arab Emirates and Israel — all on the Schengen visa-exempt list[^3-4] — a São Toméan passport adds contingency value or nothing. Sections 6.13 and 6.14 address for whom the citizenship component earns its cost; §6.9 sets out the passport's own travel-access limits. Second, diversification of documents is not diversification of identity. A second passport does not change what a financial institution learns about its holder. The FATF and the OECD recommend that institutions establish at onboarding that all nationalities and passports held have been disclosed, and that where a citizenship-by-investment document is offered as proof of identity they ask for the original birth certificate and the passports held in the original identity; that is a recommendation to institutions, not a description of universal current practice. In the Union it acquires statutory force in due course: Regulation (EU) 2024/1624 requires the collection of all nationalities held, and applies from 10 July 2027.[^3-13] The citizenship component offers no confidentiality benefit, and any expectation that it might is a ground for declining the client (see §6.11 and Chapter 15). ## 3.3 Lawful access to Europe For most of the client nationalities this report addresses, short-stay travel to Europe is an administrative burden that recurs for life. Nationals of countries on Annex I of Regulation (EU) 2018/1806 — including South Africa, India, China, Türkiye, Nigeria, Pakistan, Bangladesh, Lebanon and Egypt — must hold a visa to cross the Schengen external border.[^3-4] Each application carries a fee of €90 per adult and €45 for children from six to below 12. Each also requires documentary proof of the journey's purpose, of accommodation, of sufficient means for the stay and the return, and of the intention to leave before the visa expires. Longer-validity multiple-entry visas must be earned through the Visa Code's cascade: a one-year visa only after lawful use of three visas within the previous two years, a two-year visa after lawful use of a one-year visa within the previous two years, and a five-year visa only after lawful use of a two-year visa within the previous three years.[^3-14] For a family, that apparatus repeats per person and per cycle. What clients sought from the former programmes — and still seek — is the removal of that recurring procedure. In the reference structure, this relief arises from the Greek residence permit and only from the Greek residence permit. A third-country national holding a residence permit issued by a Schengen state may, on the basis of that permit and a valid travel document, move within the other Schengen states for up to 90 days in any 180-day period, subject to the Convention's conditions.[^3-15] Days spent in Greece under the permit are not counted against that 90/180 allowance elsewhere.[^3-16] The São Toméan passport contributes nothing to this objective: São Tomé and Príncipe is itself on Annex I, so its nationals require a Schengen visa when travelling on that passport alone.[^3-4] Any presentation of the citizenship component as a source of European mobility would be false. Clients from visa-exempt states face a different friction: entry without a visa, but capped at the same 90 days in any 180-day period — British citizens, for example, have been third-country nationals for EU free-movement purposes since 1 January 2021.[^3-17][^3-4] For them the permit's value is not visa relief but the lawful long-term position described in §3.4. Short-stay mobility under a residence permit is not a right of free movement; §4.4 sets out its mechanics and limits, and §7.10 the permit-specific position. ## 3.4 A residence held in reserve A residence held in reserve is a legal position established before it is needed. The clients this report addresses are not relocating; they want the option to relocate — or simply to stay lawfully beyond a visitor's limits — held open against change at home. A reserve position must therefore be maintainable from abroad. The Greek investor residence permit fits that reserve function in defined respects. It is granted for five years and is renewable for equal periods provided the property remains in the holder's ownership and possession, and periods of absence from Greece are, by statute, no obstacle to renewal.[^3-18] The position can accordingly be established and kept current while the family's life continues elsewhere. Held in reserve does not mean accruing in reserve. Statuses that require continuous residence do not build up while the client lives abroad: EU long-term-resident status requires five years of legal and continuous residence,[^3-19] and Greek naturalisation presupposes genuine residence, examinations and Greek tax filings for the qualifying years (see §7.13).