# 4. Citizenship, Residence, Mobility and Tax Residence The structure examined in this report assembles rights that the former EU investor-citizenship model delivered in a single grant. Assessing it honestly requires taking those rights apart first. This chapter defines the four legal concepts on which every later chapter relies, attributes each right to the exact instrument that creates it, and examines the marketing claims that arise when that attribution is blurred. ## 4.1 Four distinct legal concepts Citizenship, immigration residence, short-stay mobility and tax residence are four different legal positions. Each arises under a different body of law, is granted or determined by a different authority, is subject to different conditions, and is lost on different grounds. None of them implies any of the others. The former EU investor-citizenship programmes obscured this. A single naturalisation decision in Cyprus, Bulgaria or Malta carried Union citizenship and, with it, residence and employment rights across the member states — one instrument, many rights. That model has ended. The Court of Justice of the European Union, in its judgment of 29 April 2025 concerning Malta, declared that a naturalisation scheme granting nationality essentially in exchange for predetermined payments or investments "amounts to the commercialisation of the granting of the status of national of a Member State and, by extension, Union citizenship", and held that Malta had failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU.[^4-1] The history is set out in Chapter 2 (see §2.4 and §2.5). The consequence for private clients is structural. No single lawful instrument now concentrates citizenship, European residence, Schengen mobility and a favourable tax position for an ordinary applicant. A lawful structure assembles these positions separately, from separate authorities, and each must be assessed on its own legal terms — the point on which the executive summary turns (see §1.3). Two further acquisitions appear in the reference structure without creating any personal legal status by themselves: property ownership (§4.5) and company formation (§4.7). Both are frequently presented in the market as if they carried immigration or tax consequences of their own. They do not. This report therefore applies a single discipline throughout: every right is attributed to exactly one legal instrument, and every limitation stays attached to the right it qualifies. Section 4.9 consolidates the attribution in matrix form; Appendix A extends it. ## 4.2 What citizenship provides Citizenship is the legal bond of nationality between an individual and a state. Its acquisition, content and loss are governed by that state's nationality law; for EU member states that competence must be exercised in compliance with EU law, but the definition of the conditions for granting nationality remains a matter for each state.[^4-1] In the reference structure the citizenship component is São Toméan nationality acquired by naturalisation under Decree-Law No. 07/2025, which implements the investment and donation ground in Article 10(2) of São Tomé and Príncipe's Nationality Law, Law No. 7/2022 (see §6.2 for the legal foundation in full).[^4-2][^4-3] Subject to eligibility, due diligence and approval, citizenship of São Tomé and Príncipe may provide: - a second nationality, indefinite in duration, subject to the loss grounds of the Nationality Law;[^4-3] - eligibility for a São Toméan passport, issued by the migration service as a separate administrative act;[^4-4] as at 2 August 2026, passport issuance to adult dependent children aged 18 and over is reported to have been placed on hold pending a revised dependency framework, and no lifting of that hold has been located (reported; requires confirmation at the date of application) — see §6.3 and §11.5;[^4-5] - an additional sovereign and consular relationship; the practical value of consular protection depends on the granting state's diplomatic network, which is limited, and is not established in this report; - family contingency, through the inclusion of qualifying dependants under the applicable rules, whose scope is narrower in the gazetted texts than in some published summaries (see §6.3);[^4-2][^4-3] - potential transmission to later generations — in São Toméan law by declaration and registration, subject to conditions, not automatically (see §6.10);[^4-3] - additional succession and personal-planning options, where the client's circumstances support them (see §6.10). The rights citizenship confers are exercisable primarily vis-à-vis the granting state. What a second citizenship does not provide is equally definite. It does not provide EU citizenship or any status in EU law. It does not provide residence, employment or establishment rights in Greece or any other member state. It does not alter the client's tax position anywhere. It does not create banking access (see §6.11). And it does not provide visa-free entry to the Schengen Area: as at 2 August 2026, on the consolidated version of 30 December 2025, nationals of São Tomé and Príncipe appear in Annex I of Regulation (EU) 2018/1806 and require a visa to cross the external borders of the member states.[^4-6] Any sentence attributing European mobility to this passport is wrong in law; the point recurs in §4.4 and §4.8 because the industry's marketing recurs to it. Nor is citizenship unconditional, and eligibility is capped before it is assessed. Nationality may not be granted to a person who already holds more than two foreign nationalities, and a naturalised citizen who later acquires a fourth nationality loses São Toméan nationality; acceptance of new applications from individuals holding three or more foreign nationalities is reported to have been placed on hold in April 2026 on the strength of that cap (reported; requires confirmation at the date of application).[^4-3][^4-5] The framework further provides for prior review by the Public Prosecutor, a six-month judicial-opposition window after acquisition, and revocation among the defined sanctions (see §6.8).