# 12. Capital Allocation and the Retained Asset The reference structure deploys capital in two fundamentally different ways: money that is spent, and money that is invested in an asset the client continues to own. This chapter separates the two, prices the friction between them, and then subjects the retained asset to the discipline any investment committee would apply: a base case, a zero-growth case, a downside case calibrated to the verified Greek market history, and an exit analysis. The zero-growth and downside cases are presented with the same prominence as the base case. Nothing in this chapter is a forecast, and no outcome described here is assured. ## 12.1 Contribution capital versus retained capital The €375,000 single-applicant reference case (§1.5, built bottom-up in Chapter 10) divides into three parts. | Component | Amount | Share | Character | |---|---:|---:|---| | Qualifying Greek property (Component C) | €250,000 | 66.7% | Retained — invested in an asset the client owns | | Known programme charges: São Tomé contribution US$90,000 (€78,261), due-diligence and processing fee US$5,000 (€4,348), Greek permit fee €2,000, residence-card charge €16 | €84,625 | 22.6% | Spent — non-recoverable once paid | | Allowance for transaction taxes, professional fees, translations, insurance and other implementation costs | ≈€40,375 | 10.8% | Spent — non-recoverable once incurred | | **Total reference case** | **≈€375,000** | **100%** | | Assumptions and sources: single applicant; the report's working exchange rate of €1 = US$1.15 per §10.2. That rate is a planning assumption, not a market rate and not a forecast (§10.2): the European Central Bank's euro foreign exchange reference rate stood at 1.1535 on 3 August 2026, and 1.15 sits below that reading, below the twelve-month mean and inside the range actually observed over the year to that date.[^12-47] Converted amounts are rounded to the nearest euro and the components as printed sum to €375,000; percentages are rounded to one decimal and therefore sum to 100.1%, not 100%. Programme charges: Decree-Law No. 07/2025, Anexo I (São Tomé),[^12-1] and the €2,000 permit fee plus €16 card charge for the Greek B.5 permit.[^12-2][^12-3] The allowance line is examined item by item in §10.6–§10.15; Chapter 11 shows how family composition changes the mix. One-third of the reference outlay is contribution capital: it purchases rights and processes, not assets. The São Tomé contribution is by law non-refundable and payable only after approval; the US$5,000 due-diligence fee is non-refundable once the application is submitted.[^12-1] The Greek fees, taxes and professional costs are consumed in implementation. None of this €125,000 returns to the client under any scenario. One real client cost belongs on the citizenship side and is easily overlooked. A São Tomé and Príncipe application is filed through the designated application channel, which publishes that applications are initiated through licensed marketing agents (§6.5, §18.3). The licensed submitting agent's retainer is therefore a cost the client genuinely bears, and it is not one of the government charges in the table above. It is carried at **€4,348**: an allowance of US$5,000 at the report's planning assumption of €1 = US$1.15, distinct from the programme's own US$5,000 due-diligence and processing fee in the table above, and the same figure on every costed configuration (§10.14). What that figure is, and is not, must be stated exactly. It is an allowance carried in Kestrel Private's own cost model, dollar-denominated and therefore moving with the programme's other dollar charges. It is not published, it is not gazetted, and it is not sourced to any instrument. A written quotation is required before engagement, and the line requires confirmation at the date of application. Within that spent capital, the allowance carries two charges before it reaches a single third-party implementation line. Kestrel Private's professional engagement fee is charged per application, because each application is a separate body of work: a separate set of counterparties, a separate schedule of disbursements, and a separate government reaching a separate decision. One fee arises on the São Tomé and Príncipe citizenship application and one on the Greek investor residence application (§10.11). A client who instructs only one of the two programmes pays one fee. The reference case instructs both, so **€18,000 of the €40,375 allowance is Kestrel Private's own charge**, and the submitting agent's retainer allowance takes a further €4,348. That leaves approximately €18,027 for transaction taxes, notarial and registry charges, translations and apostilles, insurance, banking and contingency. Acquisition friction alone is modelled at €14,855–€32,795 (§12.4, mid-point €23,825): at the low end of that range acquisition friction consumes more than four-fifths of what remains, and from the mid-point upwards the allowance is exhausted before any of the other implementation lines is priced. The allowance itself does not move. It is the residual between the €375,000 planning figure and the known base of €250,000 plus €84,625, and neither of those moves. What moves is what the residual must absorb. Priced item by item at §10.14, and now including the submitting agent's retainer allowance, the allowance's own list totals €40,600 at the lean end of every band, €62,463 in the heavy configuration and €76,263 at the top of every band: shortfalls against €40,375 of €225, €22,088 and €35,888 respectively. The corresponding all-in figures are €375,225, €397,088 and €410,888. **The €375,000 figure therefore holds for the leanest costed configuration and is exceeded as the configuration grows.** It is a planning reference that the lean case narrowly exceeds once every real cost is counted, and a defensible single-applicant planning figure is approximately €376,000; §20.2 states the consequence for the structure's cost model as a whole. Restated on the leanest of those configurations, the division between spent and retained capital moves against the client. | Component | Lean all-in amount | Share | Character | |---|---:|---:|---| | Qualifying Greek property (Component C) | €250,000 | 66.6% | Retained — invested in an asset the client owns | | Spent: known programme charges €84,625, plus the allowance's own list priced at the lean end of every band, €40,600 | €125,225 | 33.4% | Spent — non-recoverable once paid or incurred | | **Lean all-in total** | **€375,225** | **100%** | | Assumptions and sources: the same single applicant and the same €1 = US$1.15 planning assumption as the table above; the lean column of the §10.14 stress test, which prices every band at its lean end simultaneously and includes both of Kestrel Private's per-application fees (€18,000), the €4,348 submitting agent's retainer allowance and the €652 São Tomé post-approval document allowance. Components foot to the total (€250,000 + €84,625 + €40,600 = €375,225) and percentages are rounded to one decimal. This is the report's leanest costed configuration, not its central one; the heavy and top configurations move the spent share further, to €397,088 and €410,888 all-in. The remaining two-thirds (€250,000) is retained capital: it remains invested in a specific Greek property in the client's full ownership. The optional company, banking and tax layer (the staged company provision costed at §10.12) sits outside the €375,000 reference case and is likewise spent, not retained. It carries no Kestrel Private professional engagement fee at all: its cost is entirely third-party, being corporate registrar and formation charges, corporate-service provision and the corporate team that performs the work. Kestrel Private's fee arises on the two programme applications only: two fees in the reference case, and never a third. This division is the correct starting point for any assessment of what the structure costs. It is not the end point, because retained capital carries its own risks: the subject of the rest of this chapter. ## 12.2 What "retained in property" means Retention here has a precise legal content. The applicant must acquire full ownership and possession of one property with a minimum acquisition value of €250,000 at the time of purchase.