# 10. What the Structure Actually Costs This chapter builds the report's public reference case (an illustrative single-applicant position of approximately €375,000) from the bottom up. It states what is known, bands what can only be estimated, and names what cannot be known until a specific property and specific professional providers have been selected. Its central finding should be stated at the outset rather than left to the end: once every real cost is counted, including the retainer of the licensed submitting agent through which a citizenship application must be filed, the €375,000 figure holds in the leanest case modelled here and is exceeded as the configuration grows, and a defensible single-applicant planning figure is closer to €376,000 (§10.14). Family scaling is dealt with in Chapter 11; the distinction between contribution capital and retained capital, and every exit-side cost, in Chapter 12. ## 10.1 Cost-model methodology Every cost line in this chapter is placed in one of three tiers. - Known — charges fixed by statute or published official schedule: the São Tomé and Príncipe contribution and due-diligence fee, the Greek permit and card fees, and the €250,000 statutory minimum property value. These are stated exactly, with their instruments, and remain subject to confirmation of the schedules in force at the date of application. - Banded — costs that are real in every transaction but market-set or scale-based: notarial and registry charges, legal fees, technical due diligence, translations and legalisation, insurance, currency conversion. These are given as sourced bands, never point estimates, and each requires a written quotation before engagement. - Unknowable before selection — costs that depend on the specific property, the client's documents and the providers instructed: the VAT-versus-transfer-tax classification, the objective (tax-assessed) value, remedial works, furnishing, building charges. These are named in §10.15 rather than guessed at. One line departs from the banded tier's rule against point estimates, and the departure is stated rather than concealed. The retainer of the licensed submitting agent through which a citizenship application must be filed is a cost the client genuinely bears, and omitting it would understate the position. It is carried at a single stated figure: an allowance of US$5,000 (€4,348 at the planning assumption) held in Kestrel Private's own cost model for that application. It is not published, not gazetted and not sourced to any instrument, and it is not a quotation; a written quotation is required before engagement, and the line requires confirmation at the date of application (§10.4). Four disciplines govern throughout. First, the client-reality rule: every figure is the figure payable by a non-EU-national, non-resident investor purchaser; no owner-occupier, primary-residence or other relief requiring a status the reference client does not hold is assumed anywhere in this chapter. Second, Greek fiscal figures (transfer tax, VAT, ENFIA and related charges) rest on convergent professional sources with the governing instrument identified in each note; they are reported figures, subject to confirmation at the date of application. Third, no line is netted against any other: each is payable to a different counterparty. Fourth, and governing how every table in this chapter should be read, the model separates two kinds of money: 1. **Kestrel Private's professional engagement fee**: the firm's own charge for coordinating the work, fixed and agreed in writing before anything begins. It is charged on programme applications, and on nothing else, because each programme applied to is a separate application: a separate body of work, a separate set of counterparties, a separate schedule of disbursements, and a separate government reaching a separate decision. A client instructing one programme pays one fee. The reference case comprises two applications (the São Tomé and Príncipe citizenship application and the Greek investor residence application), and therefore carries two fees, and only two. The optional company, banking and tax layer is not a programme application and carries no Kestrel Private fee at all; its cost is entirely third-party (§10.12). There is no third fee anywhere in this structure. Within each application the fee is fixed: it does not scale with the size of the investment or with the composition of the family. 2. **Disbursements**: every other line in this chapter. These are amounts payable to a government, a tax authority, a notary, a land registry, admitted counsel, a technical adviser, a translator, an insurer, a bank or another service provider in one of the jurisdictions involved. A disbursement passes to the party entitled to it. It is not part of Kestrel Private's fee, and the firm's fee does not rise or fall with it. The distinction matters because the totals in this chapter are dominated by disbursements and by the investment itself, not by the advisory fee. Presenting them as a single "price" would obscure both who is actually being paid and which lines the client can obtain a written quotation for before instructing them. Every table below is therefore read as the applicable fee lines (one for each application instructed, two in the reference case) plus a schedule of disbursements. The chapter builds the executive summary's reference case (§1.5): | Cost component | Illustrative amount | | ----------------------------------------------------- | ------------------: | | Qualifying Greek property | €250,000 | | São Tomé single-applicant contribution of US$90,000 | €78,261 | | São Tomé due-diligence and processing fee of US$5,000 | €4,348 | | Greek main-applicant permit fee | €2,000 | | Greek residence-card production charge | €16 | | **Known base subtotal** | **€334,625** | *Single applicant; conversions at the report's planning assumption of €1 = US$1.15 (§10.2), a rate set below the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026 and therefore slightly overstating the euro cost of the two dollar-denominated lines;[^10-39] statutory and published charges as at 2 August 2026, subject to confirmation at the date of application. Foots: €250,000 + €78,261 + €4,348 + €2,000 + €16 = €334,625. Sources: Decree-Law No. 07/2025, Anexo I;[^10-1] Law 5038/2023, Articles 100 and 171;[^10-2] the official administrative record for the change-of-use category.[^10-3]* A total planning figure of approximately €375,000 therefore leaves €40,375 for every other cost line in this chapter, including both of Kestrel Private's professional engagement fees, one for each of the two applications (§10.11), and the retainer of the licensed submitting agent through which the citizenship application must be filed (§10.4). Whether that allowance is sufficient is tested, line by line, in §10.14. It is not. The executive summary's discipline governs every figure that follows. The reference figure is an illustrative planning model for a single modelled case. It is not: - A fixed price. - An all-inclusive price. - A guaranteed maximum cost: it does not cap what the position will cost. - A family price; family shapes are modelled separately in Chapter 11. - A guarantee of approval, on either side. - A promise that €250,000 will remain fully recoverable (see Chapter 12). ## 10.2 Exchange-rate assumption The report's euro conversions of US-dollar amounts use a planning assumption of €1 = US$1.15. This is an assumption adopted for internal consistency and set deliberately below the prevailing market rate. It is not a market rate, not a forecast, and not a rate any client will obtain. The citizenship component's charges are denominated in US dollars in the gazetted schedule; the dollar figures govern, and the euro figures in this report are illustrative conversions only.[^10-1] The assumption is anchored to the European Central Bank's euro foreign exchange reference rates, the standard published daily series. That series records US$1.1535 on 3 August 2026 and US$1.1485 on 31 July 2026. Over the 12 months to 3 August 2026 the series covers 255 trading days, with a mean of US$1.1639 and a minimum of US$1.1340.[^10-39] The planning rate of US$1.15 therefore sits inside the observed range and below both spot and the 12-month mean: it is a rate the euro has actually traded at, and it converts dollar charges into more euro than the market rate of 3 August 2026 would, which is the direction that protects the client's budget. The report's former planning assumption of US$1.10 is not carried forward. On the same series it did not occur on a single one of those 255 trading days. It lies 5.04 standard deviations below the 12-month mean and below the 12-month minimum, and was last recorded on 8 April 2025.