[^4-2][^4-3] Finally, the value of any second citizenship is relative. It must be measured against the client's existing nationality and actual objectives, not against a generic ranking (see §6.9 and §6.13; the suitability test in §13.2 applies this). ## 4.3 What an immigration residence permit provides An immigration residence permit is a permission granted by a state, under its own immigration statute, for a third-country national to reside in its territory. Its scope, duration, conditions and revocation grounds are those the statute sets — no more. A permit is not nationality, does not mature into nationality by lapse of time alone, and remains conditional throughout its life. In the reference structure the residence component is the Greek investor residence permit (type B.5) under Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024, supported by qualifying property in the restricted €250,000 change-of-use category (Chapter 7 sets out the category in full; see §7.4).[^4-7][^4-8] The permit is granted for five years and is renewable for equal periods provided the property remains in the holder's ownership and possession; periods of absence from Greece are no obstacle to renewal.[^4-7] Under the conditions of the permit, the holder may: - reside lawfully in Greece for the permit's duration; - renew the position for successive five-year periods while the qualifying conditions continue to be met;[^4-7] - include qualifying family members, whose permits are derivative and expire with the sponsor's (see §7.9);[^4-7] - travel within the Schengen Area for short stays — the subject of §4.4; - use the permit in place of a visa at the external border, and remain outside the EES and ETIAS regimes described in §4.4. The permit does not provide: - Greek or EU citizenship, or a passport of any state; - residence in any member state other than Greece — long-term resident status under Directive 2003/109/EC requires five years of legal and continuous residence together with stable and regular resources and any integration conditions the member state imposes; those are requirements a holder who does not actually live in Greece does not accumulate, since the investor permit carries no presence condition at all;[^4-7][^4-9] - access to any form of employment in Greece (Article 100 §9);[^4-7] - political rights at any level; - automatic tax residence anywhere (§4.6); - a right to naturalisation. Under the official administrative record for Greek naturalisation, holders of the investor permit fall on the seven-year residence track, and the further requirements — examination in Greek language, history and institutions, evidenced integration and Greek tax returns for the residence years — presuppose an actual life in Greece. There is no investor fast-track to citizenship in Greek law, and naturalisation remains a discretionary state decision even where every condition is met (see §7.13).[^4-10] The permit's conditionality is as load-bearing as its rights. In the reference category, sale of the qualifying property while the permit is valid revokes the seller's permit; prohibited short-term letting carries revocation and a €50,000 administrative fine (see §7.12 and §7.14).[^4-7][^4-8] A residence permit is best understood as a renewable, revocable licence whose continuation the holder must keep earning by satisfying its conditions. ## 4.4 What Schengen mobility means in practice A residence permit issued by a Schengen state generally allows its holder to travel to other Schengen states for up to 90 days in any 180-day period. That sentence, and the rights behind it, come from one instrument: Article 21 of the Convention Implementing the Schengen Agreement (CISA), as replaced by Regulation (EU) No 265/2010 and amended by Regulation (EU) No 610/2013. A third-country national holding a valid residence permit issued by a member state may, on the basis of that permit and a valid travel document, move freely for up to 90 days in any 180-day period within the territories of the other member states, subject to conditions.[^4-11][^4-12] The conditions are those of the Schengen Borders Code: a valid travel document (valid for at least three months after the intended departure and issued within the previous 10 years); the ability to justify the purpose of stay and sufficient means of subsistence; absence of a threat to public policy, internal security, public health or international relations; and absence from the national alert list of the state concerned.[^4-13] The permit substitutes for a visa at the external border, and the Greek investor permit qualifies: it is issued as a stand-alone document in the EU uniform format under Regulation (EC) No 1030/2002, with an electronic storage medium, and is therefore a residence permit within the meaning of the Borders Code.[^4-14][^4-15] Four mechanical points define what the right is worth in practice: - **Counting.** The entry date counts as the first day of stay and the exit date as the last; and "periods of stay authorised under a residence permit or a long-stay visa shall not be taken into account in the calculation".[^4-13] Days spent in Greece under the permit do not consume the 90/180 allowance for the rest of the area. - **The floor.** Even where the short-stay conditions are not all met, a permit holder must be authorised to enter other member states for transit to the issuing state, unless subject to a national no-entry alert — the holder can always return to Greece through the area.[^4-13] - **The ceiling.** Article 21 confers short-stay presence and nothing else. It confers no employment, establishment or long-stay right in any other member state; stays beyond 90/180 require that state's own visa or permit. Nor is this EU free movement: Directive 2004/38/EC applies to Union citizens who move between member states and their family members, and a Greek investor-permit holder is not a beneficiary.[^4-16] - **Residual formalities.** A member state may require aliens entering its territory to report their presence on entry or within three working days; whether it does varies by member state — Belgium, for example, operates such declarations.[^4-12][^4-17] The area within which the right operates comprises, as at 2 August 2026, 29 countries: 25 EU member states plus Iceland, Norway, Switzerland and Liechtenstein. Bulgaria and Romania became full members on 1 January 2025. Ireland has opted out and operates its own visa and border policy.