[^12-2] The client holds registered title. The property may be let on a long-term basis;[^12-2] it generates any rental income the market provides; it can be sold, with the proceeds belonging to the client; and it passes on death under the applicable succession rules (see §8.4 and Chapter 16 for title and documentation, §9.10 for taxation of the income). Ownership is therefore real, and the distinction from a donation-based programme, in which the equivalent capital is simply gone, is genuine. It is the basis on which the structure's public presentation describes €250,000 as remaining the client's at the end of implementation. But the retained asset is retained subject to conditions that ordinary property ownership does not carry: - Selling the qualifying property while the permit is valid revokes the seller's residence permit (see §7.12).[^12-2] - Short-term letting and sub-letting are prohibited for this category; breach carries revocation of the permit and a standalone administrative fine of €50,000.[^12-2] - A change-of-use property may not be used as the seat or branch of a business.[^12-2] - A residential lease to a tenant using the property as a primary residence binds the landlord for a minimum of three years, even where a shorter term is agreed. This rule is reported by convergent professional sources; the gazette text of the governing instrument has not been read for this report and requires confirmation at the date of application.[^12-4] The asset is therefore best described as a retained but encumbered investment: owned outright, income-producing only within a restricted letting regime, and operationally illiquid for as long as the client wishes to keep the residence position it supports. ## 12.3 Why retained does not mean guaranteed Ownership says nothing about value. The executive summary states the principle (the fact that the client owns the property does not mean the capital is preserved or readily recoverable), and the verified market record shows why the distinction is not theoretical. Greek apartment prices, on the Bank of Greece national index, fell 42.4% in nominal terms from their peak in Q3 2008 to their trough in Q3 2017 — nine consecutive negative years, with single-year falls of 11.7% (2012) and 10.9% (2013).[^12-5] The Athens index fell 44.7% peak-to-trough over the same cycle.[^12-6] Deflated by the Greek harmonised index of consumer prices, the national fall was approximately 46% in real terms; as of the 2025 annual data, 17 years after the peak, prices had recovered in nominal terms only, and remained approximately 18% below their 2008 level in real terms.[^12-5][^12-7] Three further features of the specific asset class compound the market risk: 1. Floor-set pricing. A conversion unit sold at exactly €250,000 and sized 60–100 m² implies €2,500–4,167/m² — at or above central-Athens average asking levels, for product concentrated in districts where conventional stock trades well below the Athens average. The statutory threshold, not local comparables, sets the price of eligible product (an analytical conclusion from the price data, not an official statistic).[^12-8][^12-9] Econometric evidence from Portugal's programme found transaction prices exceeding fiscal values by an average of approximately €38,000 at that programme's €500,000 threshold (a more than 10% price increase), with bunching at the threshold; no equivalent Greek study exists, and the mechanism is stated here as analysis.[^12-10] The scale of that premium cannot be measured. No verified district-level price series for the conversion districts was located, and no Greek econometric study of the effect exists. Its likely range can, however, be bounded on verified premises. The lower bound is the only measured investor-permit price effect in the literature — the Portuguese finding above, more than 10% at that programme's threshold. The upper bound is the implied €/m² gap: €2,500–4,167/m² for floor-priced product, in districts where conventional stock trades well below the Athens average, against a reasoned band of €500–1,200/m² for the conversion works that create the product.[^12-11] This report therefore uses a band of **20–50% of the entry price** as its analytical measure of the floor-set premium. It is a reasoned range on verified premises, not a verified series; it is used only in the separately labelled overlay at §12.9 and §12.11, and nowhere in the base or zero-growth cases. 2. Concentrated, investor-held supply. Reported market coverage describes 1,000–2,000 completed Athens conversion apartments marketed from spring 2026 and an estimated 3,000–5,000 more by 2027, clustered in a small number of districts, with approximately 94% of properties acquired under the investor-permit route never owner-occupied.[^12-12] 3. Currency exposure. The asset is a euro asset; its value in the client's home currency moves with the exchange rate (see §14.13). None of the above means the property will lose value. It means that capital preservation, appreciation, rental income and resale liquidity cannot be guaranteed, and that the phrase "retained asset" must always be read as "retained, at risk". Chapter 8 applies this discipline to property selection; §8.15 states the property-without-immigration test that follows from it. ## 12.4 Acquisition friction and unrecoverable costs Part of the capital deployed against the property never enters the asset at all. The one-off acquisition stack — taxes, notarial and registration charges, legal fees and due diligence — is consumed on day one; the client's recoverable position immediately after completion is the property alone. Greek tax and cost figures, and Greek procedural requirements, in this section and the rest of this chapter are reported by convergent professional sources against the governing instruments; each remains subject to confirmation against the gazette text and current schedules at the date of application. | Item (on a €250,000 acquisition) | Basis | Low | High | |---|---|---:|---:| | Real-estate transfer tax (FMA) with municipal surcharge | 3.09% of taxable value | €7,725 | €7,725 | | Notarial fees | 0.8–1.2% + 24% VAT | €2,480 | €3,720 | | Land registry / cadastre registration | ≈0.5% + fixed charges | €1,250 | €1,250 | | Legal fees (conveyancing) | ≈1–2% + 24% VAT | €3,100 | €6,200 | | Buyer's agent (only where instructed) | 2–4% + 24% VAT | €0 | €12,400 | | Technical due diligence (conversion property) | quotation-based band | €300 | €1,500 | | **Total acquisition friction** | | **€14,855** | **€32,795** | | Mid-point of the range | | **€23,825** | | | As a share of the €250,000 retained capital | | **5.9%** | **13.1%** | Assumptions and sources: taxable value assumed equal to the €250,000 price and the transaction assumed to bear FMA rather than VAT (the expected treatment for the reference acquisition, confirmed property-by-property, §8.6); percentage bands are reported market bands, not tariffs;[^12-13][^12-14] the technical-due-diligence band is a reasoned analysis figure in a market with no published tariff — written quotations are required.