[^3-20] Nor is the reserve unconditional: the permit confers no right of access to employment, and sale of the qualifying property while the permit is valid revokes it.[^3-18] A residence held in reserve is a maintained legal position with continuing conditions — not a stored right — and its continuity depends on the legislative stability of the category itself (see §7.14). ## 3.5 Family contingency and intergenerational planning Families bought the former programmes as families. The European Parliament's figures imply more than three persons admitted per approved application,[^3-1] and the Greek register shows the same pattern today: 56,917 family-member permits alongside 30,439 investor permits as at March 2026.[^3-3] The objective is contingency for the whole household, not only the principal applicant. Each component serves that objective differently, under its own family rules. Residence permits include qualifying family members but do not outlive the sponsor's status: Greek family-member permits expire simultaneously with the sponsor's, and a child reaching 21 moves to a three-year independent permit.[^3-18] The programmes' family definitions differ materially and are examined in §6.3, §7.9 and Chapter 16; their cost consequences are modelled in Chapter 11. Only citizenship reaches the next generation. A child born abroad after a parent's São Toméan naturalisation may acquire São Toméan nationality by declaration and registration, with effect from birth, subject to the conditions of the Nationality Law — the precise mechanics, and their limits, are set out in §6.10.[^3-11] A second nationality can also widen succession planning: under Regulation (EU) 650/2012 a person possessing multiple nationalities may choose the law of any of those nationalities to govern the succession as a whole.[^3-21] That option is real but heavily qualified — it does not touch inheritance taxation, and its usefulness depends on the content of the chosen law — and §6.10 states the qualifications in full. ## 3.6 International property and currency diversification This objective is capital held outside the home jurisdiction and outside the home currency. For families whose wealth, income and property are concentrated in one country — often one whose exchange-control and transfer rules constrain how capital may leave — a euro-denominated asset in a European jurisdiction is an objective in itself, independent of any immigration benefit. The executive summary's related objective, a tangible family base that can be used if circumstances change, is a question of use rather than of capital, and is examined with the property component's usability, letting and disposal constraints at §7.12 and §8.8–§8.10. The constraint environment is verifiable. As at 2 August 2026, a South African resident individual may externalise R2,000,000 per calendar year under the single discretionary allowance — at that level since 8 April 2026 — and a further R10,000,000 per calendar year under the foreign capital allowance, routed through an Authorised Dealer and subject to a South African Revenue Service tax-compliance status verification.[^3-22] At an illustrative rate of R20 to the euro — an illustration only, not a dated market rate, and not a figure to be relied on — a single individual's combined R12,000,000 is of the order of €600,000 in a calendar year, which is the order of magnitude the reference structure requires (Chapter 10 states the costs and the report's currency assumptions). Two qualifications attach immediately. The allowances are per individual and per calendar year, so a family funding several applicants does not draw more from one person's limits. And the binding constraint is tax-compliance status rather than quantum: the foreign capital allowance depends on a verification the taxpayer must be able to obtain, and amounts above the combined R12,000,000 require prior approval.[^3-22] A mainland Chinese individual's foreign-exchange purchases are capped at US$50,000 equivalent per calendar year.