[^4-18] Cyprus participates in Schengen cooperation but is not yet part of the area without internal border controls; it separately recognises residence permits issued by Schengen states, under Decision No 565/2014/EU (Article 2(1)(c)), so that their holders do not require a Cyprus short-stay visa for stays up to 90 days in any 180-day period — but that concession does not extend to nationals of Türkiye or Azerbaijan, unless they are family members of an EU citizen, and days spent in Cyprus count against a separate Cypriot limit, not the Schengen allowance (see §7.10).[^4-19][^4-20][^4-21] Two newer border systems now frame the practice. The Entry/Exit System (EES) began progressive operations on 12 October 2025 and has been fully operational at all external border crossing points since 10 April 2026; the EES Regulation does not apply to holders of residence permits within the meaning of the Borders Code other than those covered by Article 2(3)(a) and (b), nor to holders of long-stay visas, and Commission guidance confirms that residence-permit holders of EES-operating countries are exempt.[^4-22][^4-23] ETIAS, the travel-authorisation system for visa-exempt nationals, 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.[^4-24][^4-25] 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.[^4-24][^4-6] The visa baseline the permit replaces is worth stating briefly. Without a permit, a visa-required national applies under the Visa Code for each trip or multiple-entry visa: a fee of EUR 90 per adult application, documentation of purpose, accommodation, means and the intention to leave, biometrics, and a discretionary decision, with longer-validity multiple-entry visas earned only through the cascade of prior compliant use.[^4-26] The permit removes that apparatus for short stays throughout the area — a genuine, citable convenience, which must nonetheless not be described as a right of free movement. Two caveats keep the description honest. First, internal border controls can return: the Borders Code permits temporary reintroduction as a last resort, and as at 2 August 2026 Germany, France, Austria, Italy, the Netherlands, Norway, Poland and Sweden have notified controls for stated periods during 2026.[^4-13][^4-27] The Article 21 right is unaffected, but document checks at internal borders do occur, and "borderless" language overstates the position. Second — the pairing point. Article 21 requires the permit and "a valid travel document". No EU instrument requires that travel document to be the passport against which the permit was issued; but the uniform-format card records the holder's nationality as a mandatory printed field, border checks examine the travel and residence documents together, and the only published national matching standard located — Belgium's official border guidance — requires that "the following 5 identity parameters have to match 100% between the travel document and the residence permit: Name, First Name, Sex, Date of Birth and Nationality", failing which travel with that combination is stated not to be possible, with an express dual-national example.[^4-11][^4-15][^4-21][^4-17] The practical consequence for the reference structure: a client whose Greek permit was issued against the original passport cannot rely on presenting the São Tomé passport with it. Short-stay travel should be planned on the passport whose identity data, including nationality, match the permit; whether and how Greece would re-issue a permit against a newly acquired second nationality is not addressed in any published rule and requires confirmation by Greek counsel at engagement. The documentary mechanics are treated in §7.10, and the consolidated mobility position in §19.4. Throughout every variant of that analysis, one attribution holds: the mobility belongs to the permit, never to the passport. For each client nationality this report names, the position is the same. Nationals of Annex I states — South Africa, India, China, Nigeria and Türkiye among them — gain no Schengen access from a São Tomé passport, because both passports are visa-required; nationals of Annex II states — the United Kingdom (British citizens; the Annex II entry excludes British nationals as referred to in Part 3 of that Annex), the United States, the United Arab Emirates and Israel among them — already hold visa-free short-stay access on their existing passports.[^4-6] Annex status is amended from time to time and must be confirmed at the date of application. In either case, whatever Schengen mobility the structure delivers is delivered by the Greek permit. ## 4.5 What property ownership provides Ownership of Greek immovable property is a property right, acquired by notarial deed and registration and held under Greek civil law. In the reference category the applicant must hold full ownership and possession of one property with a minimum acquisition value of €250,000 (see §7.4 and §7.6).[^4-7] What ownership provides is the asset itself. The client holds registered title; may let the property on a long-term basis, which Article 100 expressly permits for this category; may pass it on death, subject to Greek inheritance tax on Greek-situs property regardless of the nationality or residence of deceased and heir; and may sell it, with the permit consequence noted below.[^4-7][^4-28] Ownership also brings obligations that run with the asset irrespective of where the owner lives: a Greek tax number is a practical precondition of purchase, and annual holding taxes (ENFIA), municipal charges and filing obligations follow the deed (see §8.12 and §9.10).[^4-29][^4-30] What ownership does not provide is any personal legal status. It confers no right of residence: a person who buys Greek property and never applies for a permit holds an asset and nothing more. Ownership is a qualifying condition of the investor permit, not a residence right in itself. It confers no mobility, no employment right, no tax residence and no non-dom status. In this category it also carries statutory restraints: short-term letting and sub-letting are prohibited, on pain of revocation of the permit and a €50,000 fine, and the property may not serve as the seat or branch of a business.[^4-7][^4-8] The property's two functions — immigration condition and investment asset — are joined at exactly one point, and it is a point of risk rather than comfort: in this category, sale of the qualifying property while the permit is valid revokes the permit.