[^10-39] A planning rate that has not existed for more than a year distorts every euro figure derived from it, and the residual allowance most of all. The remaining conservatism is small and is stated so that no reader mistakes the assumption for an observation. At US$1.15 the euro cost of every dollar-denominated line is about 0.3% higher than at the reference rate of 3 August 2026, and the residual allowance inside the €375,000 planning figure is correspondingly about €250 lower: €40,375 at the planning assumption against about €40,626 at that reference rate. The model is therefore marginally prudent on cost and marginally conservative on the allowance, and §10.14 should be read on that basis. The sensitivity is material in its own right. On the reference case the dollar-denominated charges total US$100,750 (the contribution, the due-diligence and processing fee, the post-approval documents and the licensed submitting agent’s retainer allowance), which is €87,609 at the planning assumption and €87,343 at the reference rate of 3 August 2026. A movement of US$0.05 in the rate moves that figure by roughly €3,982 and a movement of US$0.10 by roughly €8,343: between about one and four-fifths and about three and three-quarter times the lean case's shortfall against the planning figure of €225 (§10.14). The lean case has no margin for a rate movement to exhaust: an adverse movement of that order would multiply the shortfall several times over, and a favourable movement of the same order would offset it only on an assumed rate, and only before the unbanded lines listed in §10.14 are priced at all. The prevailing rate at the date of this report is stated above; the rate obtainable on the payment day must also be stated in any client-specific model, and neither is this planning assumption. One rate is used throughout this report. Kestrel Private's published worked example (§10.12) now applies the same €1 = US$1.15 planning assumption as this chapter; what it allocates across its three stages, and on what basis, this report does not reproduce (§10.12), so the two documents' euro figures should not be expected to agree cell for cell. The dollar amounts, which govern, are the same in both. Because the rate is an assumption rather than a market observation, every euro figure derived from a dollar charge moves with the market: a client funding in a third currency bears two conversions, and all converted amounts require confirmation at the date of application (§14.13). Two practical consequences follow. The euro cost of the dollar-denominated components is fixed only on the day each payment is executed, at the rate and margin actually achieved (§10.10). And a client funding from a third currency carries exchange exposure against both the euro and the dollar between planning and completion (see §14.13). ## 10.3 Citizenship contribution The contribution to the National Transformation Fund is fixed by Anexo I of Decree-Law No. 07/2025 at US$90,000 for a single applicant (€78,261 at the planning assumption). The family schedule (US$95,000 for a family application of two to four persons; US$5,000 for each additional qualifying dependant; defined post-approval addition fees) is priced in Chapter 11.[^10-1] Three features of the contribution matter to the cost model. - Payment falls only after approval. Delivery of the approval certificate is conditional on deposit of the contribution within 90 days of approval; if the deposit is not made, the process lapses. The contribution is therefore not at risk before a decision, but **it is non-refundable once made**.[^10-1] - The contribution is spent, not invested. It is a non-refundable payment to the Fund, the structure's principal unrecoverable component, and Chapter 12 treats it accordingly. - The amounts can change. The responsible ministers may alter the Anexo I fees and minimum amounts by joint order (a power the decree confers expressly "without prejudice to commitments assumed by the State in specific instruments"), and an update does not affect processes already formally admitted. The schedule current at the date of application must be confirmed before any engagement (see §14.2).[^10-1] The legal basis, payment mechanics and process are set out in §6.4–§6.5; this chapter carries only the money. ## 10.4 Citizenship processing and due-diligence fees The due-diligence and processing fee is US$5,000 per application, not per person, and is non-refundable once the application has been submitted. At the planning assumption it converts to €4,348.[^10-1] The programme's official site labels this charge a submission fee, payable per application, and publishes a separate US$5,000 due-diligence fee borne by the benefactor of a sponsored application.[^10-4] The label carried here should therefore not be read as confirming that the due-diligence report required by the decree is covered by the US$5,000. Post-approval document charges are less well fixed. The gazetted Anexo I contains no passport, identity-card or certificate fee: a verified negative against the full gazette text.[^10-1] The programme's official site (now on the government domain cip.gov.st, to which the former stpcip.com address redirects) publishes an aggregate charge of US$750 per applicant for citizenship documents (certificate of registration, passport and national identity card), read there on 4 August 2026; that is the official figure this report carries, approximately €652 per applicant at the planning assumption, and it requires confirmation at the date of application.[^10-4] Industry sources circulate a per-document split; it appears in neither the decree nor the official schedule and is not used here. Two related points. The Migration and Frontiers Service publishes a separate domestic passport fee schedule in dobra: a common passport at 1.500,00 STD, roughly €61 at a reported peg of €1 = 24.50 dobras, itself a reported figure requiring confirmation; that domestic schedule is not the programme charge, and the two must not be conflated.[^10-5] Separately, the decree's document schedule requires a due-diligence report issued by an entity recognised by the programme's administering unit; whether procuring that report is covered by the US$5,000 fee or separately charged is not stated in the decree and requires confirmation at the date of application.[^10-1] The licensed submitting agent's retainer allowance is a further citizenship-side cost, and it is not a government charge at all. The programme's designated application channel states that applications must be initiated through a licensed agent, and the decree licenses agents and penalises unlicensed promotion.[^10-4][^10-1] A client therefore cannot file directly, and bears the cost of the licensed submitting agent through which the file passes. That cost is real in every citizenship application and belongs in the model. This chapter carries that cost at an allowance of US$5,000 (€4,348 at the planning assumption) held in Kestrel Private's own cost model for the citizenship application. It is a dollar-denominated allowance carried on the same footing as the programme's other dollar charges, and it moves with them as the rate moves. It is not published, not gazetted and not sourced to any instrument, and it is not a quoted retainer: no submitting agent has quoted it, and it is not evidence of what any agent charges. The retainer a client is actually asked to pay may differ materially from this allowance, in either direction, and only a written quotation will establish it; the line requires that quotation before engagement and confirmation at the date of application. Separately, the decree provides that the programme's net proceeds revert to the National Transformation Fund "in the percentages defined" — a revenue split defined outside the gazetted text and not published; no inference is drawn from it here.[^10-1] Citizenship-side legal and professional fees are addressed in §10.8; document translation and legalisation for the citizenship file in §10.9. ## 10.5 Property acquisition price The reference case assumes acquisition of one property at exactly €250,000: the statutory minimum for the restricted change-of-use category under Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024. The applicant must acquire full ownership and possession of a single property with a minimum acquisition value of €250,000 at the time of purchase.[^10-2][^10-6] The €250,000 is a floor, not a market price. An actual purchase may complete above it, and every percentage-based line in this chapter (transfer tax, notarial, registry, legal and agency charges) scales with the price actually paid. Whether a property priced at the statutory floor is worth its price is a separate question from whether it qualifies — the central question of Chapter 8 (see §8.3). **Nothing in this chapter treats the €250,000 as preserved or recoverable capital: what is recovered on an eventual sale depends on the property market at that time and on the transaction costs of the exit, which are modelled in Chapter 12.** The full price must be paid before the residence application through prescribed banking channels (crossed bank cheque, credit transfer or card payment through a Greek-operating provider), with the payment details recorded in the notarial deed.