[^3-23] Regimes of this kind explain the demand for externally held assets, and they simultaneously gate who can lawfully fund the structure: source-of-funds analysis comes first in every case (see Chapter 15 and §13.10). Two boundaries keep this objective honest. The structure's capital is not homogeneous: the citizenship contribution is spent, while the €250,000 property is retained but at risk — a distinction Chapter 12 makes precise (§12.1). And diversification is a motive, not an assessment of investment quality: the property must remain commercially defensible with the immigration benefit ignored, which is the test Chapter 8 applies (§8.15). Nothing in the diversification objective guarantees that the capital moved is capital preserved. ## 3.7 Banking and business optionality Banking and business optionality is the ability to hold accounts, form a company or establish a business presence outside the home jurisdiction, exercisable if and when needed. Lawful European residence changes the legal starting point for banking in one defined respect. The EU right to a basic payment account extends to consumers legally resident in the Union; a client holding the Greek permit is legally resident in a member state and may engage that right subject to its conditions, whereas a non-resident third-country national holds no such right.[^3-24] The limits are equally defined: account opening remains a risk-based decision of each institution, and Greek law obliges an institution to refuse the relationship where customer due diligence cannot be completed.[^3-25] A bank-account application is not a bank-account approval — §9.4 and §9.5 govern. Business optionality is similarly conditional. A European company can be formed, but a company does not create personal tax residence, and the corporate, substance and tax consequences belong to the optional layer (see §4.7 and Chapter 9). Within the structure itself, the Greek permit does not establish a right of access to employment, and a change-of-use property may not serve as the seat or branch of a business (see §7.11).[^3-18] The objective also has a transparency floor. Greece has undertaken automatic exchanges of financial-account information since 2017.[^3-26] An account held in Greece by a client resident for tax purposes in a reportable jurisdiction is subject to reporting under the Common Reporting Standard, where the account is a reportable account and an exchange relationship exists between the jurisdictions concerned. The structure provides options; it provides no opacity. ## 3.8 Tax-residence planning Tax-residence planning is prospective: a possible future tax-residence position where the client relocates and separately qualifies. It is treated last deliberately, because it is the objective most commonly misdescribed in this market. The demand is real and has verifiable push factors. From 6 April 2025 the United Kingdom abolished the remittance basis for non-domiciled residents, replacing it with a four-year foreign income and gains regime available only to new arrivals after 10 years of non-residence — a change that has internationally mobile UK-resident families reassessing their base.[^3-27] But a residence permit is not a tax plan. The Greek permit does not of itself create Greek tax residence. Under the Greek Income Tax Code as consistently reported by professional sources, tax residence arises from any one of several independent connecting factors: presence in Greece exceeding 183 days cumulatively in any 12-month period, in which case the person is treated as resident from the first day of that presence; or Greece being the person's permanent or main residence, habitual abode, or centre of vital interests. Any one of those factors is sufficient on its own, so a client who acquires a Greek dwelling and makes it a family base may engage the test without approaching the day count; double-taxation-treaty tie-breakers may then displace the domestic result. Section 9.6 sets out the position in full. The elective regimes for new residents require an actual transfer of tax residence with separate qualifying conditions — the investor regime, for instance, requires a €500,000 qualifying investment, which the €250,000 reference property alone does not meet. Each of these tests and figures requires confirmation at the date of application.[^3-28][^3-29] Home-country positions persist unless the client genuinely emigrates and requalifies: a United States citizen, most starkly, remains subject to US tax on worldwide income whatever documents are acquired.[^3-30] The report therefore treats tax residence as a separately assessed, optional outcome — §9.6 to §9.8 set out the law, and §13.8 the suitability questions. ## 3.9 Why no single modern programme provides every benefit The former EU programmes owed their commercial power to bundling. One grant of member-state nationality carried Union citizenship, and with it free movement and residence across the Union, access to employment, the passport, and transmission to children — every objective in this chapter, in one transaction. That is the transaction on which the Court of Justice of the European Union gave judgment: the Grand Chamber declared that Malta had failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU by establishing and operating a naturalisation scheme under which nationality is "essentially granted in exchange for predetermined payments or investments", a programme that "amounts to the commercialisation of the granting of the status of national of a Member State and, by extension, Union citizenship".