[^12-15] The mid-point is the arithmetic mean of the low and high totals and is the figure §12.11 models. The table excludes currency-conversion costs (bank FX margins commonly 2–4% of the amount converted against typically under 1% through specialist brokers — a swing of several thousand euro on the sums involved),[^12-16] and excludes the wider implementation stack (permit fees, translations, apostilles, insurance, the licensed submitting agent's retainer allowance on the citizenship side, and Kestrel Private's fixed professional engagement fee charged for each of the two applications), which Chapter 10 itemises. A commonly quoted all-in rule of thumb for Greek acquisition costs is 8–10% of price; the mid-point above is 9.5%.[^12-13] Two consequences follow. First, between roughly €15,000 and €33,000 of the money deployed against the property is unrecoverable from the first day: the property must appreciate by 5.9–13.1% merely to return the client's property-side outlay in nominal terms, before any exit costs. Second, the friction is asymmetric: it is incurred with certainty, while the offsetting appreciation is uncertain. The scenario analysis below therefore measures every outcome against the full entry outlay, not the €250,000 price alone. ## 12.5 Rental-income assumptions The letting regime is fixed by statute. Long-term letting is expressly permitted; short-term (sharing-economy) letting and sub-letting are prohibited for this category, on pain of permit revocation and a €50,000 fine; and the property may not house a business.[^12-2] Any income model that assumes short-term letting yields is unlawful for this asset and must be disregarded. A residential lease binds the landlord for a minimum of three years, on the reported basis stated at §12.2;[^12-4] from 1 April 2026, residential rent is reported to require payment into a landlord bank account declared to the tax authority, with the 5% deemed-expense deduction forfeited on non-compliance.[^12-17] Gross yield. Portal-aggregator data (asking prices and asking rents — transacted yields are lower) put the Greek average gross residential yield at 4.38% and the Athens average at 5.52%, with the cheaper central districts where conversion stock concentrates showing the highest gross figures.[^12-8] Because the €250,000 statutory floor sets the price of eligible product above district comparables (§12.3), a floor-priced unit yields less per euro than the district averages suggest. This report adopts a planning band of 4.0–5.0% gross (€10,000–12,500 a year, or roughly €833–1,042 a month) as an analytical judgement from that data, not an observed transacted figure. Reported market colour is consistent with caution: realtors report earlier investor-permit owners letting units 10–15% below comparable market rents.[^12-18] Rent growth is currently positive and decelerating (asking rents: national +4.2%, Attica +3.9% year-on-year in Q1 2026).[^12-19] Taxation of the income. Rental income of individuals is taxed on a progressive schedule which, from tax year 2026, is reported as 15% up to €12,000, 25% from €12,000.01 to €24,000, 35% to €36,000 and 45% above, applied to 95% of gross rent (a flat 5% deemed-expense deduction; actual operating costs of an individual landlord are not otherwise deductible).[^12-20][^12-21][^12-22] A non-resident owner is taxed in Greece on this Greek-source income and must file accordingly (see §9.10 for the fuller treatment, including home-country taxation of the same income). Worked at the band mid-point: €12,000 of gross rent produces tax of €1,710, an effective 14.25% of gross. Occupying the property instead. Personal owner-occupation does not ordinarily generate deemed property income equal to 3% of the property's value; the 3% rule principally concerns specified self-use or free-concession arrangements. Occupation may, however, be relevant to Greece's separate objective-expenditure or presumed-living-cost rules, whose operation for a non-resident and for a Greek tax resident is set out at §9.10.[^12-48] The consequence for this chapter is arithmetical rather than fiscal: every scenario below assumes the property is let, and a year of personal occupation is a year of ownership costs (§12.6) with no income to set against them. All rental figures are assumptions for modelling. Rental income cannot be guaranteed, and periods without a tenant produce no income while the ownership costs of §12.6 continue. ## 12.6 Management and maintenance Annual ownership costs are itemised for property selection at §8.12; this section fixes the allowances the scenarios use. - ENFIA (annual property tax): illustratively €300–700 for a €250,000 Athens apartment below the €500,000 surcharge threshold; a 20% discount is reported for residences insured against fire, earthquake and flood.[^12-23][^12-20] The exact figure requires the tax authority's calculation on the selected property. - Municipal duty (TAP): 0.25–0.35‰ of assessed value, collected through the electricity bill; from 1 January 2027 it is reported to be replaced by a Local Development Fee of 0.30–0.70‰.[^12-24][^12-20] - Compliance: outsourced non-resident tax compliance is reported at roughly €250–500 a year for basic filings, with rental filings in higher tiers — confirmed by written quotation.[^12-25] - Management: 5–10% of gross rent where an agent is instructed (an assumption; absentee ownership makes some form of management difficult to avoid). - Maintenance and repairs: material on Athens stock averaging more than 40 years of age;[^12-18] building-specific common charges apply in addition. - Voids: no official rental-vacancy series exists. The 2021 census recorded 26.8% of Municipality of Athens dwellings vacant — a figure that includes second homes and derelict stock and is not a rental-market vacancy rate, but which evidences a large idle stock.[^12-26] No verified source on the procedure or timelines for recovering possession from a non-paying tenant was located; that point requires confirmation at the date of application. The scenarios therefore adopt a single all-in operating allowance of **15–25% of gross rent** (mid-point 20%), covering management, maintenance, insurance, ENFIA and municipal charges, compliance and normal voids. This is a stated assumption, not a verified figure; a severe void or a major repair would exceed it. Netting the allowance and tax from the §12.5 band gives a net-of-everything running yield of approximately **2.6–3.3% on the €250,000 price, or 2.4–3.0% on the full entry outlay** of €273,825 used below, before any capital movement, in either direction. ## 12.7 Base-case property scenario The base case assumes the current cycle continues in moderated form: nominal rent and price growth of 2–3% a year (mid-point 2.5% used in §12.11). This sits deliberately below current momentum (national apartment prices rose 5.7% year-on-year in Q1 2026, Athens 5.2%) because the deceleration is verified: Athens growth has slowed from +13.9% (2023) to +8.5% (2024) to +6.2% (2025) to +5.2% (Q1 2026), fading fastest in the districts where investor-permit purchases concentrated, and net foreign inflows into Greek property — the marginal buyer of exactly this stock — fell approximately 25% in 2025.