[^10-2] Funding must therefore move through the banking system, which is why the currency-conversion line in §10.10 is a structural cost, not an optional one. Eligibility and ownership conditions are dealt with in §7.4–§7.6. ## 10.6 Property taxes and transaction costs Real-estate transfer tax (FMA) is 3% of the taxable value, the rate in force since 1 January 2014 (Α.Ν. 1521/1950, Article 4 §1).[^10-40] A further municipal element of 3% of the tax is charged in practice, giving an effective 3.09%; this report has confirmed the 3% main rate against the gazetted instrument but has not been able to pin the instrument imposing the municipal element, and Article 4 §3 of the same law apportions 3.00% of the tax collected to municipalities rather than adding a charge to the buyer. The effective rate is therefore reported, not verified, and the notary's computation must be obtained before signing. The base is the higher of the contract price and the objective (tax-assessed) value; the buyer is liable, and the tax is paid before the notarial deed is executed. On €250,000, and assuming the taxable value equals the price, FMA at 3.09% is €7,725; at 3% alone it is €7,500. This chapter models the higher figure, so that the model does not understate a cost the client will be asked to pay; where the 3% burden proves correct, every total built on this line falls by €225. If the objective value of the selected property exceeds the price, the tax follows the higher figure, a property-specific fact (§10.15). All figures in this section are reported by convergent professional sources and subject to confirmation at the date of application.[^10-7][^10-8] VAT at 24% applies, instead of FMA, to transfers of new buildings (building permit issued or revised from 1 January 2006) before first use by a VAT-liable constructor acting in the course of business; FMA and VAT are mutually exclusive.[^10-9] A developer may, however, elect a VAT-suspension regime, and the suspension currently runs to 31 December 2026, with suspensions in force to 31 December 2025 prolonged automatically; where it applies, the purchaser pays FMA at 3.09% rather than 24% VAT.[^10-10][^10-11] Whether a specific commercial-to-residential conversion sale is within VAT scope is property-specific: a pre-2006-permit or previously used building is outside VAT (FMA applies); a conversion executed under a new post-2006 permit and sold before first use by a developer is within scope but in practice suspension-elected (FMA applies); and a sale by a non-developer is never VAT-able. The reference acquisition is therefore expected to bear FMA at 3.09%, but the classification must be confirmed by the purchaser's lawyer and notary before signing, and no continuation of the suspension beyond 31 December 2026 can be assumed as at 2 August 2026.[^10-9][^10-10] The banded transaction charges on a €250,000 price are these. | Item | Band | Amount on €250,000 | | --- | --- | ---: | | FMA at an effective 3.09% (assumes taxable value = price; €7,500 at the 3% main rate alone) | fixed % | €7,725 | | Notary, 0.8%–1.2% + 24% VAT | statutory sliding scale | €2,480–€3,720 | | Land registry / cadastre, ≈0.5% of taxable value plus fixed charges | schedule-based | ≈€1,250, plus unquantified fixed charges | | Estate agent, if the buyer instructs one, 2%–4% + 24% VAT | market; commonly quoted near the lower end | €6,200–€12,400 | *Reported bands; VAT at 24% included where stated. The FMA line is modelled at the effective 3.09%: the 3% main rate is confirmed against Α.Ν. 1521/1950, Article 4 §1, and the municipal element is reported but not pinned to an instrument, so if the burden is 3% alone this line is €7,500 and every total built on it falls by €225. The registry line is the percentage element only: no source read for this report quantifies the fixed charges that the same schedule adds, so the registry figure — and every total built on it — is a floor. The buyer's agent line arises only where the buyer instructs an agent; each party customarily pays its own agent. Sources: professional and market guides as cited, subject to confirmation at the date of application.[^10-7][^10-8]* A commonly reported rule of thumb puts total acquisition costs on a resale or suspension purchase at around 8%–10% of price including transfer tax, professional fees and registration; that corresponds to a full professional stack including a buyer's agent.[^10-8] The Greek-side acquisition stack modelled in §10.14 (transfer tax, notary, registry, conveyancing counsel and any buyer's agent, and excluding technical due diligence) runs from about 5.8% of price in the lean case to about 10.0% in the heavy case, and to about 12.5% where every band is at its top (about 5.7%, 9.9% and 12.4% if FMA is 3% rather than 3.09%); the rule of thumb therefore describes the middle of this chapter's range, not its ceiling. Appendix C states the same stack with technical due diligence added, at roughly 5.9%–13.1% (§C.9); the two are the same lines measured on different baskets. The property-side compliance documents behind these charges are described in §8.5–§8.6. ## 10.7 Residence application and card fees The government fee (παράβολο) for the investor permit (type B.5) is €2,000, payable electronically, for issuance and again for each renewal; minors are exempt from permit fees. The electronic residence card carries a €16 production charge. The official administrative record for the change-of-use category (last updated 31 July 2026) prices the main applicant's initial-issuance file at €2,016 in total.[^10-2][^10-3] | Fee | Amount | | --- | ---: | | Main applicant — permit fee (issuance; again on each five-year renewal) | €2,000 | | Main applicant — electronic residence card | €16 | | Family member (spouse or other qualifying member, type O.1/O.2) — permit fee | €150 | | Child turning 21 — independent three-year permit (type O.2), Article 171 §1(β) | €150 | | Minor child — permit fee | exempt | | Optional national D-visa entry route — consular fee | €180 | *Schedule as at 4 August 2026, from Law 5038/2023 (Article 171) and the official administrative record; subject to the schedule in force at the date of application. The €2,000, €150 and €450 amounts and the minors' exemption are Article 171's; the €16 charge is not in Article 171 and rests on the administrative record, where it is the electronic card production cost for the main procedure. The €180 national-visa consular fee is set by Joint Ministerial Decision 214926/2025.[^10-17] The fee for the child's independent permit is stated here at €150: Article 171 §1(β) sets the fee for permit types O.1 and O.2 at €150, reserving €450 for the three-year independent permit granted under the first sentence of Article 90 §5, while Article 95 §2 grants the investor's child that permit by analogous application of the second sentence. €150 is therefore the fee on the face of the Code; the €450 figure circulating in practice requires confirmation against the administrative record at the date of application, and the difference is €300 per child. Family-member card charges follow the schedule at filing, and family composition and totals are modelled in Chapter 11.[^10-2][^10-3][^10-12]* No separate biometrics charge appears in the instruments read. The application may be filed by proxy before entry, but the applicant (and each family member) must enter Greece once within an exclusive 12-month period to give biometrics.[^10-12] The associated travel and accommodation costs are real and personal to the client: they depend on the country of origin, the size of the party and the season, and no band is offered for them here, but they sit inside the executive summary's allowance and are carried as a named unquantified line in §10.14 and §10.15. Filing mechanics are described in §7.7 and §17.11. ## 10.8 Legal and technical due diligence Greek conveyancing lawyers' fees are market-set, reported at approximately 1%–2% plus 24% VAT of the property price: €3,100–€6,200 on €250,000. The retainer's scope matters as much as the rate: a title review over the prescription period, encumbrance searches and contract work are reported as standard scope, subject to confirmation of what the retainer actually covers; whether the residence filing is included is a matter of contract (below).[^10-8] Where immigration filing is contracted separately from the conveyance, a published single-firm schedule prices the work at approximately €2,000–€3,500 per investor all-in: a reported, firm-specific anchor, not a market tariff. In a tightly controlled case the filing can be contracted within the conveyancing retainer; the stress test in §10.14 shows both configurations.[^10-13] No published tariff market exists for buyer-side technical due diligence; leading inspection practices quote on request and bill on time.