[^4-7] The client therefore holds an asset whose disposal costs the family its residence position, on top of ordinary market, legal and liquidity risk. Whether the property would be worth buying if it carried no immigration benefit is the central test of Chapter 8 (see §8.15); what "retained capital" does and does not mean is the subject of Chapter 12 (see §12.3). ## 4.6 What tax residence requires Tax residence is a fiscal status determined by each jurisdiction's domestic law, and, where two jurisdictions both claim it, by treaty tie-breakers. It is distinct from immigration residence. A permit is a permission to be present; tax residence is a conclusion drawn from facts — chiefly presence, home and the centre of a person's interests. The residence tests below are taken from the codified text of Article 4 of Law 4172/2013; the elective-regime conditions and the summary of how residents and non-residents are taxed rest on professional summaries of the governing statutes and remain subject to confirmation against the gazetted text at the date of application (Chapter 9 treats the regime in detail). Under Article 4 of the Greek Income Tax Code, an individual becomes Greek tax resident on presence exceeding 183 days cumulatively in any twelve-month period, or where Greece is the permanent or main residence, the habitual abode or the centre of vital interests.[^4-31] Greek tax residence brings taxation of worldwide income; non-residents are taxed on Greek-source income only, as reported.[^4-32] Three consequences matter for the structure: - The residence permit does not create tax residence. The permit carries no minimum-stay requirement, and a holder who remains below the day threshold, keeps a permanent home and habitual abode outside Greece and retains the centre of vital interests abroad may not become Greek tax resident; that conclusion is drawn from facts, is tested year by year, and is subject to the tie-breaker provisions of any applicable double-tax convention and to confirmation by Greek tax counsel.[^4-7][^4-31] This report models a non-relocating client on that assumption; it is an assumption of the model, not a statement of any client's position. - Tax obligations arise without tax residence. The property makes the client a Greek taxpayer for the asset: tax on any rental income, holding taxes and, on death, inheritance tax on the Greek property (see §9.10).[^4-32][^4-28] - Relocation reverses the analysis. A client who genuinely moves to Greece may become taxable there on worldwide income, and only then do the elective regimes arise. The alternative-taxation regime for investors (Article 5A) requires, as reported, non-Greek tax residence in seven of the eight preceding years, a qualifying Greek investment of €500,000 — the €250,000 reference property is half that amount — and an annual flat tax of €100,000 for at most 15 years, on application and subject to revocation.[^4-33] None of the regimes is available to a non-resident, and none is engaged by property purchase or by the permit itself (see §9.6–§9.8). The home-country half of the analysis is equally fixed. Home liability continues under the client's own law until the client genuinely emigrates and separately requalifies; the United States, exceptionally, taxes on the basis of citizenship itself, so for a US citizen neither the Greek permit nor a further nationality changes the citizenship basis of US federal taxation. The Greek property, the permit and any Greek account do create additional US reporting and foreign-tax-credit consequences, on which US counsel must advise (see §9.12).[^4-34] Client-jurisdiction positions are examined in §9.12 and §13.2. Citizenship, for its part, is tax-inert almost everywhere. São Toméan personal taxation is reported by secondary sources to be residence-based, with no taxation by reason of citizenship alone; this rests on secondary material and requires confirmation at the date of application.[^4-35] Financial-account reporting under the OECD Common Reporting Standard is keyed to the account holder's jurisdictions of tax residence, not citizenship;[^4-36] São Tomé and Príncipe has made no CRS commitment as at the Global Forum's status document of 27 July 2026,[^4-37] and acquiring its citizenship neither creates a reportable residence nor removes one. A Greek account opened by a non-resident client is reportable by the Greek bank to each of the client's jurisdictions of tax residence with which Greece has an activated exchange relationship — Greece has exchanged under the CRS since 2017; the United States exchanges under FATCA rather than the CRS, and a jurisdiction that has made no CRS commitment receives nothing under it.[^4-37][^4-36][^4-34] ## 4.7 What company formation does—and does not—achieve A company is a separate legal person. Forming one creates a vehicle — for holding assets, contracting, invoicing and, where the facts support it, conducting a business. In the reference structure the company is part of the optional layer only (Chapter 9; see §9.2), and its honest description is professional establishment, not the purchase of any status. What company formation does not achieve is the list that matters: - It does not of itself confer personal tax residence on the owner. Personal residence is determined by the individual's own presence, home and centre of interests under each jurisdiction's own law (§4.6). Where a jurisdiction's residence test refers to office-holding or business activity, company involvement is one factual element among several, not a substitute for the test. - It does not confer immigration status. Owning a Greek, Cypriot or other EU company gives the owner no right to reside or work in the EU; and in the reference category the qualifying property may not be used as the company's seat or branch.[^4-7] - It does not of itself produce a low-tax result. Under Article 4 of the Greek Income Tax Code, a legal person is Greek tax resident if its place of effective management is in Greece at any time in the year, judged on facts including day-to-day management and the directors' residence.[^4-31] The substance warning runs the reverse of the sales pitch: a company cannot give its owner tax residence, but an owner managing a foreign company from Greece can give the company Greek tax residence.[^4-31] - It does not escape the owner's home system. Attribution regimes — such as South Africa's controlled-foreign-company rules — can tax the company's income in the owner's hands regardless of where the company sits (see §9.14).