Residence and citizenship by investment: what they do and do not do for tax

Residence by investment programmes grant a residence permit in return for an investment, typically in property, funds, government bonds or a business. Citizenship by investment programmes grant a passport. Both are marketed alongside tax benefits, and the connection is often overstated. Immigration status and tax residence are decided under different rules, and for most people the tax outcome depends on where they spend their time and keep their home.

A passport is not a tax residence

Most countries tax by residence. Acquiring a new nationality does not by itself make you resident in that country or end your residence anywhere else. If you continue to live in Germany, France or the UK, those countries continue to tax you as before, whatever passports you hold. The main exception runs the other way: the United States taxes its citizens on worldwide income wherever they live, so a US citizen who acquires another passport remains within US tax.

A residence permit works the same way. Some golden visa programmes require only a few days of presence a year to keep the permit. That is convenient for immigration purposes and means, for tax purposes, that the holder usually remains resident in the country where they actually live.

Programmes are changing

European investor programmes have narrowed considerably. Portugal removed real estate as a qualifying investment for its golden visa in 2023, leaving routes such as investment funds and job creation. Spain closed its golden visa programme in 2025, and Ireland closed its investor programme earlier. Greece has raised its property thresholds in the most sought-after areas. In 2025 the Court of Justice of the European Union ruled that Malta's citizenship by investment programme breached EU law. Outside Europe, several Caribbean states run citizenship programmes, and minimum investments and due diligence requirements have been rising. Any programme should be checked at the time of application.

Reporting follows residence

Under the Common Reporting Standard, banks and other financial institutions in participating countries report account information to the tax authorities of every country where the account holder is tax resident. They ask for a self-certification of tax residence and are expected to test it against what they know: address, phone number, instructions and documents. The OECD has specifically identified residence and citizenship by investment schemes that could be used to misstate residence, and institutions are told to make further enquiries where a client relies on one of them. Claiming residence in a country you rarely visit is likely to be questioned, and the account will often be reported to the country where you really live as well.

Where these programmes do help

A permit can be a sensible first step for someone who intends to move and wants the right to do so in place. A second passport can make travel easier or provide security. Neither changes tax on its own. The investment itself, whether property or fund units, has its own tax treatment in the host country, including transfer taxes, annual property taxes and tax on any income or gain.

Before you sign

• Decide whether you intend to live in the new country, and plan tax residence around that answer.
• Check the current rules of the programme, including minimum stay requirements and permitted investments.
• Understand how the investment itself will be taxed while held and on sale.
• Make sure your self-certifications to banks match your actual tax residence.
• If you are a US citizen, factor in US tax whatever else you acquire.

If you are considering a residence or citizenship programme, call us before you commit funds. The first 30-minute consultation is free, your dedicated consultant is available 24/7, and every request is answered within 24 hours.

General information, not advice. Tax rules change and depend on your facts. Greyridge Global coordinates and delivers cross-border tax and corporate work through appropriately licensed professionals in each jurisdiction. Legal, tax, immigration, fiduciary, and regulated services are provided by qualified advisors engaged for your matter. Nothing on this page is tax or legal advice.