# Foreword ## Purpose of this report For ordinary private clients, the European Union's retail investor-citizenship market has ended. Cyprus terminated its investment programme for new applications from 1 November 2020, and Bulgaria abolished its scheme with effect from April 2022.[^F-1] On 29 April 2025 the Court of Justice of the European Union held, in Commission v Malta (C-181/23), that Malta—recorded by the European Commission in September 2022 as the only member state then operating such a scheme—had failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU.[^F-2] The Court did not outlaw discretionary naturalisation: powers to naturalise for exceptional merit or a defined public interest may persist in national law, exercised case by case and not as a priced product (see §2.7).[^F-2] Chapter 2 sets out that history. The objectives that created the market did not end with it: an additional nationality, resilience against disruption at home, a lawful European residence held in reserve, property and capital outside the home jurisdiction, and wider banking, succession and planning options remain among the reasons international families take advice. This report examines one lawful response: a structured position combining citizenship of São Tomé and Príncipe under Decree-Law No. 07/2025[^F-3] with a five-year Greek investor residence permit supported by qualifying property under the restricted €250,000 change-of-use category of Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024,[^F-4] the qualifying property itself as a retained asset, and an optional company, banking and tax-residence layer. The components are complementary parts of one coordinated position, each established separately and assessed on its own legal terms; Chapter 5 defines this reference structure precisely. The report is written to a research standard. It establishes what the structure actually provides, what it costs, which risks are being assumed and for whom it may—or may not—be suitable. The structure is not a substitute for European Union citizenship, and this report does not present it as one. Each right is attributed to the exact instrument that provides it—short-stay Schengen mobility, for example, arises from the Greek residence permit and never from the São Tomé passport[^F-5]—and each limitation is stated with the same care as each capability. ## Scope and intended audience The executive summary (Chapter 1) states the position in short form; this Foreword describes how the report was made. From that history the report turns to the objectives clients actually pursue (Chapter 3), the legal concepts the market habitually confuses (Chapter 4), the reference structure and its components (Chapters 5 to 9), cost and capital at risk (Chapters 10 to 12), suitability, including when a client should not proceed (§13.14), the risks and failure points, including those no adviser controls (Chapter 14), source-of-funds standards, documentation, implementation and professional roles (Chapters 15 to 18), and the consolidated conclusions (Chapters 19 and 20). The report is not a survey of the wider market; other programmes appear only where comparison is instructive (Appendix B). It is written for private clients—typically nationals of non-EU states weighing an additional citizenship alongside a European residence held in reserve—and for the professional advisers who act for them: private-client lawyers, tax advisers, wealth managers. It is written to be read critically: each material statement is attributed to the source relied on, and the report says where a source could not be verified. ## Verification and publication standard Sourcing follows a fixed hierarchy: primary legislation, official gazettes and court judgments first; official government portals and administrative records second; EU institutions, the Financial Action Task Force, the OECD, central banks and national statistical offices third; reputable professional publications for context only, never as sole authority for a legal or fiscal claim. Marketing materials and industry rankings are not sources. Each citation names the instrument and provision relied on and the date the source was read—unless stated otherwise, 2 August 2026. Before drafting, an independent verification pass attempted to refute each material claim in the research base against its cited source; claims were corrected, downgraded or removed where they did not survive. Each drafted chapter is in turn subjected to structured adversarial review before publication, and Appendix N §N.8 records, for the Foreword and for each chapter, the number of findings raised, the number applied and the number rejected with reasons. Throughout, one rule applies: citation or silence. Every legal, regulatory, fiscal or factual claim is either cited to a primary or official source or expressly framed as requiring confirmation at the date of application. Where a claim could not be verified, we say so. One limitation is material: every Greek primary tax source consulted during the research phase was unreachable, so the Greek tax material is reported at the level of convergent professional publications and is not confirmed against the Government Gazette; every figure in that material is date-stamped and requires confirmation at the date of application. Stated uncertainty of that kind is part of the standard, not a departure from it. Appendix M lists every primary instrument cited, together with the archived copies relied on; Appendix N describes the methodology, including what was and was not independently verified. ## Important legal, tax and investment limitations This report is general information. It is not legal, tax, immigration, financial or investment advice to any person, and it is not an offer, quotation or personal recommendation. Reading it, or corresponding about it, does not create a client relationship with Kestrel Private. Kestrel Private is a trading name of 8T20 Capital (Pty) Ltd, a South African company (registration number 2019/482395/07), and engagements are contracted under South African law.