[^4-38] - It does not deliver banking. A bank-account application, personal or corporate, is a compliance decision of the institution: under Greek anti-money-laundering law an institution that cannot complete customer due diligence must refuse or terminate the relationship, and nothing obliges acceptance into a private- or corporate-banking relationship.[^4-39] Separately, a consumer legally resident in the Union may claim a basic payment account under Article 16 of Directive 2014/92/EU, subject to that Directive's conditions and to the anti-money-laundering refusal grounds; a basic payment account is not a banking relationship of the kind these structures are usually sold with (see §9.4 and §9.5).[^4-40][^4-39] A company can still be worth forming — for administration, letting, liability or succession reasons assessed on their own merits (§9.2, §9.16). What it can never honestly be sold as is a residence, tax or banking status. ## 4.8 Common marketing claims that confuse these rights The claims below are composites of formulations that recur across the investment-migration market. None is attributed to any firm. Each fails in the same way: it takes a right created by one instrument and implies it flows from another. **"An EU passport in five years."** This confuses a residence permit with an entitlement to naturalisation. The Greek investor permit confers residence, not nationality, and no lapse of time converts one into the other; investor-permit holders fall on the seven-year residence track, whose substantive requirements presuppose an actual, taxable life in Greece (§4.3).[^4-10] A holder who uses the permit as a mobility instrument while living elsewhere does not accumulate what the citizenship file requires; naturalisation remains a discretionary state decision; and since the Court's judgment of 29 April 2025 no member state may lawfully operate a transactional citizenship scheme.[^4-10][^4-1] What is true: long-term residence, genuinely lived, is the established route by which most families may in time reach an EU citizenship — as an assessment-based possibility, never a product with a date (see §7.13 and §2.7). **"Visa-free Europe with your new passport."** This confuses the passport with the permit, and short-stay presence with residence. In the reference structure the claim is simply false: São Tomé and Príncipe is a visa-required (Annex I) state, and every Schengen right the structure delivers arises from the Greek permit under CISA Article 21 (§4.4).[^4-6][^4-11] Where the claim is made for visa-exempt CBI states, it conflates three further things. A visa waiver is short-stay presence only — up to 90 days in any 180-day period, with no residence or work rights.[^4-6] It belongs to the country, not the holder: the EU may suspend a third country's exemption, and since Regulation (EU) 2025/2441 the operation of an investor-citizenship scheme granting nationality for predetermined payments without a genuine link is itself a ground for suspension.[^4-41] And the precedent is concrete: Vanuatu's exemption was partially suspended in 2022, fully suspended in 2023, and the country was moved to the visa-required list in early 2025 — a mobility loss suffered by every holder of its passport, caused solely by its citizenship programme.[^4-42] The permit-based mobility in the reference structure is an individual title under EU law, subject to its own distinct risk — the continuity of the Greek category itself, treated at §7.14 and §14.1. **"Tax-free residency."** This confuses an immigration permission with a fiscal status, and a special regime with an exemption. The Greek permit neither creates tax residence nor removes any liability: a non-relocating holder remains taxable where he was, and a genuinely relocating holder becomes taxable in Greece on worldwide income (§4.6).[^4-31] The elective regimes are neither automatic nor free — the investor regime consists of paying a flat tax of €100,000 each year, for at most 15 years, after satisfying prior-non-residence and €500,000 investment conditions the €250,000 reference property does not meet.[^4-33] It is a tax, not an exemption. Greek-source income is taxed in every case, the property generates Greek tax obligations regardless of residence (§4.5), and account reporting continues to run on tax residence throughout.[^4-32][^4-36] Three further confusions recur and can be dealt with briefly. **"A second passport for financial privacy."** CRS reporting is keyed to tax residence, not citizenship; the self-certification a client signs at onboarding asks for all jurisdictions of tax residence and is unaffected by an additional passport, and institutions may not rely on a self-certification they have reason to know is incorrect.[^4-36] A new citizenship changes nothing in this mechanism for a client who remains resident where he was — and using citizenship documents to misdescribe tax residence is precisely the abuse the OECD's guidance targets (see §6.11 and §15.12). **"The €250,000 remains yours — capital preserved."** Ownership is real; preservation is not promised by anyone. Retained capital is at-risk capital: Bank of Greece indices record a nominal fall of 42.4% in national apartment prices from 2008 to 2017, and 44.7% in Athens, across nine consecutive negative years;[^4-43][^4-44] and in this category a sale during the permit's validity revokes the permit, so the exit itself carries an immigration cost.[^4-7] Ownership is a property right; value, liquidity and income are market outcomes (see §8.15, §12.3 and §12.10). **"One application covers the family, permanently."** A principal's rights are not the family's rights. Greek family permits are derivative and expire with the sponsor's; a child reaching 21 moves to a three-year independent permit.[^4-7] On the citizenship side, the decree's dependant definition is narrower than some published summaries suggest, adult-dependant passport issuance is reported to be on hold (§4.2), and transmission to children born later is by declaration, subject to conditions.