[^12-27][^12-6][^12-28] On the §12.11 arithmetic the base case produces a ten-year outcome of approximately +40% nominal on the full entry outlay (approximately +3.4% a year), of which the larger part is accumulated net rent rather than price gain. In real terms, at an assumed 2.5% inflation, the outcome is approximately +9% over the decade, or +0.9% a year. Those figures are struck after the capital-gains tax of §12.10 on the assumption that the current suspension is not extended; if it is, the base case is approximately +42% nominal and +11% real. The base case is an illustration of moderate success, not a projection; it assumes ten years of uninterrupted letting at the modelled allowance, no extraordinary repairs, an unchanged letting regime and an orderly exit at full market value. ## 12.8 Zero-growth scenario The zero-growth case holds prices and rents flat in nominal terms for ten years. It is not a stress case. Greek residential prices went sideways-to-down for nearly a decade within living memory; a flat nominal decade is the reversed historical median experience, not an extreme.[^12-5] With no capital growth, the return is net rent alone: approximately €74,000 accumulated over ten years on the §12.11 assumptions, against which entry friction (€23,825 modelled) and exit costs (≈€11,250) are charged. The nominal outcome is approximately +14% on the full outlay over ten years — approximately +1.3% a year. In real terms the outcome is negative: at inflation of 2.5–3% a year (Greek HICP: +3.0% in 2024, +2.9% in 2025), a flat €250,000 commands roughly €195,000 of today's purchasing power at year 10, and the all-in real outcome is approximately −10.8%, or −1.1% a year.[^12-7] The zero-growth case is the honest planning centre of gravity for a client who treats the property primarily as the price of the residence position: it shows the structure carrying itself in nominal terms while quietly losing ground in real terms. ## 12.9 Downside scenario The downside case is not invented. It is calibrated to the verified record of the last severe Greek cycle, set out at §12.3: a 42.4% national nominal fall peak-to-trough (Athens 44.7%) over nine consecutive negative years, approximately 46% in real terms.[^12-5][^12-6][^12-7] Two further features of that episode bear directly on the modelling: - Housing rents (Eurostat harmonised series, ELSTAT-compiled) fell 25.8% nominal from their 2011 peak to their 2018 trough — approximately 25% real — lagging the price cycle by roughly three years, and then sat at the floor for three further years. By 2025 rents remained approximately 24% below their 2011 peak in real terms.[^12-7] - Transactions collapsed and residential property became effectively illiquid for years; no official time-on-market series exists, and the honest formulation is that in such conditions sales take years, not months.[^12-5][^12-27] The §12.11 downside row transposes that history onto the holding period: prices −42% over the window, rents declining to −26% and holding at the floor, an orderly (not forced) sale at the end. The nominal outcome is approximately −26% on the full outlay; in real terms, using the historical episode's own cumulative inflation of +8.1%, approximately −32%. Had a comparable nominal decline occurred under present inflation rates, the real outcome would be materially worse. A separate, labelled analytical overlay: premium reversion. The historical index fall happened to conventionally priced stock. A floor-priced conversion unit carries an additional exposure the index does not capture: if the €250,000 category closes, thresholds rise, or the investor-permit bid otherwise withdraws, the exit price reverts toward district fundamentals before any market-wide decline is applied. §12.3 derives the analytical measure of that premium as 20–50% of the entry price, and §12.11 applies it on the convention price × (1 − p): a €250,000 unit reverts to €200,000 at the mild end of the band and €125,000 at the severe end, and the index decline is then applied to that reverted figure. This overlay is analysis on verified premises, not a verified series; §12.11 shows it as a distinct band. Two structural features make the downside stickier than for ordinary property: selling to cut losses revokes the residence permit,[^12-2] and a sitting tenant on a three-year lease constrains vacant-possession timing, on the reported basis stated at §12.2.[^12-4] The downside case is as legitimate a planning input as the base case. It happened, in this market, to this asset class, within the last two decades. ## 12.10 Resale and exit scenario Who buys. While the €250,000 change-of-use category remains open on current terms, the natural buyer of a second-hand conversion unit at or above €250,000 is another investor-residence applicant: the statute expressly contemplates resale during the permit's validity to a third-country national, who acquires a permit right while the seller's permit is simultaneously revoked, and requires certification of whether the property has previously been used for a permit.[^12-2] Whether a conversion property that has already supported a permit can qualify a new €250,000 application is, however, an open administrative question: professional commentary on Circular 1/2026 reports that a property previously used for an investor residence permit cannot be redeployed at €250,000 by another investor, and the position requires confirmation at the date of application.[^12-29] If the investor-permit bid is absent at exit — because of that rule, a category closure or a threshold rise — residual value is set by local purchasers at district price levels materially below floor-set pricing (§12.3), in competition with the 2026–2027 conversion pipeline concentrated in the same districts.[^12-12] This buyer-pool reasoning is analysis on verified rules, and it is the single most important exit consideration in the chapter. What a sale costs. The seller-side stack, at reported bands: agent's commission 2–4% + 24% VAT where instructed (each party customarily pays its own agent); legal fees ≈1–2% + VAT where instructed; an Energy Performance Certificate, mandatory on sale;[^12-30] an engineer's certificate and owner's declaration that no unauthorised constructions or uses exist, required on every inter vivos transfer deed and valid for two months;[^12-31] an ENFIA certificate evidencing the property declared and the tax settled for the preceding five years, without which the notary may not execute the deed (the article number of this requirement after recodification of the tax procedure code requires confirmation at the date of application);[^12-32] and the seller's tax-clearance certificate in practice. The municipal TAP-clearance certificate is no longer required: the requirement is reported abolished with effect from 1 January 2024, although the repealing instrument has not been pinned and the date requires confirmation at the date of application.[^12-33] A planning figure of approximately 3–6% of gross sale price with an agent (1–2% without) is used in §12.11.[^12-13] The buyer's own 3.09% transfer tax burdens the achievable price (an incidence observation, stated as analysis). Capital gains tax. The 15% individual capital-gains tax on Greek real estate (Article 41 of L.4172/2013) is suspended through 31 December 2026 pursuant to Article 90 of L.5162/2024; as at 2 August 2026 an individual seller pays no Greek CGT on a sale completed by that date.