[^10-14] Two engineer documents attach to a conversion purchase in any event: the seller-side certificate that no unauthorised constructions or uses exist (required on every transfer deed) and the change-of-use technical report prescribed for the residence application (different documents with different functions), both of which the buyer's engineer should review together with the Electronic Building Identity file (indicative issue cost €120–€250 for an apartment, customarily seller-side).[^10-15][^10-16][^10-17] A reasoned planning band for full buyer-side technical due diligence on a conversion property (legality check, permit-file review, cross-check of the prescribed conversion report, condition survey) is €300–€1,500 per property. That band is this report's analysis, not a market rate, and written quotations are required in every case. The due-diligence questions themselves are Chapter 8's (see §8.4–§8.5, §17.7). No citable fee band exists for legal and professional work on the citizenship application (file preparation, source-of-funds documentation, applicant-specific legal explanation of the decree's provisions). It is a real line, obtained by written quotation, and the executive summary's allowance must absorb it (§10.14). ## 10.9 Translation, apostille and legalisation Both components consume certified translations and legalisation, and these costs scale per person and per document — the main driver of documentation-cost differences between a single applicant and a family (§11.8; the document requirements themselves are listed in §16.10). - Certified translation into Greek: published provider rates run from €15 per page (up to 230 words, plus 24% VAT) to €30–€60 for a one-page certificate; a planning band of €15–€60 per page plus VAT is reported.[^10-18][^10-19] - Apostille, United Kingdom: the Foreign, Commonwealth and Development Office charges £45 per document (standard paper service), £35 for an e-apostille, £40 next-day for registered businesses and £100 for the restricted urgent service, plus courier costs.[^10-20] - Apostille, South Africa: the Department of International Relations and Cooperation levies no fee for legalising public documents; private documents (powers of attorney, affidavits) are first notarised — notarial fees are market-set — and then apostilled by the High Court Registrar without charge.[^10-21] - Notarisation, United Kingdom: published schedules run from about £60–£100 plus VAT for a single document, with others quoting £90–£200 or more.[^10-22] - The citizenship file: the decree requires certified translations and legalisation by Hague Apostille (or consular authentication where the Convention does not apply) of foreign documents, with the official application form in Portuguese or English.[^10-1] Costs of sworn translation into Portuguese, where required, are not banded in this report and require quotation. Sterling charges are stated above in the currency of the published schedule; this report adopts no euro–sterling planning rate, and a client converting them carries the conversion cost described in §10.10. In euro terms, and on the assumptions of the stress test, a single applicant assembling a South-African-route file may spend under €200 on this section, while a file routed through UK notarisation and apostille of powers of attorney runs several times that, and a multi-person family file reaches a four-figure sum. The stress test carries €150 (lean) to €900 (heavy) for one applicant. ## 10.10 Insurance and administrative costs The Immigration Code requires full sickness insurance for the permit; for the investor permit the operative document at issuance and at each renewal is a private insurance policy, with foreign policies accepted only where an express clause covers the period of residence in Greece.[^10-12][^10-17] The coverage minimums — disability from accident at least €15,000 per year, medical and pharmaceutical expenses at least €1,500 per year, broad hospital care at least €10,000 per year, each with co-payment capped at 20% — were fixed under the predecessor Code and are still applied in practice, subject to confirmation at the date of application.[^10-23] Reported premiums for minimum-compliance cover are approximately €70–€300 per adult per year, materially more for comprehensive cover or older applicants; premiums load from age 65 and cover above age 75 may be unavailable. Written quotations are required.[^10-24] Property insurance is market-priced and quotation-based; an insured residence also attracts an ENFIA reduction of 20% where the property's taxable value does not exceed €500,000 and 10% where it does, conditional on cover in the preceding year of at least three months, and in force since ENFIA 2025 (§10.13).[^10-7] The stress test allows €350–€800 for first-year property and health cover combined. A Greek-notary power of attorney is priced at €300 plus 24% VAT on a published single-firm schedule; the foreign-execution route combines local notarisation (§10.9) with an apostille. A planning band of €150–€500 per power-of-attorney event, all-in, is reported; one instrument can often serve a couple, while a file run from abroad may need both a foreign-executed instrument and a Greek one.[^10-13] The same single-firm schedule prices procurement of a Greek tax number (AFM) at €400 plus VAT and assistance with a bank-account application at €300 plus VAT — reported anchors, not tariffs. An AFM is a practical precondition of the purchase: no notary can draw the deed without it, and it is required for the transfer-tax declaration and for later property and tax filings. A bank-account application is an application, not an approval (§9.4–§9.5). Both lines are carried in the stress test at §10.14, in every case.[^10-13] On approximately €335,000 of cross-border transfers (property, contribution and fees), the exchange-rate margin — not the wire fee — dominates cost. Banks commonly build a 2%–4% margin into the exchange rate (approximately €6,700–€13,400 on the reference sums), while specialist brokers price large transfers far tighter, often well under 1% (approximately €1,005–€3,350 at 0.3%–1.0%). The reported planning bands are 30–100 basis points (specialist) against 200–400 basis points (bank); written quotes are required, and the route chosen is one of the largest single swing items in §10.14.[^10-25] That €335,000 basis is the sum of the €250,000 price, the €2,016 Greek fee file and the dollar-denominated charges converted at the planning assumption, and it assumes the client funds from a currency other than the euro and the US dollar, so that the whole sum is converted. A euro-funded client converts only the dollar leg — the contribution, the due-diligence fee and the document charges, approximately €83,000 — and a dollar-funded client only the euro leg of approximately €252,000; in each case the modelled conversion cost falls by roughly three-quarters or by roughly one-quarter respectively, and the funding currency must therefore be stated in any client-specific model. ## 10.11 Kestrel Private's professional engagement Kestrel Private's professional engagement is charged as a fixed professional engagement fee agreed in writing before work begins. The fee published on kestrelprivate.com/fees at the date of this report is €10,000 for a programme application and €8,000 for a second application instructed alongside it, the reduction reflecting the onboarding, due-diligence and document work the two share; it is charged once for each application, and the same page states that the fee, the scope and the terms on which any property is presented are set out in the engagement letter and agreed before any work begins.[^10-26] Each programme applied to is a separate application — a separate body of work, a separate set of counterparties, a separate schedule of disbursements, and a separate government reaching a separate decision on its own criteria — and each carries its own engagement and its own fee. A client who instructs the citizenship application alone pays one fee. A client who instructs the residence application alone pays one fee. The reference case is both applications, and therefore carries two. The fee attaches to programme applications and to nothing else. There are two such applications in this structure — the citizenship application and the residence application — and therefore two fees in total, never three. The optional company, banking and tax layer is not a programme application and carries no Kestrel Private fee: its cost is entirely third-party, being corporate registrar and formation charges, corporate-service provision and the corporate team that performs the work (§10.12). | Application within the reference case | Professional engagement fee | | ------------------------------------------------- | --------------------------: | | São Tomé and Príncipe citizenship application | €10,000 | | Greek investor residence application | €8,000 | | **Kestrel Private fees within the reference case** | **€18,000** | *Single applicant; the fixed fee published at kestrelprivate.com/fees as at 4 August 2026, agreed in writing before work begins and charged once per application.