[^4-2][^4-3][^4-5] Family scope and its costs are examined in Chapters 11 and 16 (see §11.5 and §11.9). The correction across all six claims is one sentence long: two separate programmes do not become EU citizenship, EU-wide rights or a tax status when they are packaged together. Which is why this report prices, assesses and stress-tests each instrument separately (see §5.8 and §20.1). ## 4.9 Rights and limitations matrix The matrix consolidates this chapter. The columns are the four instruments a client of the reference structure can actually hold: the second citizenship, the Greek residence permit, the Greek property and — only where separately established by facts and election — Greek tax residence. Schengen mobility is deliberately a row, not a column: it is not a free-standing status but an effect of exactly one instrument, the permit. Company formation is omitted as a column because a company is a separate legal person and confers no personal status on its owner (§4.7). Appendix A extends this matrix across the full structure. | Right or attribute | São Tomé citizenship | Greek residence permit | Greek property ownership | Greek tax residence | |---|---|---|---|---| | Legal source | Decree-Law No. 07/2025 with Law No. 7/2022[^4-2][^4-3] | Article 100, Law 5038/2023, as amended[^4-7][^4-8] | Notarial deed and registration under Greek civil law (see §7.6) | Article 4, Law 4172/2013[^4-31] | | Passport and travel document | Yes — eligibility for the São Toméan passport, with the reported adult-dependant hold (§4.2)[^4-4][^4-5] | No — the permit must accompany a valid travel document[^4-11] | No | No | | Residence in Greece | No | Yes — under the conditions of the permit[^4-7] | No — ownership confers no immigration status | No — a fiscal status, not a permission | | Employment in Greece | No | No — Article 100 §9[^4-7] | No | No — the status authorises nothing | | Short-stay Schengen mobility (up to 90 days in any 180-day period) | No — Annex I, visa required[^4-6] | Yes — CISA Article 21, subject to its conditions[^4-11] | No | No | | Residence or work in other EU states | No | No — short-stay presence only[^4-11][^4-16] | No | No | | Political rights | In São Tomé and Príncipe, as provided by its law (not examined in this report); none in any EU member state | None | None | None | | Bank account | No right to an account; from 10 July 2027 EU onboarding rules require collection of all nationalities held[^4-39][^4-45] | No right to a private- or corporate-banking relationship; a consumer legally resident in the Union may claim a basic payment account under Directive 2014/92/EU Art. 16, subject to its conditions and to the anti-money-laundering refusal grounds (see §9.4 and §9.5)[^4-40][^4-39] | None | None | | Tax consequences | None of itself; São Toméan taxation reported residence-based (requires confirmation); CRS position unchanged[^4-35][^4-36] | None of itself — no automatic tax residence[^4-31] | Greek obligations attach to the asset: holding taxes, tax on rental income, inheritance tax on Greek-situs property[^4-29][^4-28] | Greek taxation of worldwide income; elective regimes only where separately qualified[^4-32][^4-33] | | Transmission to descendants | Potential — by declaration and registration under the Nationality Law, subject to its conditions (see §6.10)[^4-3] | None — family permits are derivative and expire with the sponsor's; a child at 21 receives a three-year independent permit[^4-7] | The asset is heritable, subject to Greek inheritance tax[^4-28] | Not transmissible | | Duration | Indefinite, subject to defined loss grounds and the six-month judicial-opposition window (see §6.8)[^4-2][^4-3] | Five years, renewable while ownership and conditions continue[^4-7] | Indefinite, subject to obligations and market risk (Chapter 8) | Determined year by year on the facts; the Article 5A regime is limited to 15 years[^4-31][^4-33] | | Principal loss triggers | Fraud, security grounds, acquisition of a fourth nationality; judicial opposition within six months[^4-3][^4-2] | Sale of the qualifying property; prohibited letting; failure of conditions[^4-7] | Sale, enforcement or market events — and a sale during the permit's validity revokes the permit[^4-7] | Change of facts; regime revocation on non-payment or failure of the qualifying investment[^4-33] | Cells state the general legal position as at 2 August 2026 for a third-country-national client of the reference structure; every affirmative cell is subject to the conditions of the instrument cited. The Greek tax column states the statutory residence tests from the codified text of Article 4 of Law 4172/2013, while the elective-regime conditions and the resident/non-resident split rest on professional summaries pending gazette confirmation (§4.6). Sources: the notes to this chapter; the matrix is the seed of Appendix A. Three readings of the matrix carry the chapter's weight. First, the mobility row contains exactly one affirmative cell — the permit's. Second, no cell in any column reaches EU citizenship, an EU passport, or residence and employment across the Union: those rights are not available within this structure at any price (see §19.8). Third, holding all four columns at once merges nothing: each instrument keeps its own authority, conditions and failure modes, which is why the components are assessed separately throughout this report (see §5.7 and §5.8) and why the suitability question is asked instrument by instrument (Chapter 13). ### Notes [^4-1]: 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, paragraphs 96–102 and operative part; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181 (accessed 2 August 2026). [^4-2]: 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), in particular Articles 3, 10, 14 and 18; gazette facsimile via https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^4-3]: São Tomé and Príncipe, Lei n.º 7/2022 ("Lei da Nacionalidade"), Diário da República, I Série, N.