[^12-34] Nothing is enacted beyond 31 December 2026; a further extension and permanent abolition are both reported to be under consideration.[^12-35] Because a ten-year hold ends far beyond the enacted horizon, §12.11 models the revived tax as the default for a year-10 exit and prints the suspension-survives case alongside it. If the suspension lapses, Article 41 as currently drafted taxes the whole documented gain since acquisition at 15%, reduced by holding-period coefficients (100% in year one, falling to 84.5% at ten years on the reproduction read — the coefficient table rests on a single consolidated source and requires confirmation) and by up to €25,000 where the property was held at least five years; on the texts currently in force there is no rebasing for gain accrued during the suspension.[^12-36] Worked illustratively: a €250,000 purchase sold at €300,000 in year 10 would bear approximately €2,588, about 0.9% of proceeds. The revived tax is a modest line at reference-case scale; the headline exit risks remain price level and liquidity. Timing constraints. A sale while the permit is valid revokes it;[^12-2] a sale with vacant possession must respect the three-year minimum lease, on the reported basis stated at §12.2;[^12-4] and a sale into a weak market may take years (§12.9). Kestrel Private's assessment must therefore establish, before implementation, whether the client can hold the position to or beyond the five-year permit horizon, and must sequence and price the residence consequence of any earlier sale in advance (see §13.5 and §14.14). ## 12.11 Ten-year illustrative return analysis The table below runs the three scenarios on a single, fully stated set of assumptions. It is an illustration of mechanics, not a projection of outcomes. | Ten-year path (single set of assumptions) | Cumulative net rent, years 1–10 | Terminal property value | Exit costs and tax on exit | Total outcome (rent + net proceeds) | Versus €273,825 outlay, nominal | Annualised, nominal | Versus outlay, real | Annualised, real | |---|---:|---:|---:|---:|---:|---:|---:|---:| | Base case (+2.5%/yr prices and rents) | €82,514 | €320,021 | −€19,526 | €383,009 | +39.9% | +3.4% | +9.3% | +0.9% | | Zero growth (0%/yr nominal) | €73,969 | €250,000 | −€11,250 | €312,719 | +14.2% | +1.3% | −10.8% | −1.1% | | Downside (2008–2017 transposed: prices −42%, rents to −26%) | €63,391 | €145,000 | −€6,525 | €201,866 | −26.3% | −3.0% | −31.8% | −3.8% | | Downside including premium reversion (analytical overlay band) | €63,391 | €72,500–€116,000 | −€3,263 to −€5,220 | €132,628–€174,171 | −51.6% to −36.4% | −7.0% to −4.4% | −55.2% to −41.2% | −7.7% to −5.2% | Assumptions and sources, stated in full: Entry: €250,000 acquisition (statutory minimum)[^12-2] plus €23,825 modelled acquisition friction (the mid-point of the §12.4 range, and 9.5% of price, within the reported 8–10% rule of thumb[^12-13]) for a total outlay of €273,825. Outlay sensitivity: at the §12.4 low (friction €14,855, outlay €264,855) the three principal rows read +44.6% / +18.1% / −23.8% nominal; at the §12.4 high (friction €32,795, outlay €282,795) they read +35.4% / +10.6% / −28.6%. Income: year-1 gross rent €11,250 (4.5% gross, the §12.5 band mid-point — analytical, asking-based data);[^12-8] all-in operating allowance 20% of gross (§12.6 assumption); rental tax on 95% of gross at the reported tax-year-2026 scale (15% to €12,000 taxable, 25% band above — the 25% band engages in later base-case years);[^12-20][^12-21][^12-22] rents assumed otherwise fully collected; net cash held uninvested to year 10 (no reinvestment credit; cash-flow timing is ignored, which understates well-performing paths relative to a discounted measure). Growth paths: base +2.5%/yr on rents and prices; zero-growth flat; downside prices −42% over the window and rents declining linearly to −26% by year nine then flat, per the verified 2008–2018 series.[^12-5][^12-6][^12-7] Exit: orderly sale at 4.5% costs (mid of the 3–6% with-agent band; the downside additionally assumes the sale is achievable at all, which the 2008–2017 record does not support on short notice).[^12-13] Premium-reversion band: the §12.3 analytical band of 20–50% is applied on the convention terminal-before-decline = €250,000 × (1 − p), giving €200,000 and €125,000, to which the −42% index decline is then applied — analysis, not a verified series (§12.9). Tax on exit: Article 41 is modelled as revived for a year-10 sale, since nothing is enacted beyond 31 December 2026; the base case therefore bears €5,125 (gain €70,021 × 84.5% coefficient − €25,000, at 15% — coefficient single-source, requires confirmation), included in the exit column, and the other rows nil (no gain). If the suspension is instead extended or the tax abolished, the base case reads €388,134, +41.7% nominal, +3.6% a year, +10.7% real, +1.0% a year, and no other row changes.[^12-34][^12-36] Real terms: base and zero-growth deflated at an assumed 2.5%/yr (anchored on HICP +3.0% in 2024, +2.9% in 2025); the downside rows use the historical episode's cumulative +8.1% (2008–2017) — under present inflation the same nominal fall would be worse in real terms.[^12-7] Annualised figures are geometric equivalents of the ten-year totals. Figures rounded to the nearest euro; components foot to the totals shown. Currency: euro throughout; home-currency outcomes differ with the exchange rate (§14.13). Greek tax figures are reported-tier and subject to confirmation at the date of application. Three readings of the table are fair, and all three should be made together. First, on the stated assumptions the structure's property component can plausibly carry itself: even the zero-growth path returns its nominal outlay with a modest surplus — +14.2% on the modelled friction, falling to +10.6% if friction runs at the top of the §12.4 range. Second, the real-terms columns are less comfortable: only the base case preserves purchasing power, and a flat decade quietly costs about 1% a year in real terms. Third, the downside is not survivable-by-assumption: a repeat of the verified 2008–2017 cycle, applied to this asset, loses between a quarter and a half of the outlay depending on how much of the entry premium survives — and the same history says the position could not have been exited quickly at any acceptable price. Kestrel Private's assessment must establish whether the client can hold the position through that full range of outcomes without needing the €250,000 to behave as a store of value; where it cannot, the structure is not suitable (see §13.6–§13.7 and §13.14). No probability weights are assigned to the scenarios, deliberately. The verified record establishes that each path is possible; it does not establish which is likely over any particular decade. ## 12.12 Comparison with contribution-heavy structures The main structural alternative in the current market is the Caribbean donation route, in which the entire qualifying sum is a non-refundable contribution. The published minimum contributions of the five Eastern Caribbean programmes, from the responsible units' official schedules as at 2 August 2026: | Programme (donation route) | Single applicant | Family up to four | Recoverable element | |---|---:|---:|---| | St Kitts and Nevis — Sustainable Island State Contribution | US$250,000 | US$250,000 | None | | Dominica — Economic Diversification