[^3-31] Chapter 2 sets out that history. The bundle is no longer for sale, and nothing lawfully available reassembles it. Each instrument now delivers a subset. A non-European citizenship provides nationality, a passport, contingency and succession options — but no European residence and, for São Tomé and Príncipe, no Schengen access of any kind.[^3-4] Even where a citizenship programme's passport does carry a Schengen visa exemption, that exemption is a concession the Union can withdraw: Vanuatu's waiver was partially suspended from 4 May 2022, fully suspended from 4 February 2023 and then removed altogether by transfer to the visa-required list, on grounds arising from its investor-citizenship schemes.[^3-32] Regulation (EU) 2025/2441, adopted on 26 November 2025 and published in the Official Journal on 10 December 2025, inserted a further suspension ground into Regulation (EU) 2018/1806: the operation, by a third country listed in Annex II, of an investor citizenship scheme under which citizenship is granted in exchange for pre-determined payments or investments, without the person having any genuine link to that country. The Regulation entered into force on 30 December 2025, the twentieth day after its publication in the Official Journal, with no deferred application date.[^3-33] It reaches Annex II countries only, and São Tomé and Príncipe is on Annex I: the lever cannot apply to the citizenship component, which has no visa exemption to lose.[^3-4] Mobility resting on a purchased nationality is structurally contingent; the structure examined in this report does not rely on the citizenship component for European mobility at all (see §5.7). A residence permit, conversely, provides lawful residence and short-stay Schengen movement — but no citizenship, no vote, no employment right, and a position that stands on the retained property and on the continuity of the legislative category.[^3-18] The property is an asset, not preserved capital. The optional layer yields applications and elective regimes, never purchasable outcomes. The mapping of the eight objectives to instruments is therefore as follows. | Objective (§1.2) | Component that may principally address it | Principal conditions and limits | See | |---|---|---|---| | Additional nationality and passport | Citizenship component (Decree-Law No. 07/2025) | Home-nationality law must permit it; grant discretionary; post-grant opposition and revocation grounds | §6.7–§6.8, §13.2 | | Resilience against political, economic or personal disruption | Citizenship component | Value depends on the client's existing nationality; no European rights arise | §6.9, §6.13–§6.14 | | Lawful European residence held in reserve | Residence component (Article 100, Law 5038/2023) | Property must remain owned; no employment right; renewal and legislative-change conditions | Ch. 7 | | Easier short-stay Schengen movement | Residence component (CISA Article 21) | Up to 90 days in any 180-day period; short stays only; never from the São Tomé passport | §4.4, §7.10 | | Property and capital outside the home jurisdiction | Property component | At-risk asset; recoverability not guaranteed; funding subject to home exchange control | Ch. 8, Ch. 12, Ch. 15 | | A tangible family base | Property component, with the residence component | Usability, letting and disposal constraints; sale revokes the permit | §7.12, §8.8–§8.10 | | Business, banking and succession options | Optional layer; citizenship component for succession options | Applications, not approvals; a company creates no personal tax residence; succession choices heavily qualified | Ch. 9, §6.10 | | Possible future tax-residence position | Optional layer, with genuine relocation | Only where the client relocates and separately qualifies; the permit does not create tax residence | §9.6–§9.8, §13.8 | Objectives as listed in the executive summary (§1.2). Attributions state the component that may principally address each objective under the instruments cited in the referenced sections: Decree-Law No. 07/2025 and Lei n.