º 25, 10 March 2022 (in Portuguese), in particular Articles 5, 10–11, 15–16 and 19–21 (Article 11(1)–(2): no grant to a person already holding more than two foreign nationalities; loss on acquisition of a fourth); facsimile via https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^4-4]: São Tomé and Príncipe, Serviço de Migração e Fronteiras, official site (passport issuance; electronic-passport PKI certificates), https://www.smf.st/ (accessed 2 August 2026). [^4-5]: IMI Daily, "São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule", 11 April 2026 (Citizenship by Investment Unit director's memorandum of 10 April 2026: hold on new applications from individuals holding three or more foreign nationalities; hold on passport issuance for adult dependent children aged 18 and over pending a revised dependency framework), https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/; corroborated by NTL International, "São Tomé and Príncipe CBI 2026 legislative updates", 14 April 2026, https://ntlinternational.com/press/sao-tome-and-principe-cbi-2026-legislative-updates (both accessed 2 August 2026; the memorandum itself is not public — reported, requires confirmation at the date of application). [^4-6]: Regulation (EU) 2018/1806 (listing the third countries whose nationals must be in possession of visas), consolidated version of 30 December 2025, Article 3(1), Article 4(1), Annexes I and II (the Annex II entry for the United Kingdom excludes British nationals as referred to in Part 3 of that Annex); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^4-7]: Greece, Law 5038/2023 (Immigration Code, Government Gazette A′ 81/01.04.2023), Articles 95, 100 and 171, as amended by Article 64 of Law 5100/2024; consolidated text (codified through Law 5307/2026) via https://www.taxheaven.gr/law/5038/2023 (in Greek) (accessed 2 August 2026). [^4-8]: Greece, Law 5100/2024 (Government Gazette A′ 49/05.04.2024), Article 64; official consolidated PDF (with Law 5167/2024) via https://migration.gov.gr/wp-content/uploads/2025/03/Νόμος-5100_2024-κωδικοποιημένος-με-τον-5167_2024-ΦΕΚ-Α-49_5.4.2024.pdf (in Greek) (accessed 2 August 2026). [^4-9]: Council Directive 2003/109/EC concerning the status of third-country nationals who are long-term residents, Articles 4(1), 5 and 13; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32003L0109 (accessed 2 August 2026). [^4-10]: Greece, National Registry of Administrative Public Services (mitos.gov.gr), "Πολιτογράφηση Αλλογενών Αλλοδαπών" (naturalisation of foreign nationals; residence tracks including the seven-year track for investor-permit holders; examination and integration requirements), record last updated 30 July 2026; https://mitos.gov.gr/index.php/ΔΔ:Πολιτογράφηση_Αλλογενών_Αλλοδαπών (in Greek) (accessed 2 August 2026). [^4-11]: Convention Implementing the Schengen Agreement, Article 21(1), as replaced by Regulation (EU) No 265/2010 of 25 March 2010, Article 1(2); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265 (accessed 2 August 2026). [^4-12]: Regulation (EU) No 610/2013 of 26 June 2013 (substituting "90 days in any 180-day period" across the Schengen acquis; replacing CISA Article 22), Article 2; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0610 (accessed 2 August 2026). [^4-13]: Regulation (EU) 2016/399 (Schengen Borders Code), consolidated version of 12 October 2025, Articles 2(16), 6(1), 6(2), 6(5)(a) and 25–29; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0399-20251012 (accessed 2 August 2026). [^4-14]: Greece, Law 5038/2023, Article 14 §§1–2 (residence permits issued as stand-alone uniform-format documents with electronic storage medium); gazette facsimile of Government Gazette A′ 81/01.04.2023 via https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf, cross-checked against the consolidated text (codified through Law 5307/2026) at https://www.taxheaven.gr/law/5038/2023 (in Greek) (accessed 2 August 2026). [^4-15]: Regulation (EC) No 1030/2002 laying down a uniform format for residence permits, consolidated version of 21 November 2017, Articles 1 and 4a; and Regulation (EU) 2017/1954, Annex (mandatory card entries including "8. Nationality."); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002R1030-20171121 and https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R1954 (accessed 2 August 2026). [^4-16]: Directive 2004/38/EC on the right of citizens of the Union and their family members to move and reside freely within the territory of the Member States, Articles 2(1) and 3(1), consolidated version; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004L0038-20110616 (accessed 2 August 2026). [^4-17]: Belgian Immigration Office (IBZ), "Visa-free travel with residence permits — general principles" (reporting declarations on entry; the five identity parameters, including nationality, that must match 100% between travel document and residence permit), https://dofi.ibz.be/en/themes/entry/border-control/visa-free-residence-permits/general-principles (accessed 2 August 2026). [^4-18]: European Commission (DG HOME), "Schengen area" (composition of 29 countries; Bulgaria and Romania from 1 January 2025; status of Cyprus and Ireland), https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area_en (accessed 2 August 2026). [^4-19]: Decision No 565/2014/EU of the European Parliament and of the Council of 15 May 2014, Articles 1, 2(1)(c) and 5; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014D0565 (accessed 2 August 2026). [^4-20]: High Commission of the Republic of Cyprus in the United Kingdom, Visa Information (application of Decision No 565/2014/EU; exception for nationals of Türkiye and Azerbaijan "unless they are family members of an EU citizen"), https://cyprusinuk.com/visa-information/ (accessed 2 August 2026). [^4-21]: European Commission, Practical Handbook for Border Guards (2022 edition), Second Part, Section I, points 3.6–3.7 and p. 74 with footnote 83 (entry-check mechanics; separate Cyprus calculation; one-way recognition), https://home-affairs.ec.europa.eu/system/files/2022-11/Practical%20handbook%20for%20border%20guards_en.pdf (accessed 2 August 2026; the 2022 edition is cited only for points unaffected by later accessions). [^4-22]: Regulation (EU) 2017/2226 (Entry/Exit System), consolidated version of 12 June 2026, Article 2(3)(c) — which excludes holders of residence permits "other than those covered by points (a) and (b)" — and Article 2(3)(e); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R2226-20260612 (accessed 2 August 2026). [^4-23]: European Commission, "The Entry Exit System is fully operational since 10 April 2026. Who is exempt?", news item of 27 July 2026, https://home-affairs.ec.europa.eu/news/entry-exit-system-fully-operational-10-april-2026-who-exempt-2026-07-27_en (accessed 2 August 2026). [^4-24]: Regulation (EU) 2018/1240 (ETIAS), consolidated version of 12 June 2026, Article 2(1) and 2(2)(d)–(f); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1240-20260612 (accessed 2 August 2026). [^4-25]: eu-LISA, ETIAS activity page ("ETIAS is currently not in operation and no applications for travel authorisations are collected at this point"), https://www.eulisa.europa.eu/activities/large-scale-it-systems/etias (accessed 2 