[^10-26] Foots: €10,000 + €8,000 = €18,000. The fee is per application, not per person, and within each application it does not scale with the size of the investment or the composition of the family (§10.1). These two lines are the whole of Kestrel Private's charging within this structure: the optional company, banking and tax layer sits outside the reference case and carries no Kestrel Private fee of its own (§10.12).* These two lines are the only charges in the chapter that are Kestrel Private's own. Everything else — the contribution to the National Transformation Fund, the property price, transfer tax or VAT, the Greek permit and card fees, the licensed submitting agent's retainer, notarial and registry charges, admitted counsel in each jurisdiction, technical due diligence, translation and legalisation, insurance, and bank and conversion charges — is a disbursement payable to the government, authority, professional or provider entitled to it, in the amount that party charges (§10.1). The client pays each directly, and each appears as its own line in this chapter so that it can be quoted, questioned and compared before it is instructed. The fees are fixed while the disbursements are not, so the total cost of the position moves with the disbursements and not with the firm's charges. And the fees remain a minority of the total: on the reference case they are €18,000 against modelled all-in totals of €375,225, €397,088 and €410,888 (§10.14) — about 5% of the lean figure and less of the others — of which €250,000 is the property the client continues to own (§12.1). That said, €18,000 is about 45% of the €40,375 allowance the planning figure leaves for everything other than the known base, and the stress test in §10.14 must be read on that basis. It carries both published fees as discrete lines for exactly this reason. ## 10.12 Optional company, banking and tax costs The optional layer sits outside the €375,000 reference case, and it carries no Kestrel Private fee. The firm's professional engagement fee is charged on programme applications only — the citizenship application and the residence application, two fees in total (§10.11) — and the optional layer is not a programme application. Its cost is entirely third-party: corporate registrar and formation charges, corporate-service provision, and the corporate team that performs the work. There is therefore no third fee anywhere in this structure, and a client who does not instruct the layer does not pay for it at all. The bands below are those third-party costs in full. The layer's substance, and when it is unnecessary, are Chapter 9's subject (§9.15–§9.16). - Greek IKE — electronic one-stop-shop filing €18 (minimum capital €1); professional formation approximately €100–€200; tax representation and AFM for a non-resident founder approximately €200–€500. Running costs: accounting approximately €80–€200 per month, registered or virtual office from approximately €29–€49 per month, annual registry fee €100 — an indicative all-in year of approximately €1,500–€3,100 for a dormant or light company.[^10-27][^10-28] - Cyprus company — incorporation all-in approximately €700–€1,500 through service providers (registrar filing about €165) to €1,500–€4,000 or more through law firms; the €350 annual levy was abolished from 2024. Annual running costs approximately €2,400–€4,000 (dormant or holding) to €3,900–€6,900 (small trading company, statutory audit included).[^10-29][^10-30] - Banking applications — professional support is quotation-based (personal-account anchor in §10.10); banks' own charges are schedule-based and modest against the sums above. No fee secures approval, and approval cannot be bought (§9.5). - Tax-residence assessment — advice on the Greek non-dom regimes or ordinary tax residence is quotation-based regulated work. The regimes themselves carry their own charges where a client relocates and separately qualifies — the Article 5A regime, for instance, is a flat €100,000 per year plus €20,000 for each included relative — but those are consequences of a separate election, not costs of this structure (§9.6–§9.9). The published three-stage worked example on Kestrel Private's site allocates €15,000 to the optional company stage. That stage figure is a published bundled total, and this report neither reproduces nor reconciles its composition. The formation and running bands set out above are this report's own, and they are the figures against which any stage allocation should be tested by written quotation before the layer is instructed. The €390,000 three-stage total and this report's €375,000 reference case describe the same structure, with and without the optional layer. They are not two views of one arithmetic: the published example states its euro figures at the same €1 = US$1.15 planning assumption as §10.2, and it is a stage-priced engagement model that allocates third-party allowances across its three stages on a basis this report does not reproduce, while the figures here are built line by line from the underlying schedules. Neither figure is a quotation, and the limits stated at §10.1 apply to both.[^10-31] ## 10.13 Ongoing ownership and compliance costs The recurring stack below assumes a single non-resident owner, the property unlet and held personally, as at 2 August 2026. Where the property is long-let, Greek tax on the rent and management costs are added (§9.10, §12.5–§12.6); the property-level obligations behind these lines are described in §8.11–§8.12. | Recurring line | Reported band (per year) | | --- | ---: | | ENFIA (annual property tax) — illustrative for a €250,000 Athens apartment | ≈€300–€700 | | Municipal property duty (TAP), 0.25‰–0.35‰ of assessed value | ≈€63–€88 | | Non-resident tax compliance (E1 return where required, ENFIA handling; tax-representative arrangements) | ≈€250–€500 | | Permit health insurance (minimum-compliance band, per adult) | ≈€70–€300 | | **Quantified subtotal** | **≈€683–€1,588** | | Building common charges (κοινόχρηστα) | building-specific; no statutory scale | | Municipal refuse and lighting charges (via the electricity account) | municipality-specific tariff | | Property insurance | market-priced; earns the ENFIA discount | | Letting and management, if instructed | market-contracted; quotation | *Illustrative planning stack, reported figures subject to confirmation at the date of application. ENFIA is computed per property by the tax administration (zone price, age, floor and other coefficients); the band shown is illustrative for a €250,000 Athens apartment below the €500,000 surcharge threshold, before the 20% insured-residence discount.[^10-32][^10-7] TAP is computed here on an assessed value of €250,000; the assessed value of the selected property is a property-specific figure established during due diligence, and the charge follows it.[^10-33] The compliance band is a single market source's basic tier; rental filings sit in higher tiers of roughly €1,000–€2,500.[^10-34] Unquantified lines are established from the municipal tariff and the building's own charge history during due diligence.* Mechanics worth noting. ENFIA for 2026 was payable in full by 31 March 2026 or in 12 monthly instalments to February 2027, operated remotely with tax-portal credentials; the dates restate each year.[^10-35] From 1 January 2027 TAP is replaced by a Local Development Fee of 0.30‰–0.70‰, also collected through utility bills — up to about €175 per year at a €250,000 assessed value.[^10-7][^10-33] A tax representative is discretionary at code level, though in practice designation accompanies non-resident tax-number issuance; a foreign tax resident files a Greek return only where Greek-source taxable income arises.[^10-36][^10-38] The E9 property declaration is due by 31 January of the year following the deed — the classic first compliance failure of foreign owners.[^10-37][^10-38] The structure's own interaction carries two further duties, each with a charge attached. The permit holder must declare, through the migration information system, every change of personal status — the Code names change of nationality expressly — and any loss, renewal or change of passport details; the declaration is due within two months, failure carries a fine of €100 and €200 on repetition, and reissue of the permit carries a €100 fee.[^10-12] Whether Greece re-keys the permit to a newly acquired second nationality while the original subsists is not published in statute, ministerial decision or administrative record, and requires Greek counsel's confirmation at engagement (see §7.8). Separately, a renewal filed late is possible for up to three months after expiry at a fine of €100 for each month of delay, and is barred thereafter absent proven force majeure; that rule is taken from the consolidated text of the Immigration Code, the amending instrument has not yet been identified, and it requires confirmation at the date of application.[^10-2] The five-year renewal cycle adds its own periodic costs: the €2,000 permit fee again, the card charge, a fresh insurance policy, and the definitive registration certificate where registration proof was deferred at initial issuance.