[^F-6] It is an advisory and coordination firm, not a law firm, and it is not an authorised financial services provider under South Africa's Financial Advisory and Intermediary Services Act, 2002; regulated advice in each jurisdiction is a matter for the admitted lawyers, tax advisers and other professionals engaged for the purpose. Decisions on citizenship, residence and banking rest with governments and financial institutions alone. This report does not guarantee, and Kestrel Private cannot guarantee, approval of any application, processing times, the opening of any bank account, any tax outcome, rental income, the preservation or recoverability of capital, resale liquidity, or the continuation of any programme, law or fee schedule. Rights described in this report exist subject to the conditions of the instruments that create them, and those instruments can change. Figures are illustrative and carry their assumptions—currency, exchange rate, date, family composition, fee schedule—where they appear; every figure requires confirmation at the date of application. The qualifying property is an investment asset as well as an immigration condition: its value may fall as well as rise, and ownership does not mean that the capital is preserved or readily recoverable. A client is free to acquire a qualifying property from any source, on the same engagement terms. Statements of law, figures and programme status are made as at 2 August 2026 unless a different date is shown; laws, fees and administrative practice change, sometimes without notice. Before acting on anything in this report, readers should obtain independent professional advice in each relevant jurisdiction. Appendix O sets out these limitations in full. Kestrel Private August 2026 ### Notes [^F-1]: Cyprus: European Commission, press release IP/22/5422 (referral of Malta to the Court of Justice; chronology recording the Cypriot programme's termination for new applications from 1 November 2020 and Bulgaria's abolition effective 5 April 2022), 29 September 2022, https://ec.europa.eu/commission/presscorner/api/files/document/print/en/ip_22_5422/IP_22_5422_EN.pdf (accessed 2 August 2026). Bulgaria (primary instrument): *Bulgarian Citizenship Act* (Закон за българското гражданство), Articles 12a and 14a, repealed (Отм. – ДВ, бр. 26 от 2022 г.) with effect from 5 April 2022, and transitional §7 (pending proceedings terminated) (in Bulgarian); Ministry of Justice consolidated text, https://justice.government.bg/home/normdoc/2134446592 (accessed 2 August 2026). [^F-2]: Court of Justice of the European Union (Grand Chamber), judgment of 29 April 2025, *Commission v Malta*, Case C-181/23, EU:C:2025:283, operative part and paras 96–102, declaring that Malta failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU; the Court did not outlaw discretionary or merit-based naturalisation and adopted no free-standing "genuine link" test, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181 (accessed 2 August 2026). That Malta was the only remaining member state operating such a scheme is recorded in European Commission, press release IP/22/5422, 29 September 2022 (note F-1); no later official statement to that effect was located as at 2 August 2026, and the position at the date of judgment is stated on that basis. [^F-3]: 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, published and in force 1 August 2025 (in Portuguese). No official online copy of the gazette was locatable as at 2 August 2026. The text relied on is a facsimile of those gazette pages, read in full in Portuguese by two readers independently and archived; the archived copy is listed in Appendix M. The facsimile was retrieved from a file hosted by a citizenship-by-investment agency (https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf, accessed 2 August 2026); the host is identified for provenance only and is not relied on as a source. [^F-4]: Greece, *Law 5038/2023* (Immigration Code, Government Gazette A′ 81/01.04.2023), Article 100, as amended by *Law 5100/2024* (Government Gazette A′ 49/05.04.2024), Article 64 (in Greek); consolidated texts via https://www.taxheaven.gr/law/5038/2023 and the official consolidated PDF at 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). [^F-5]: *Convention Implementing the Schengen Agreement*, Article 21, as replaced by *Regulation (EU) No 265/2010*, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265 (accessed 2 August 2026); *Regulation (EU) 2018/1806*, Annex I (São Tomé and Príncipe among the states whose nationals require a visa), consolidated version of 30 December 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^F-6]: Kestrel Private, published regulatory-scope and legal pages (entity, governing law, and the statement that the firm does not provide regulated legal, tax, immigration or financial advice), https://kestrelprivate.com/legal/regulatory-scope (accessed 2 August 2026).