º 7/2022 for the citizenship component (notes 3-5 and 3-11), Article 100 of Law 5038/2023 for the residence component (note 3-18), and Article 21 of the Convention Implementing the Schengen Agreement for short-stay movement (note 3-15). Every attribution is subject to eligibility, due diligence and government approval, and no component provides any objective in guaranteed form. No row of this table is delivered by every component, and no component delivers every row. That is the analytical foundation of the whole report: a lawful modern position must be assembled from separate instruments, established separately and assessed each on its own legal terms, and it is not — and must never be represented as — an equivalent of the EU citizenship the former market sold. A proposal presenting any single programme as answering the full set should be tested against Chapter 4's rights-attribution discipline (§4.8 catalogues the common confusions; §4.9 and Appendix A tabulate which instrument carries which right). Chapter 5 then sets out how the components are coordinated into one position. ### Notes [^3-1]: European Parliament, resolution of 9 March 2022 with proposals to the Commission on citizenship and residence by investment schemes (2021/2026(INL)), OJ C 347, 9.9.2022, p. 97, recitals citing European Parliamentary Research Service estimates for 2011–2019; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022IP0065 (accessed 2 August 2026). [^3-2]: FATF/OECD, *Misuse of Citizenship and Residency by Investment Programmes*, FATF, Paris, November 2023: Executive Summary ¶1 (legitimate clients) and ¶5 (intermediaries), ¶3 (frauds and laundering of the proceeds of crime and corruption), ¶42 (marketing agents working with little oversight or accountability), ¶67 (identity laundering), ¶79 (evasion of travel bans and alerts), ¶189 (substantial evidence of the risk of abuse) and §4.3 (OECD analysis of schemes potentially posing a high risk to the integrity of the Common Reporting Standard; the scheme count in that section is stated as at November 2023 and is not reproduced here); https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse-CBI-RBI-Programmes.pdf (accessed 2 August 2026). [^3-3]: Greece, Ministry of Migration and Asylum, monthly statistical bulletin «Νόμιμη Μετανάστευση», March 2026, Annex B, Tables 12α–17 (in Greek); https://migration.gov.gr/wp-content/uploads/2026/04/ΠΑΡΑΡΤΗΜΑ-Β_Μάρτιος_2026_ΥΜΑ-GR-Ενημερωτικό-Μάρτιος-Β-Νόμιμη-Μετανάστευση.pdf (accessed 2 August 2026). [^3-4]: Regulation (EU) 2018/1806 of the European Parliament and of the Council, Article 3(1), Article 4(1) and Annexes I and II, consolidated version of 30 December 2025; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). Annex placements must be confirmed at the date of application; the lists continue to be amended. [^3-5]: São Tomé and Príncipe, Decreto-Lei n.º 07/2025 («Regulamentação da Nacionalidade por Investimento ou Doação»), Diário da República, I Série, N.º 33, 1 August 2025, pp. 429–440 (in Portuguese); gazette facsimile at https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^3-6]: Constitutional Court of South Africa, *Democratic Alliance v Minister of Home Affairs* [2025] ZACC 8 (CCT 184/23), judgment of 6 May 2025, confirming [2023] ZASCA 97 (13 June 2023) and declaring section 6(1)(a) of the South African Citizenship Act 88 of 1995 invalid from its promulgation on 6 October 1995; https://collections.concourt.org.za/handle/20.500.12144/38508 (accessed 2 August 2026). [^3-7]: UK Government, "Dual citizenship", gov.uk; https://www.gov.uk/dual-citizenship (accessed 2 August 2026). [^3-8]: US Department of State, Foreign Affairs Manual, 7 FAM 080 (dual nationality; presumption of intent to retain; INA §349, 8 U.S.C. 1481); https://fam.state.gov/fam/07fam/07fam0080.html (accessed 2 August 2026). [^3-9]: India, The Citizenship Act, 1955, section 9(1), Ministry of Home Affairs consolidated text of 10 September 2024; https://www.mha.gov.in/sites/default/files/2024-09/TheCitizenshipAct1955_10092024.pdf (accessed 2 August 2026). [^3-10]: People's Republic of China, Nationality Law (1980), Articles 3 and 9, official National Immigration Administration English text; https://en.nia.gov.cn/n147418/n147458/c155976/content.html (accessed 2 August 2026). [^3-11]: São Tomé and Príncipe, Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República, I Série, N.