Fund | US$200,000 | US$250,000 | None | | Grenada — National Transformation Fund (Grenada) | US$235,000 | US$235,000 | None | | Antigua and Barbuda — National Development Fund (plus processing US$10,000 / US$20,000) | US$230,000 | US$230,000 | None | | Saint Lucia — National Economic Fund | US$240,000 | US$240,000 | None | | Reference structure — São Tomé contribution to the National Transformation Fund (São Tomé and Príncipe), Component A | US$90,000 | US$95,000 | None (contribution); the European position is funded separately by the €250,000 retained property | Assumptions and sources: official citizenship-investment-unit fee pages and gazetted schedules, accessed 2 August 2026;[^12-37][^12-38][^12-39][^12-40][^12-41] headline contribution rules only, before due-diligence, processing, document and additional-dependant fees, whose age thresholds and amounts differ by programme — fee rules are stated here, never constructed family totals. Two distinct funds share the name National Transformation Fund — Grenada's and São Tomé's; each is identified by its state in the table. All figures US dollars as published. Each Caribbean programme also offers real-estate routes (US$200,000–600,000 depending on route and state, plus substantial government fees, with statutory holding periods of three to seven years in approved, largely programme-linked stock); those routes raise the same eligibility-versus-investment-quality questions examined in Chapter 8 and are not a retained-asset equivalent. The capital-allocation contrast is straightforward. A Caribbean family-of-four donation spends US$230,000–250,000 with certainty and recovers nothing; the outcome is known on day one. The reference structure's family contribution (US$95,000 for two to four applicants) is US$135,000–155,000 lower than any Caribbean family-of-four donation, but the structure then deploys a further €250,000 into the retained property plus its friction — a materially larger total outlay, of which the largest part is an asset rather than an expense. The honest comparison prices the offsetting risks rather than declaring a winner: - The donation's risk is certain and bounded: 100% of the contribution is gone, and nothing else is at market risk. The retained asset's risk is uncertain and unbounded in both directions: §12.11 shows outcomes from meaningful gain to a loss of about half the outlay, plus years-long illiquidity in the downside. - The rights obtained differ. The Caribbean programmes grant citizenship in exchange for a qualifying contribution, and those citizenships currently carry passports that are Schengen visa-exempt (Annex II);[^12-42] that exemption is now structurally conditional: the revised visa-suspension mechanism makes an investor-citizenship scheme operated without a genuine link a potential suspension ground,[^12-43] the Commission's Eighth Report records that the situation "continues to raise significant concern" and calls for adequate vetting "pending the discontinuation of those schemes",[^12-44] reported (unpublished) Commission letters of June 2026 are said to demand phase-out by June 2028,[^12-45] and Vanuatu's exemption has already been suspended and then removed on precisely this ground.[^12-46] The reference structure attributes Schengen mobility to the Greek residence permit, not to any passport; its mobility risk is Greek programme continuity, examined at §7.14 and §14.1. - Operating record differs in scale, and runs the other way. The Commission's Eighth Report estimates approximately 107,000 passports issued across the five Caribbean programmes, with 13,113 applications in 2023 and 10,573 in 2024;[^12-44] the São Tomé regulation under which the programme currently operates dates from 1 August 2025 (§6.12),[^12-1] and no comparable issuance record is published. The individual founding dates of the five Caribbean programmes were not verified for this report and are not stated here. - Cost certainty runs the other way too. The donation route's total cost is fixed and published; the reference structure's final cost depends on a property market outcome that will not be known for years. Neither profile is superior in the abstract. A client whose sole objective is a second citizenship at a known, sunk cost may be better served by a donation programme assessed on its own merits; a client who wants a European residence position and is genuinely prepared to own, let and eventually sell a Greek property (with the §12.11 range of outcomes) obtains, in exchange for that risk, the possibility that a substantial part of the capital comes back. Which profile fits which client is a suitability question, taken up in Chapter 13. ### Notes [^12-1]: 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, pp. 429–440, 1 August 2025 (Portuguese), Anexo I (contribution and fee schedule), Art. 14(4) (deposit after approval) — gazette facsimile via https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^12-2]: Law 5038/2023 (Government Gazette A′ 81/01.04.2023), Article 100, as amended by Law 5100/2024 (Government Gazette A′ 49/05.04.2024), Article 64 — §2(γ) (€250,000 change-of-use category; full ownership and possession), §7 (long-term letting), §7A (short-term-letting and company-seat prohibitions; €50,000 fine), §8 (resale confers a permit right on a qualifying buyer and revokes the seller's permit), §11 (prior-use certification); consolidated Greek texts via https://www.taxheaven.gr/law/5038/2023 and the consolidated PDF 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). [^12-3]: Greece, National Registry of Administrative Public Services (mitos.gov.gr), "Permanent golden visa (change of use) – Initial issuance" (fee table €2,000 + €16; record 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). [^12-4]: Law 1703/1987, Article 2, as amended by Law 2235/1994, Article 1(5) (three-year minimum duration of primary-residence leases) — rule as uniformly stated by professional sources; gazette text not read for this report and requiring confirmation at the date of application: Iason Skouzos TaxLaw, "The duration and termination of a lease contract", https://www.taxlaw.gr/en/practice-areas/real-estate/the-duration-and-termination-of-a-lease-contract/ (accessed 2 August 2026). [^12-5]: Bank of Greece apartment price index (national, nominal), as republished by the Bank for International Settlements, series QGRN628BIS — CSV downloaded via FRED and recomputed (peak Q3 2008 = 109.50; trough Q3 2017 = 63.08; −42.4%), https://fred.stlouisfed.org/graph/fredgraph.csv?id=QGRN628BIS (accessed 2 August 2026). [^12-6]: Bank of Greece, "New Index of Apartment Prices by Geographical Area" (Athens series, file version 25 November 2025) — the Bank's own open-data file, via Internet Archive capture of the official URL; recomputed (peak Q2 2008 = 101.43; trough Q1 2017 = 56.10; −44.7%), 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). [^12-7]: Eurostat, HICP annual average indices for Greece (ELSTAT-compiled): CP041 "actual rentals for housing" (rents −25.8% nominal 2011→2018; ≈−24% real below the 2011 peak in 2025) and CP00 "all items" (+8.1% 2008→2017; 2024 +3.0%, 2025 +2.9%) — API JSON downloaded and computed, https://ec.europa.eu/eurostat/api/dissemination/statistics/1.0/data/prc_hicp_aind?format=JSON&lang=EN&geo=EL&coicop=CP041&unit=INX_A_AVG (and coicop=CP00) (accessed 2 August 2026). [^12-8]: Global Property Guide, Greece rental yields (data as at May 2026: Greece average 4.38%; Athens 5.52%; district