[^10-2][^10-17] ## 10.14 Contingency allowance The executive summary allows €40,375 between the known base of €334,625 and the approximately €375,000 planning figure, and lists what that allowance must cover. The subtraction is exact at the report's planning assumption of €1 = US$1.15 (§10.2): €375,000 − €334,625 = €40,375. That allowance must carry, among everything else, both of Kestrel Private's professional engagement fees — €18,000 across the two applications (§10.11) — and the retainer of the licensed submitting agent through which the citizenship application must be filed, carried here at a stated allowance of US$5,000 — €4,348 (§10.4). Those two items alone commit €22,348 of the €40,375 before a single Greek transaction cost is priced. The test below prices the allowance's list at three points: the lean end of every band, the heavy configuration, and the top of every band this chapter states. | Cost line (all within the €40,375 allowance) | Lean case | Heavy case | Top of every band | Basis | | --- | ---: | ---: | ---: | --- | | FMA transfer tax at an effective 3.09% (€7,500 at the 3% main rate alone) | €7,725 | €7,725 | €7,725 | §10.6 | | Notary, 0.8%–1.2% + 24% VAT | €2,480 | €3,720 | €3,720 | §10.6 | | Land registry / cadastre, ≈0.5% (fixed charges additional, unquantified) | €1,250 | €1,250 | €1,250 | §10.6 | | Conveyancing lawyer (lean 1%; heavy 1.5%; top 2% + 24% VAT) | €3,100 | €4,650 | €6,200 | §10.8 | | Buyer's estate agent (lean none; heavy 2.5%; top 4% + VAT) | €0 | €7,750 | €12,400 | §10.6 | | Technical due diligence (conversion property) | €300 | €1,500 | €1,500 | §10.8 | | Power of attorney, all-in (lean one Greek instrument; heavy and top two events) | €372 | €600 | €1,000 | §10.10 | | Translations and apostilles (single applicant) | €150 | €900 | €900 | §10.9 | | Greek residence-filing professional fees (lean: contracted within the conveyancing retainer) | €0 | €3,000 | €3,500 | §10.8 | | Property and permit health insurance, first year | €350 | €800 | €800 | §10.10 | | Greek tax number (AFM), €400 + 24% VAT | €496 | €496 | €496 | §10.10 | | Bank-account application support, €300 + 24% VAT | €372 | €372 | €372 | §10.10 | | Currency conversion on ≈€335,000 (lean specialist 0.3%; heavy bank 2%; top bank 4%) | €1,005 | €6,700 | €13,400 | §10.10 | | Post-approval citizenship documents, US$750 per applicant | €652 | €652 | €652 | §10.4 | | Licensed submitting agent's retainer, stated allowance of US$5,000 (not a quotation) | €4,348 | €4,348 | €4,348 | §10.4 | | Kestrel Private's professional engagement — citizenship application (published fee) | €10,000 | €10,000 | €10,000 | §10.11 | | Kestrel Private's professional engagement — residence application instructed alongside the citizenship application (published fee) | €8,000 | €8,000 | €8,000 | §10.11 | | **Total against the allowance** | **€40,600** | **€62,463** | **€76,263** | — | | **Headroom against €40,375** | **−€225** | **−€22,088** | **−€35,888** | — | *Single applicant; €250,000 property bearing FMA with taxable value equal to price; €1 = US$1.15 (§10.2); the client assumed to fund from a currency other than the euro and the US dollar, so that the whole ≈€335,000 converts — a euro- or dollar-funded client converts materially less and the conversion line falls accordingly (§10.10). Lean case: no buyer's agent, conveyancing counsel at the bottom of the band with the residence filing contracted inside the retainer, specialist-rate currency conversion, South-Africa-route document legalisation. Heavy case: buyer's agent at 2.5% plus VAT, counsel at 1.5% with separate immigration filing, bank-rate conversion at 2%, UK-route documents with notarisation. Top-of-band case: every banded line at the upper figure this chapter states. The AFM and bank-account lines are single-firm reported anchors and are carried in all three columns; the registry line carries the percentage element only, and the fixed charges the same schedule adds are unquantified, so all three totals are floors. Two professional engagement fees are carried in every column because the fee is charged once per application and the reference case comprises two applications (§10.11); a client instructing a single programme carries one, and the corresponding column falls by €10,000 or €8,000 as the case may be. No third fee arises: the optional layer carries none (§10.12). The submitting-agent line is likewise carried flat in all three columns: it is a stated allowance of US$5,000 held in Kestrel Private's own cost model, not a published charge and not a quotation, and the retainer actually charged may differ materially from it in either direction (§10.4). The document line is the official US$750 per-applicant post-approval aggregate, carried in every column and priced separately from the submitting agent's allowance (§10.4). FMA is modelled at the effective 3.09%; where the 3% main rate alone is the true burden (§10.6) the line is €7,500 and each total falls by €225, to €40,375, €62,238 and €76,038, with headroom of €0, −€21,863 and −€35,663 — on that basis the lean case meets the allowance exactly. The euro figures rest on the planning assumption of €1 = US$1.15, which is about 0.3% below the European Central Bank's euro reference rate of US$1.1535 on 3 August 2026. At that reference rate the known base is about €334,374 and the allowance about €40,626; the lean allowance items are about €40,585, so the lean case sits about €41 below the €375,000 reference rather than €225 above it — and the lean all-in about €374,959. The heavy and top cases exceed the allowance on either rate (§10.2).[^10-39] Columns foot: lean 7,725 + 2,480 + 1,250 + 3,100 + 0 + 300 + 372 + 150 + 0 + 350 + 496 + 372 + 1,005 + 652 + 4,348 + 10,000 + 8,000 = €40,600; heavy 7,725 + 3,720 + 1,250 + 4,650 + 7,750 + 1,500 + 600 + 900 + 3,000 + 800 + 496 + 372 + 6,700 + 652 + 4,348 + 10,000 + 8,000 = €62,463; top of every band 7,725 + 3,720 + 1,250 + 6,200 + 12,400 + 1,500 + 1,000 + 900 + 3,500 + 800 + 496 + 372 + 13,400 + 652 + 4,348 + 10,000 + 8,000 = €76,263. Adding the known base of €334,625 gives all-in totals of €375,225 (lean), €397,088 (heavy) and €410,888 (top of every band). Bands and anchors as cited in §§10.6–10.11; arithmetic exact within stated assumptions.[^10-8][^10-13][^10-25][^10-7]* The heavy case is not the ceiling. It is one plausible configuration, and its inputs sit inside — not at the top of — the bands this chapter reports for the buyer's agent, the currency-conversion margin, the conveyancing percentage and separate residence-filing counsel. Where every band is taken at its upper figure, the modelled stack reaches approximately €76,300 and exceeds the allowance by approximately €35,900, roughly 1.6 times the heavy-case shortfall of about €22,100. The swing items, in order of magnitude, are the buyer's agent (€0 to €12,400), the currency-conversion route (€1,005 to €13,400), separate residence-filing counsel (€0 to €3,500), the conveyancing percentage (€3,100 to €6,200) and technical due diligence (€300 to €1,500). Neither the two professional engagement fees nor the submitting agent's retainer is a swing item: the fees are fixed at €10,000 and €8,000 in every column and the retainer is carried at €4,348 in every column, and at €22,348 combined they are by some distance the largest committed block inside the allowance — 55.4% of it, before any Greek transaction cost is priced at all. The lean case has no residual at all. It sits €225 above the allowance before the model reaches the lines the allowance also carries but which no source will band before selection: citizenship-side legal work (§10.8), the compulsory-entry travel and accommodation of the applicant and each family member (§10.7, §17.11), the fixed element of the land-registry charges (§10.6), property furnishing or completion, and any genuine reserve for the unforeseen. Each of those is additive to a figure that is already over. A single long-haul journey to Greece for the biometric appointment, or one written quotation for citizenship-side legal work, widens the gap rather than consuming a margin, because there is no margin to consume. One point of construction should be stated so that no reader suspects double counting. The US$750 post-approval document aggregate — €652 — is priced as its own line in the table above, in every column, and it appears nowhere else in the model: it is not folded into the submitting agent's allowance, which is a separate US$5,000, and it is not inside the known base, whose citizenship-side lines are the contribution and the submission fee only (§10.1). The submitting agent's line, for its part, is the only line in the table for which neither a band nor a quotation exists, and it is the line most capable of moving the result: were the retainer to prove materially higher than the allowance carried here, the lean shortfall would widen by the difference; were it materially lower, the lean case would move back towards the allowance without