º 25, 10 March 2022, Articles 2, 5, 11 and 21–22 (in Portuguese); gazette facsimile at https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^3-12]: United Nations, Member States list (São Tomé and Príncipe admitted 16 September 1975); https://www.un.org/en/about-us/member-states (accessed 2 August 2026). [^3-13]: FATF/OECD, *Misuse of Citizenship and Residency by Investment Programmes*, November 2023, ¶170 (financial institutions "should consider enhancing their policies to establish that all nationalities and passports are disclosed when onboarding a client", and should routinely request the original birth certificate and the passports held in the original identity where a citizenship-by-investment document is the proof of identity) and ¶139 (verification of place of birth and all current citizenship holdings) — recommendations to institutions, not a statement of universal practice; and Regulation (EU) 2024/1624, Article 22(1)(a) (collection of all nationalities held), which applies from 10 July 2027; https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse-CBI-RBI-Programmes.pdf and https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401624 (accessed 2 August 2026). [^3-14]: Regulation (EC) No 810/2009 (Visa Code), Articles 14, 16(1)–(2) and 24(2) and Annex II, consolidated version of 28 June 2024; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R0810-20240628 (accessed 2 August 2026). [^3-15]: Convention Implementing the Schengen Agreement, Article 21(1), as replaced by Regulation (EU) No 265/2010, Article 1(2), and amended by Regulation (EU) No 610/2013; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265 (accessed 2 August 2026). [^3-16]: Regulation (EU) 2016/399 (Schengen Borders Code), Article 6(2) (periods of stay authorised under a residence permit not taken into account in the 90/180 calculation), consolidated version of 12 October 2025; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0399-20251012 (accessed 2 August 2026). [^3-17]: EU–UK Withdrawal Agreement, Article 126 (transition period ended 31 December 2020), OJ L 29, 31.1.2020; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12020W/TXT (accessed 2 August 2026). [^3-18]: Greece, Law 5038/2023 (Immigration Code, Government Gazette A′ 81/01.04.2023), Article 100 (permit type «Β.5») — five-year duration and renewal (§4), absences no obstacle to renewal (§4), no right of access to employment (§9), resale revoking the seller's permit (§8), and the prohibition on using a change-of-use (§2γ) property as the seat or branch of a business (paragraph pin not confirmed against the gazette text; see Chapter 7) — as amended by Law 5100/2024 (Government Gazette A′ 49/05.04.2024), Article 64; family members under Article 95 §2 (title O.1 family-reunification permits, expiring simultaneously with the sponsor's) and the independent three-year permit (type O.2) on a child reaching 21. Consolidated text (codification through Law 5307/2026) via https://www.taxheaven.gr/law/5038/2023 and https://migration.gov.gr/wp-content/uploads/2025/03/Νόμος-5100_2024-κωδικοποιημένος-με-τον-5167_2024-ΦΕΚ-Α-49_5.4.2024.pdf (accessed 2 August 2026). [^3-19]: Council Directive 2003/109/EC concerning the status of third-country nationals who are long-term residents, Article 4(1); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32003L0109 (accessed 2 August 2026). [^3-20]: Greece, National Registry of Administrative Public Services (mitos.gov.gr), «Πολιτογράφηση Αλλογενών Αλλοδαπών» (naturalisation record; residence, examination, integration and tax-filing requirements), last updated 30 July 2026; https://mitos.gov.gr/index.php/ΔΔ:Πολιτογράφηση_Αλλογενών_Αλλοδαπών (accessed 2 August 2026). [^3-21]: Regulation (EU) No 650/2012 (Succession Regulation), Articles 21–23, including Article 22(1) (choice of the law of a State whose nationality the person possesses; a person possessing multiple nationalities may choose the law of any of them); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0650 (accessed 2 August 2026). [^3-22]: South African Reserve Bank, Financial Surveillance Department, Exchange Control Circular No. 6/2026, 8 April 2026 (single discretionary allowance increased to R2,000,000 per private individual per calendar year with effect from that date), https://www.resbank.co.za/content/dam/sarb/what-we-do/financial-surveillance/financial-surveillance-documents/2026/6-2026.pdf; and Currency and Exchanges Guidelines for Individuals, version of 7 January 2026, §3.6 (foreign capital allowance R10,000,000 per private individual per calendar year via an Authorised Dealer, subject to a SARS tax-compliance status verification; amounts above the combined R12,000,000 require prior Financial Surveillance approval), https://www.resbank.co.za/content/dam/sarb/what-we-do/financial-surveillance/financial-surveillance-documents/2026/Currency%20and%20Exchanges%20Guidelines%20for%20Individuals.pdf (accessed 2 August 2026). The R20/€ rate used in the text is an illustration only and carries no dated source; conversions for decision purposes must use a dated market rate. [^3-23]: State