tables) — asking-price-based aggregator data, via archive.org capture of the page, https://www.globalpropertyguide.com/europe/greece/rental-yields (accessed 2 August 2026). [^12-9]: Spitogatos (SPI), Q1 2026 market report (asking rents and asking sale prices; Athens Centre ≈€11.9/m²/month), https://en.spitogatos.gr/blog/buy-rent-properties-greece-q1-2026 (accessed 2 August 2026). [^12-10]: J. Pereira dos Santos and K. Strohmaier, "All That Glitters? Golden Visas and Real Estate", IZA Discussion Paper No. 16857, March 2024 (Portugal; ≈€38,000 average transaction-price excess over fiscal values at the €500,000 threshold; bunching), https://docs.iza.org/dp16857.pdf (accessed 2 August 2026). [^12-11]: anakainisixoron.gr, «Κόστος ανακαίνισης σπιτιού 2025», 19 November 2025 (Greek; trade guide: standard full apartment renovation ≈€350–730/m², premium ≈€670–1,100+/m², new-build construction ≈€800–1,400/m²) — no published office-to-residential conversion cost series exists; the €500–1,200/m² band used here is this report's reasoned analysis from those anchors, https://anakainisixoron.gr/2025/11/19/kostos-anakainisis-spitiou-2025-o-pio-analytikos-odigos/ (accessed 2 August 2026). [^12-12]: Proto Thema (economy section), report of 26 December 2025 on the Athens conversion pipeline and investor-permit stock returning to market (1,000–2,000 units from spring 2026; 3,000–5,000 more by 2027; ≈94% never owner-occupied) — single major daily, corroborated reproduction; reported tier, https://www.protothema.gr/economy/article/1748790/etoima-gia-maziki-epistrofi-stin-agora-hiliades-akinita-pou-agorasan-kinezoi-israilinoi-kai-tourkoi-me-golden-visa/ (accessed 2 August 2026). [^12-13]: Your Overseas Home, "Greece buying costs" (FMA 3.09%; notary, registry, lawyer and agent bands; ≈8–10% all-in rule of thumb; seller-side bands) — market secondary, https://www.youroverseashome.com/greece/advice/greece-buying-costs/ (accessed 2 August 2026). [^12-14]: PwC, Worldwide Tax Summaries — Greece (last reviewed 16 February 2026): transfer-tax rate and base, ENFIA structure, insured-property discount, TAP replacement — professional source; reported tier pending gazette confirmation, https://taxsummaries.pwc.com/greece (accessed 2 August 2026). [^12-15]: propertycheck.gr (buyer-side inspection practice — time-billed, no published tariff) and proper.gr, Electronic Building Identity guide (indicative €120–250 per apartment) — the €300–1,500 technical-due-diligence band is this report's reasoned analysis in the absence of a tariff market, https://propertycheck.gr/ ; https://proper.gr/ilektroniki-taftotita-ktiriou-odigos/ (accessed 2 August 2026). [^12-16]: Cambridge Currencies, specialist-broker versus bank FX pricing (banks commonly 2–4% embedded margin; specialists often well under 1%) — reported market source, https://cambridgecurrencies.com/cambridge-currencies-specialist-broker-bank-rates/ (accessed 2 August 2026). [^12-17]: newmoney.gr and concordant Greek press on Article 210 of L.5222/2025 (residential rent payable into an AADE-declared landlord bank account from 1 April 2026; loss of the 5% deduction on non-compliance) — reported tier; the deferring instrument is not independently confirmed and the rule requires confirmation at the date of application, https://www.newmoney.gr/roh/palmos-oikonomias/oikonomia/pos-tha-plirononte-ta-enikia-apo-1i-ianouariou-2026/ (accessed 2 August 2026). [^12-18]: capital.gr, «Η επόμενη ημέρα της αγοράς ακινήτων», 27 October 2024 (Bank of Greece official: Athens stock averaging 40+ years old, >20% of Athens apartments vacant; brokers' federation: earlier investor-permit owners letting 10–15% below market) — reported tier, https://www.capital.gr/oikonomia/3881323/i-epomeni-imera-tis-agoras-akiniton/ (accessed 2 August 2026). [^12-19]: Spitogatos (SPI), Q1 2026 market report (asking-rent growth: national +4.2%, Attica +3.9% year-on-year), https://en.spitogatos.gr/blog/buy-rent-properties-greece-q1-2026 (accessed 2 August 2026). [^12-20]: PwC, Worldwide Tax Summaries — Greece (last reviewed 16 February 2026): individual rental-income scale; ENFIA structure and insured-property discount; TAP and its replacement by the Local Development Fee — professional source; reported tier pending gazette confirmation, https://taxsummaries.pwc.com/greece (accessed 2 August 2026). [^12-21]: Greece, Law 4172/2013, Article 40 §4 (rental-income scale: 0–€12,000 at 15%; €12,000.01–€24,000 at 25%; €24,000.01–€36,000 at 35%; above €36,000 at 45%), as amended by Law 5246/2025 (Government Gazette A′ 198/11.11.2025); consolidated text, https://www.taxheaven.gr/law/4172/2013/article/40/view (Greek); corroborated by Grant Thornton Greece, «Νέος Φορολογικός Νόμος 5246/2025», https://www.grant-thornton.gr/insights/article/neos-forologikos-nomos-5246-2025/ (all accessed 2 August 2026). [^12-22]: Greece, Law 4172/2013 (Income Tax Code), Article 39 §3(α) — 5% deemed-expense deduction for an individual lessor, so that the taxable base is 95% of gross rent («Αν ο εκμισθωτής ή ο παραχωρών είναι φυσικό πρόσωπο εκπίπτει ποσοστό πέντε τοις εκατό (5%)…»); consolidated text, https://www.taxheaven.gr/law/4172/2013/article/39/view (accessed 2 August 2026; Greek). [^12-23]: taxheaven.gr, news item 58595 (ENFIA structure and coefficients under L.4916/2022; basis of the €300–700 illustrative band), https://www.taxheaven.gr/news/58595/ (accessed 2 August 2026). [^12-24]: forin.gr, text of Article 24 of L.2130/1993 (TAP at 0.25–0.35‰, collected via the electricity bill), https://www.forin.gr/laws/law/3240/telos-akinitis-periousias-nomos-2130-1993-arthro-24 (accessed 2 August 2026). [^12-25]: estiagreekhome.online, "Choosing a Greek tax representative" (outsourced compliance tiers: ≈€250–500 basic; rental filings in higher tiers) — single market source, reported band only; AADE, "FAQs for Greeks abroad and Non-residents" (November 2025 edition), FAQ 28 (non-resident filing obligation keyed to Greek-source income), https://estiagreekhome.online/blog/choosing-greek-tax-representative ; https://www.aade.gr/sites/default/files/2025-11/FAQs_omogeneis_en_0.pdf (accessed 2 August 2026). [^12-26]: Athens Social Atlas, "Vacant dwellings in the Municipality of Athens" (ELSTAT 2021 census: 117,137 of 437,188 dwellings recorded vacant, 26.8% — includes second homes and derelict stock; not a rental-vacancy rate), https://www.athenssocialatlas.gr/en/article/vacant-dwellings-in-the-municipality-of-athens/ (accessed 2 August 2026). [^12-27]: EMF Hypostat 2025, Greece chapter (Bank of Greece authors): transaction counts 2021–2023 (104,746 / 112,283 / 122,123); net foreign inflows 2024 ≈€2.75bn; housing-loan stock declining, https://hypo.org/sites/default/files/2025-09/Greece.pdf (accessed 2 August 2026). [^12-28]: Bank of Greece Q1 2026 residential price release, via two independent mirrors (national +5.7%, Athens +5.2% year-on-year), https://news.gtp.gr/2026/06/11/greek-apartment-prices-rise-5-7-percent-in-q1-2026-as-growth-moderates/ ; https://moneybuzz.gr/greece-apartment-prices-q1-2026-5-7-percent/ ; 2025 foreign-inflow decline (≈€2.06bn, −25.3%) via realting.com summary of Bank of Greece data (reported tier), https://realting.com/news/greek-housing-market-2025-results (accessed 2 August 2026). [^12-29]: Circular 1/2026 of the Secretary General for Migration Policy (21 April 2026), content as reported by Sioufas & Associates and IMI Daily (circular text not itself opened; reported tier), https://www.sioufaslaw.gr/golden-visa-διευκρινίσεις-εφαρμογής-του-άρθρ-100/ ; https://www.imidaily.com/europe/greece-cracks-down-on-golden-visa-fraud-in-sprawling-new-circular/ (accessed 2 August 2026). [^12-30]: Law 4122/2013, Article 12 (Energy Performance Certificate required on sale and on letting to a new tenant; sub-50 m² exception via Article 12 §6 with Article 4 §7(ε)) — consolidated text read, https://www.taxheaven.gr/law/4122/2013/article/12/view (accessed 2 August 2026). [^12-31]: Law 4495/2017, Article 83 (owner's declaration and engineer's certificate of no unauthorised constructions/uses on every inter vivos transfer deed; two-month validity) — consolidated text read, https://www.taxheaven.gr/law/4495/2017/article/83/view (accessed 2 August 2026). [^12-32]: Article 54Α of L.4174/2013 (Tax Procedure Code as read; ENFIA certificate covering five years a precondition of the transfer deed; current-code renumbering after recodification to be confirmed) — consolidated text read, https://www.taxheaven.gr/law/4174/2013/article/54α/view (accessed 2 August 2026). [^12-33]: Article 24 of L.2130/1993, consolidated text (§18 TAP-certificate requirement shown repealed; §18A Cadastre notification inserted), with press reporting of abolition effective 1 January 2024 (repealing instrument number not pinned — reported-convergent), https://www.taxheaven.gr/law/2130/1993/article/24/view ; https://www.ot.gr/2023/11/01/forologia/akinita-katargeitai-to-pistopoiitiko-tap-gia-metavivaseis/ (accessed 2 August 2026). [^12-34]: Article 90 of L.5162/2024 (Government Gazette A′ 198/05.12.2024), amending Article 72 §33(α) of L.4172/2013: «Η ισχύς του άρθρου 41 αναστέλλεται μέχρι και την 31η Δεκεμβρίου 2026» — consolidated text read; corroborated by the government housing portal stegasi.gov.gr, https://www.taxheaven.gr/law/5162/2024/article/90/view ; https://stegasi.gov.gr/programs/anastoli-epivolis-forou-yperaxias-apo-metavivasi-akiniton/ (accessed 2 August 2026). [^12-35]: capital.gr, 8 July 2026 (extension of both real-estate suspensions into 2027, and permanent abolition, reported under consideration; decisions expected around the September 2026 Thessaloniki Fair) — reported tier; nothing enacted as at 2 August 2026, https://www.capital.gr/tax/4003408/akinita-pros-paratasi-kai-to-2027-i-anastoli-tou-fpa-sta-neodmita-kai-to-pagoma-tou-forou-uperaxias/ (accessed 2 August 2026). [^12-36]: Article 41 of L.4172/2013 (base = deed transfer price minus deed acquisition price; holding-period coefficients; €25,000 deduction at ≥5 years) — consolidated text read; mechanics corroborated by Andersen in Greece (older page, mechanics only); the coefficient table rests on a single consolidated reproduction and requires gazette confirmation before reliance, https://www.taxheaven.gr/law/4172/2013/article/41/view ; https://gr.andersen.com/news/φόρος-υπεραξίας-ακινήτων/ (accessed 2 August 2026). [^12-37]: St Kitts and Nevis Citizenship by Investment Unit (official): Sustainable Island State Contribution page and CBI options (SISC US$250,000 single or family up to four; real-estate routes US$325,000 approved development or private condominium / US$600,000 private single-family dwelling, seven-year hold), with SRO No. 43 of 2024 (gazetted 25 October 2024), https://ciu.gov.kn/sustainable-island-state-contribution/ ; https://ciu.gov.kn/cbi-options/ ; https://ciu.gov.kn/wp-content/uploads/2025/01/SRO-43-of-2024.pdf (accessed 2 August 2026). [^12-38]: Dominica Citizenship by Investment Unit (official): Economic Diversification Fund page (US$200,000 single; US$250,000 main applicant plus up to three dependants; real-estate route from US$200,000 in approved projects, three-year hold, five if resold to another programme purchaser), https://www.cbiu.gov.dm/investment-options/economic-diversification-fund/ (accessed 2 August 2026). [^12-39]: Grenada Investment Migration Agency (official): "Becoming a Citizen" (National Transformation Fund US$235,000, single or family up to four; real-estate routes US$270,000 share / US$350,000 unit), https://imagrenada.gd/becoming-a-citizen/ (accessed 2 August 2026). [^12-40]: Antigua and Barbuda Citizenship by Investment Unit (official): National Development Fund and Schedule of Fees (NDF US$230,000 plus processing US$10,000 single / US$20,000 family up to four; real-estate route US$300,000), https://cip.gov.ag/investment-options/ndf/ ; https://cip.gov.ag/schedule-of-fees/ (accessed 2 August 2026). [^12-41]: Saint Lucia Citizenship by Investment Unit (official): Investment Options (National Economic Fund US$240,000, applicant alone or with up to three qualifying dependants; real-estate route US$300,000 plus administration fees), https://www.cipsaintlucia.com/citizenship-by-investment (accessed 2 August 2026). [^12-42]: Regulation (EU) 2018/1806, consolidated version of 30 December 2025, Annex II (Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, Saint Lucia visa-exempt; São Tomé and Príncipe in Annex I), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^12-43]: Regulation (EU) 2025/2441 of 26 November 2025 (OJ, 10.12.2025), inserting Article 8a(1)(e) into Regulation (EU) 2018/1806 (operation of an investor-citizenship scheme granting citizenship for pre-determined payments or investments without a genuine link as a ground for suspending a visa exemption), https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R2441 (accessed 2 August 2026). [^12-44]: European Commission, COM(2025) 792 final, Eighth Report under the Visa Suspension Mechanism, 19 December 2025 (Eastern Caribbean section: ≈107,000 passports estimated issued across the five states; 13,113 applications in 2023 and 10,573 in 2024; Annex I recommendation: "potential ground" for suspension; "pending the discontinuation of those schemes"; the report contains no phase-out deadline), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0792 (accessed 2 August 2026). [^12-45]: IMI Daily, 7 July 2026, reporting unpublished letters of 25 June 2026 from Commissioner Brunner to the five Eastern Caribbean governments (phase-out by 1 June 2028; interim demands), receipt confirmed by Antigua and Barbuda's Office of the Prime Minister — reported correspondence only, not an official published position, https://www.imidaily.com/caribbean/end-cbi-by-june-2028-or-risk-schengen-access-eu-writes-to-caribbean-states-antigua-says/ (accessed 2 August 2026). [^12-46]: Council Decision (EU) 2022/2198 (full suspension of the EU–Vanuatu visa waiver from 4 February 2023) and Regulation (EU) 2025/11 of 19 December 2024 (transfer of Vanuatu to Annex I), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022D2198 ; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0011 (accessed 2 August 2026). [^12-47]: 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). [^12-48]: Greece, Law 4172/2013 (Income Tax Code), Article 39 (income from immovable property; the 3% imputation attaching to the specified self-use and free-concession cases, with the free grant of a dwelling to an ascendant or descendant as a main residence expressly excepted) and Articles 30–34 (objective expenditure and presumed living costs, with the non-resident carve-out of Article 33 examined at §9.10); consolidated texts, https://www.taxheaven.gr/law/4172/2013/article/39/view and the adjacent article views (accessed 2 August 2026; Greek). Personal owner-occupation is not an occasion of deemed property income at 3% of value; the presumptive-expenditure rules are a separate head and are the ones capable of engaging on occupation.