August 2026). [^4-26]: Regulation (EC) No 810/2009 (Visa Code), consolidated version of 28 June 2024, Articles 14, 16(1)–(2) and 24(2) and Annex II; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R0810-20240628 (accessed 2 August 2026). [^4-27]: European Commission, "Temporary reintroduction of border control" (current notifications, as at 2 August 2026), https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area/temporary-reintroduction-border-control_en (accessed 2 August 2026). [^4-28]: Greece, Law 2961/2001 (Inheritance and Gift Tax Code), Article 3 (Greek-situs property within scope regardless of nationality or residence), consolidated text via https://www.taxheaven.gr/law/2961/2001/article/3/view (in Greek) (accessed 2 August 2026). [^4-29]: PwC, Worldwide Tax Summaries — Greece (Individual: other taxes, including ENFIA; last reviewed 16 February 2026), https://taxsummaries.pwc.com/greece (accessed 2 August 2026). [^4-30]: AADE (Greek Independent Authority for Public Revenue), "Issuance of Tax Identification Number… and appointment of tax representative" (non-residents), https://www.aade.gr/en/greeks-abroad-non-residents/registration-tax-register/issuance-tax-identification-number-and-authentication-key-and-appointment (accessed 2 August 2026). [^4-31]: Greece, Law 4172/2013 (Income Tax Code), Article 4 — Article 4(1)–(2) (individual tax residence: permanent or main residence, habitual abode, centre of vital interests; presence exceeding 183 days cumulatively in any twelve-month period) and Article 4(3)(c) and 4(4) (place of effective management of a legal person); codified text via https://www.taxheaven.gr/law/4172/2013/article/4/view (in Greek) (accessed 2 August 2026). [^4-32]: ICLG, Private Client Laws and Regulations 2026 — Greece (Zepos & Yannopoulos), published 14 January 2026 (taxation of residents on worldwide income and of non-residents on Greek-source income; Greek-situs inheritance tax), https://iclg.com/practice-areas/private-client-laws-and-regulations/greece/ (accessed 2 August 2026; professional summary — gazette confirmation outstanding, see §4.6). [^4-33]: Iason Skouzos TaxLaw, "The non-dom tax regime… Article 5A of the Greek Income Tax Code" (conditions including the €500,000 investment; €100,000 annual flat tax; 15-year maximum; revocation), 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; professional summary — gazette confirmation outstanding, see §4.6). [^4-34]: US Internal Revenue Service, "U.S. citizens and resident aliens abroad" (worldwide-income taxation; foreign financial account reporting, FinCEN Form 114), https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad (accessed 2 August 2026). [^4-35]: Immigrant Invest, "Taxes in São Tomé and Príncipe" (residence-based personal taxation; sole located secondary source — requires confirmation at the date of application), https://immigrantinvest.com/blog/sao-tome-and-principe-taxes/ (accessed 2 August 2026). [^4-36]: OECD, "Residence/citizenship by investment schemes" (CRS keyed to tax residence; financial institutions may not rely on self-certifications they have reason to know are incorrect), https://www.oecd.org/en/topics/sub-issues/international-standards-on-tax-transparency/residence-citizenship-by-investment.html (accessed 2 August 2026 via archived capture of 26 July 2026). [^4-37]: OECD Global Forum, "Status of commitments for the automatic exchange of financial account information (AEOI)", document of 27 July 2026 (Greece first exchanges 2017; São Tomé and Príncipe absent from every cohort), https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/aeoi-commitments.pdf (accessed 2 August 2026). [^4-38]: The Tax Faculty and BDO South Africa on section 9D of the Income Tax Act 58 of 1962 (controlled-foreign-company imputation; high-tax exemption at 67.5%), https://taxfaculty.ac.za/news/read/comparable-tax-exemption-section-9d-2a and https://www.bdo.co.za/en-za/insights/2025/tax/enjoying-the-high-tax-exemption-with-your-controlled-foreign-company (accessed 2 August 2026). [^4-39]: Greece, Law 4557/2018 (anti-money-laundering law, Government Gazette A′ 139/30.07.2018), Article 13 (obligation to refuse or terminate where customer due diligence cannot be completed), consolidated text via https://www.taxheaven.gr/law/4557/2018/article/13/view (in Greek) (accessed 2 August 2026). [^4-40]: Directive 2014/92/EU (Payment Accounts Directive), Articles 2(2) and 16(2) (right to a basic payment account for consumers legally resident in the Union, subject to its conditions), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0092 (accessed 2 August 2026). [^4-41]: Regulation (EU) 2025/2441 of 26 November 2025 (revised visa-suspension mechanism; new Article 8a(1)(e) of Regulation (EU) 2018/1806 — investor-citizenship schemes as a suspension ground), OJ of 10 December 2025; https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R2441 (accessed 2 August 2026). [^4-42]: Council Decision (EU) 2022/366 of 3 March 2022 (partial suspension of the EU–Vanuatu visa waiver from 4 May 2022), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D0366; Council Decision (EU) 2022/2198 of 8 November 2022 (full suspension from 4 February 2023), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D2198; Regulation (EU) 2025/11 of 19 December 2024 (transfer of Vanuatu to Annex I), OJ of 14 January 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0011 (all accessed 2 August 2026). [^4-43]: Bank of Greece apartment-price index (national), as republished by the Bank for International Settlements, series QGRN628BIS (peak Q3 2008 to trough Q3 2017, computed −42.4% nominal), https://fred.stlouisfed.org/graph/fredgraph.csv?id=QGRN628BIS (accessed 2 August 2026). [^4-44]: Bank of Greece, "New Index of Apartment Prices by Geographical Area" (Athens series, file version 25 November 2025; peak Q2 2008 to trough Q1 2017, computed −44.7% nominal), via archived copy of the official open-data file, http://web.archive.org/web/20260718123712/https://www.bankofgreece.gr/OpenDataSetFilesALL/DOAM/New_Index_of_Apartment_Prices_by_Geographical_Area_en_2025-11-25.xls (accessed 2 August 2026). [^4-45]: Regulation (EU) 2024/1624 of 31 May 2024 (Anti-Money-Laundering Regulation), Article 22(1)(a) (collection of all nationalities held), applicable from 10 July 2027; https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401624 (accessed 2 August 2026).