Administration of Foreign Exchange (PRC), official English Q&A confirming the US$50,000 annual individual foreign-exchange quota, 30 December 2017; https://www.safe.gov.cn/en/2017/1230/1391.html (accessed 2 August 2026). [^3-24]: Directive 2014/92/EU (Payment Accounts Directive), Article 16(2) (right to a basic payment account for consumers legally resident in the Union); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0092 (accessed 2 August 2026). [^3-25]: Greece, Law 4557/2018 (Government Gazette A′ 139/30.07.2018), Article 13 (obligation not to carry out the transaction or establish the relationship, or to terminate it, where customer due diligence cannot be completed), implementing Directive (EU) 2015/849; codified text via https://www.taxheaven.gr/law/4557/2018/article/13/view (accessed 2 August 2026). [^3-26]: OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, "Status of commitments for the automatic exchange of financial account information (AEOI)", 27 July 2026 (Greece: first exchanges 2017). The document records commitment and first-exchange status by jurisdiction; it does not establish that any particular account is reportable or that an exchange relationship exists between any two jurisdictions. https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/aeoi-commitments.pdf (accessed 2 August 2026). [^3-27]: HMRC, "Check if you can claim the 4-year foreign income and gains regime", published 6 April 2025; https://www.gov.uk/guidance/check-if-you-can-claim-the-4-year-foreign-income-and-gains-regime (accessed 2 August 2026). [^3-28]: ICLG, *Private Client Laws and Regulations 2026 — Greece* (Zepos & Yannopoulos), published 14 January 2026 (tax-residence tests under Article 4, Law 4172/2013: presence exceeding 183 days cumulatively in any 12-month period, with residence from the first day of presence; permanent or main residence; habitual abode; centre of vital interests; double-taxation-treaty tie-breakers); https://iclg.com/practice-areas/private-client-laws-and-regulations/greece/ (accessed 2 August 2026). Reported by convergent professional sources; primary gazette confirmation outstanding — the tests and figures require confirmation at the date of application. [^3-29]: Iason Skouzos TaxLaw, "The non-dom tax regime — Article 5A of the Greek Income Tax Code" (conditions including the €500,000 qualifying investment and transfer of tax residence); https://www.taxlaw.gr/en/practice-areas/tax-law/the-non-dom-tax-regime-alternative-taxation-of-foreign-source-income-of-individuals-transferring-their-tax-residence-to-greece-article-5a-of-the-greek-income-tax-code/ (accessed 2 August 2026). Reported by convergent professional sources; primary gazette confirmation outstanding — figures require confirmation at the date of application. [^3-30]: US Internal Revenue Service, "U.S. citizens and resident aliens abroad" (worldwide-income taxation; foreign-account reporting); https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad (accessed 2 August 2026). [^3-31]: Court of Justice of the European Union (Grand Chamber), judgment of 29 April 2025, *Commission v Malta*, Case C-181/23, EU:C:2025:283, operative part (failure to fulfil obligations under Article 20 TFEU and Article 4(3) TEU) and paragraphs 99–100; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181 (accessed 2 August 2026). [^3-32]: Council Decision (EU) 2022/366 of 3 March 2022 (partial suspension of the EU–Vanuatu visa waiver from 4 May 2022), OJ L 69, 4.3.2022, p. 105; Council Decision (EU) 2022/2198 of 8 November 2022 (full suspension for all Vanuatu nationals from 4 February 2023), OJ L 292, 11.11.2022, p. 47; Regulation (EU) 2025/11 of 19 December 2024 (transfer of Vanuatu to Annex I), OJ L, 14.1.2025; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D0366, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D2198 and https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0011 (accessed 2 August 2026). [^3-33]: Regulation (EU) 2025/2441 of 26 November 2025, OJ L, 10.12.2025, inserting Article 8a(1)(e) into Regulation (EU) 2018/1806 (operation, by a third country listed in Annex II, of an investor citizenship scheme under which citizenship is granted in exchange for pre-determined payments or investments, without that person having any genuine link to that third country, as a ground for suspension of a visa exemption); https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R2441 (accessed 2 August 2026). The Regulation entered into force on 30 December 2025 under its Article 2 (the twentieth day following publication in the Official Journal of 10 December 2025); it contains no deferred application provision.