any assurance of reaching it. The honest conclusion has changed, and it should be stated plainly rather than qualified. Once every real cost is counted — including the retainer of the licensed submitting agent through which the citizenship application must be filed — the €375,000 planning figure is not cleared in any case modelled here. The lean case exceeds it by €225, the heavy case by €22,088 and the top-of-every-band case by €35,888. The all-in totals are approximately €375,225, €397,088 and €410,888 respectively. The lean case is the tightly controlled single-applicant case: no buyer's agent, conveyancing counsel at the bottom of its band with the residence filing inside the retainer, specialist-rate currency conversion and the cheapest document route. That is the most favourable configuration this chapter can construct, and it still exceeds the allowance. The excess is small — €225, under 1% of the reference figure — but it is an excess, not a margin, and it arises before furnishing, biometric travel, registry fixed charges and citizenship-side legal work are priced at all. The €375,000 figure is therefore a planning reference that the lean case narrowly exceeds, not a figure the lean case holds. On this chapter's arithmetic a defensible single-applicant planning figure is closer to €376,000, and that figure is itself a floor for the reasons given above. The character of the figure is unchanged by its level. It remains an illustrative planning model, not a universal package price, and it is not a budget: a client-specific model on the selected property, the actual funding currency and written quotations — the submitting agent's retainer foremost among them — is required before any figure is relied on (§10.15, §17.9). Nothing in this chapter's arithmetic supports treating it as any of the six things §10.1 states it is not. ## 10.15 Costs that remain unknown until property selection The following cannot be known, and are not modelled, before a specific property, a specific family file and specific providers exist. Each belongs in the client-specific cost model the executive summary requires before any quotation. 1. The VAT-versus-FMA classification — permit history, seller VAT status and first-use status of the selected property (§10.6); and whether the VAT suspension is extended beyond 31 December 2026. 2. The objective value — where the tax-assessed value exceeds the price, the FMA, notarial and registry bases rise with it (§10.6). 3. The fixed element of the land-registry and cadastral charges — the percentage element is modelled, the schedule's fixed charges are quantified by no source read for this report (§10.6). 4. Technical findings — the cost of remedying anything the engineer's review discovers (regularisation, works, certification gaps) is unknowable in advance (§10.8, §8.5). 5. Furnishing and completion — property-specific; no band is offered. 6. Compulsory-entry travel and accommodation — the applicant and each family member must enter Greece once within the exclusive 12-month period to give biometrics; the cost depends on the country of origin, the size of the party and the season, and no band is offered (§10.7, §17.11). 7. Building and municipal charges — common charges follow the building's own history; refuse and lighting charges follow the municipal tariff (§10.13). 8. Insurance premiums — age-, cover- and property-specific; banded only at the minimum-compliance end (§10.10). 9. Professional quotations — the lawyer's percentage, agent instruction, technical scope and citizenship-side legal work are fixed only by written quotation (§10.8, §17.9). 10. The licensed submitting agent's retainer — carried in the model at a stated allowance of US$5,000 rather than a quoted figure, and capable of differing materially from that allowance in either direction; a written quotation is required before engagement and the line requires confirmation at the date of application (§10.4, §10.14). 11. Execution-date currency costs — the funding currency, the rate, the margin and the route on each payment day (§10.2, §10.10). 12. Government schedules at the date of application — both jurisdictions' fee schedules as then in force, including São Tomé and Príncipe's power to alter its amounts by joint ministerial order and the possibility of Greek legislative change (§10.3, §14.1–§14.2); and confirmation of the US$750 document aggregate (§10.4). 13. Family composition — every per-person line (contribution supplements, permit fees, documents, translations, insurance, compulsory-entry travel) scales with the family; Chapter 11 models it. Exit-side costs — agency, certificates, any capital-gains tax then in force, and the transaction costs of the eventual buyer — are deliberately excluded here and are priced in the exit scenarios of Chapter 12 (§12.4, §12.10). A quotation exists only once the full cost model has been completed using the selected property, the exact family composition, the government schedules current at the date of application and written quotations from the relevant legal and professional providers (§1.5, §17.9). ### Notes [^10-1]: São Tomé and Príncipe, *Decreto-Lei n.º 07/2025* («Regulamentação da Nacionalidade por Investimento ou Doação», RNID), Diário da República, I Série, N.º 33, pp. 429–440, 1 August 2025, Articles 10, 14 and 22, Anexo I and Anexo III (Portuguese; read in full from the gazette facsimile). An identical facsimile is mirrored at https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026) — cited as a mirror of the gazette text only, not as an authority. [^10-2]: Greece, *Law 5038/2023* (Immigration Code, Government Gazette A′ 81/01.04.2023), Articles 11, 100 and 171, consolidated text (codification through Law 5307/2026), https://www.taxheaven.gr/law/5038/2023 (accessed 2 August 2026; Greek). The Article 11 §1 late-renewal rule appears in the consolidated text; the amending instrument has not been identified and the rule requires confirmation at the date of application. [^10-3]: Greece, National Registry of Administrative Public Services (mitos.gov.gr), "Permanent golden visa (change of use) – Initial issuance", last updated 31 July 2026, https://en.mitos.gov.gr/index.php/ΔΔ:Permanent_golden_visa_(change_of_use)_–_Initial_issuance (accessed 2 August 2026). [^10-4]: São Tomé and Príncipe Citizenship by Investment Unit, "Donation to the National Transformation Fund" (submission fee US$5,000 per application; contribution US$90,000 single applicant, US$95,000 family of two to four, US$5,000 each additional dependant; citizenship documents US$750 per applicant covering certificate of registration, passport and national identity card; separate US$5,000 due-diligence fee for the benefactor of a sponsored application), official programme site on the government domain, https://cip.gov.st/donation-to-the-national-transformation-fund (accessed 4 August 2026). The former domain stpcip.com now redirects here, superseding the archived capture of 19 April 2026 previously cited. Official government source; the schedule current at the date of application must still be confirmed. [^10-5]: São Tomé and Príncipe, Serviço de Migração e Fronteiras, official passport fee schedule (taxas), https://www.smf.st/taxas.php (accessed 2 August 2026; Portuguese). For the euro peg used to convert the dobra figure (€1 = 24.50 dobras since January 2010): US International Trade Administration, *Country Commercial Guide — São Tomé and Príncipe* (Trade Financing), https://www.trade.gov/country-commercial-guides/sao-tome-and-principe-trade-financing (accessed 2 August 2026). Reported tier; the peg rate requires confirmation. [^10-6]: Greece, *Law 5100/2024*, Article 64 (Government Gazette A′ 49/05.04.2024), as codified with Law 5167/2024, official consolidated text hosted by the Ministry of Migration and Asylum, 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; Greek). [^10-7]: PwC, *Worldwide Tax Summaries — Greece* (Individual: Other taxes; Income determination), last reviewed 16 February 2026, https://taxsummaries.pwc.com/greece (accessed 2 August 2026). Professional secondary source; reported tier. [^10-8]: Your Overseas Home, "Greece buying costs" (transfer tax 3.09%; notary, registry, lawyer and agent bands; 8%–10% rule of thumb), https://www.youroverseashome.com/greece/advice/greece-buying-costs/ (accessed 2 August 2026). Market secondary source; reported tier. [^10-9]: Greece, VAT Code (Law 2859/2000), Article 6 §1 (transfer of completed or semi-completed buildings before first installation or use; «πρώτη εγκατάσταση» as defined in Article 6 §1(β)); consolidated text, https://www.taxheaven.gr/law/2859/2000/article/6/view (accessed 2 August 2026; Greek). The suspension's current end date is reported per the two notes following. [^10-10]: KPMG, TaxNewsFlash, "Greece: VAT suspension on real estate extended to December 31, 2026" (Law 5246/2025, Government Gazette A΄ 198/11.11.2025), November 2025, https://kpmg.com/us/en/taxnewsflash/news/2025/11/tnf-greece-vat-suspension-on-real-estate-extended-to-december-31-2026.html (accessed 2 August 2026). Reported tier. [^10-11]: Grant Thornton Greece, «Νέος Φορολογικός Νόμος 5246/2025» (transfer tax applies in place of VAT where the suspension operates), 2025, https://www.grant-thornton.gr/insights/article/neos-forologikos-nomos-5246-2025/ (accessed 2 August 2026; Greek). Reported tier. [^10-12]: Greece, *Law 5038/2023*, Government Gazette A′ 81/01.04.2023 (gazette facsimile, elinyae.gr mirror), Articles 8, 10 §11, 14, 17, 19 and 20, https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf (accessed 2 August 2026; Greek). [^10-13]: Law Office I. Papadopoulos & Partners, published golden-visa fee schedule (power of attorney €300 + VAT; AFM €400 + VAT; bank account €300 + VAT; purchase legal work €2,000 + VAT; residence filing ≈€2,000–€3,500 per investor), https://epapadopoulos.com/golden-visa-greece/ (accessed 2 August 2026). Single-firm published schedule; reported tier. [^10-14]: propertycheck.gr, buyer-side inspection practice (time-billing; no published tariff), https://propertycheck.gr/ (accessed 2 August 2026; Greek). [^10-15]: proper.gr, Electronic Building Identity guide (dossier contents; Completeness Certificate; indicative €120–€250 for an apartment), https://proper.gr/ilektroniki-taftotita-ktiriou-odigos/ (accessed 2 August 2026; Greek). Reported tier. [^10-16]: Greece, *Law 4495/2017*, Article 83 (Government Gazette A′ 167/03.11.2017) — owner's declaration and engineer's certificate on every inter vivos transfer deed, consolidated text, https://www.taxheaven.gr/law/4495/2017/article/83/view (accessed 2 August 2026; Greek). [^10-17]: Greece, Joint Ministerial Decision 214926/2025 (Government Gazette B′ 6014/11.11.2025) — supporting documents for Article 100 permits (change-of-use documents §2.6, including insurance policy and engineer's report; renewal documents), FEK PDF and concordant reproductions, https://www.pomida.gr/assets/File/1236_20250206014.pdf and https://www.taxheaven.gr/circulars/51471/214926-10-11-2025 (accessed 2 August 2026; Greek). [^10-18]: Athens Translation Centre, published translation rates (€15 per page up to 230 words, + 24% VAT), https://athenstranslations.gr/en/rates (accessed 2 August 2026). Reported tier. [^10-19]: WordHub, "How much does an official translation cost in Greece?" (€30–€60 per one-page certificate), 10 April 2025, https://www.wordhub.gr/en/blog/official-translation-cost-greece (accessed 2 August 2026). Reported tier. [^10-20]: United Kingdom, Foreign, Commonwealth and Development Office, "Get your document legalised" (£45 standard; £35 e-apostille; £40 next-day; £100 restricted urgent), https://www.gov.uk/get-document-legalised (accessed 2 August 2026). [^10-21]: South Africa, Department of International Relations and Cooperation, Legalisation Services (no charge for legalisation of public documents; private documents via notary and High Court Registrar), https://dirco.gov.za/legalisation-services/ (accessed 2 August 2026). [^10-22]: iNotary Public London, published price schedule (single document ≈£60–£100 + VAT; upper published bands £90–£200+), https://inotarypublic.co.uk/notary-public-prices-london/ (accessed 2 August 2026). Reported tier. [^10-23]: Greece, Joint Ministerial Decision οικ. 53821/2014 of 21 October 2014 (private-insurance coverage minimums for third-country nationals), signed text hosted by the Ministry of Migration and Asylum, https://migration.gov.gr/wp-content/uploads/2020/05/ΚΥΑ53821_2014.pdf (accessed 2 August 2026; Greek). Fixed under the predecessor Code and still applied in practice; formal survival under Law 5038/2023 subject to confirmation. [^10-24]: Residence-permit insurance premium market data: insurancemarket.gr (from €68 per year); mygoldenvisa.io (about €300 per person); soeasyinsurance.gr (product mirroring the coverage minimums), https://www.insurancemarket.gr/asfalisi-allodapon-adeia-diamonis ; https://mygoldenvisa.io/blog/greece-golden-visa ; https://soeasyinsurance.gr/immigration-medical/ (accessed 2 August 2026). Reported band; written quotations required. [^10-25]: Cambridge Currencies, specialist-broker versus bank foreign-exchange margins (banks "commonly build a margin of 2–4% into the exchange rate"; brokers often well under 1% on larger amounts), 29 May 2026, https://cambridgecurrencies.com/cambridge-currencies-specialist-broker-bank-rates/ (accessed 2 August 2026). Reported tier; illustrative arithmetic. [^10-26]: Kestrel Private, published fees page, https://kestrelprivate.com/fees (accessed 4 August 2026). [^10-27]: Corpenza, "Greece IKE company formation for foreigners: cost, tax and registration" (€18 electronic filing; €1 minimum capital), 28 July 2026, https://corpenza.com/en/greece-ike-company-formation-for-foreigners-cost-tax-registration (accessed 2 August 2026). Reported tier. [^10-28]: EU Inc Now, "Company formation in Greece" (formation €100–€200; non-resident AFM/representation €200–€500; accounting €80–€200 per month), https://euincnow.com/company-formation-greece (accessed 2 August 2026). Reported tier. [^10-29]: Nexora Cyprus, "Cyprus company formation costs" (all-in €700–€1,500; registrar ≈€165; €350 annual levy abolished from 2024), March 2026, https://nexoracyprus.com/articles/cyprus-company-formation-costs (accessed 2 August 2026). Reported tier. [^10-30]: Koufettas Law, "Cyprus company formation cost: 5-year breakdown" (provider €1,200–€3,000 / law firm €1,500–€4,000+; dormant ≈€2,420–€4,000 per year; small trading ≈€3,880–€6,920 per year), updated 9 April 2026, https://koufettaslaw.com/cyprus-company-formation-cost-5-year-breakdown/ (accessed 2 August 2026). Reported tier. [^10-31]: Kestrel Private, "One coordinated international position" (three-stage worked example; citizenship stage priced at €100,000; €15,000 company stage), https://kestrelprivate.com/international-structure (accessed 2 August 2026). The €100,000 citizenship-stage figure is a euro amount and must not be read as the same number as the US$100,000 headline used elsewhere on the same site; this report neither reproduces nor reconciles that stage's composition (§10.12). [^10-32]: taxheaven.gr, news item 58595 — ENFIA structure and coefficient tables under Law 4916/2022 (per-m² basic tax by zone band; basis of the illustrative €300–€700 band), 2022, https://www.taxheaven.gr/news/58595/ (accessed 2 August 2026; Greek). Reported tier. [^10-33]: Greece, *Law 2130/1993*, Article 24 (municipal duty on real property, 0.25‰–0.35‰, collected via the electricity bill), consolidated text, https://www.forin.gr/laws/law/3240/telos-akinitis-periousias-nomos-2130-1993-arthro-24 (accessed 2 August 2026; Greek). [^10-34]: estiagreekhome.online, "Choosing a Greek tax representative" (basic compliance tier ≈€250–€500 per year; rental filings in tiers ≈€1,000–€2,500), 2026, https://estiagreekhome.online/blog/choosing-greek-tax-representative (accessed 2 August 2026). Single market source; reported band only. [^10-35]: esd.gr, «ΕΝΦΙΑ 2026: αναλυτικός οδηγός» (2026 payment schedule; instalment plans), 2026, https://esd.gr/enfia-2026-neow-odigos-me-erotiseis-kai-apantiseis/ (accessed 2 August 2026; Greek). Reported tier. [^10-36]: Greece, *Law 5104/2024*, Article 8 (Tax Procedure Code — tax representative «δύναται», discretionary at code level), consolidated text, https://www.taxheaven.gr/law/5104/2024/article/8/view (accessed 2 August 2026; Greek). [^10-37]: Greece, *Law 3427/2005*, Article 23 (E9 property declaration by 31 January of the year following acquisition), consolidated text, https://www.taxheaven.gr/law/3427/2005/article/23/view (accessed 2 August 2026; Greek). [^10-38]: AADE, "FAQs for Greeks abroad and Non-residents" (November 2025 edition), FAQ 28 (a foreign tax resident files a Greek return only where real Greek-source taxable income arises; the E9 declaration as the common first compliance failure of foreign owners), https://www.aade.gr/sites/default/files/2025-11/FAQs_omogeneis_en_0.pdf (accessed 2 August 2026). [^10-39]: 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); daily file at https://www.ecb.europa.eu/stats/eurofxref/eurofxref-daily.xml. The same series gives US$1.1485 on 31 July 2026 and, over the 255 trading days in the 12 months to 3 August 2026, a mean of US$1.1639, a minimum of US$1.1340 and no observation at US$1.10 (last recorded 8 April 2025); the 12-month distribution statistics are computed by this report from that published series. Cited for the reference point against which the report's planning assumption is set; it is not the rate used in this report's conversions. [^10-40]: Greece, *Α.Ν. 1521/1950* (real-estate transfer tax), Article 4 §§1 and 3 (3% main rate at §1; §3 apportioning 3.00% of the tax collected to municipalities, an apportionment provision and not a surcharge on the buyer), consolidated text, https://www.taxheaven.gr/law/1521/1950/article/4/view (accessed 4 August 2026; Greek). The instrument imposing the municipal element charged in practice has not been identified; the effective 3.09% is reported, not verified.