Citizenship for sale: how unique is Malta?

BELGIUM

While Malta's IIP creates a two-tier system granting people paying €650,000 automatic citizenship and retains the present restrictive system for all other foreigners seeking naturalisation, Belgium does not discriminate between different categories of foreign residents.

To become a naturalised citizen in Belgium you must be at least 18 years of age and have lived in Belgium for at least three years. However, this period can be reduced for political refugees and stateless persons. Additionally, it is possible to take into account your residence abroad if you can prove genuine ties with Belgium for the three-year period.

The applications are reviewed by the Committee on Naturalisation in parliament, which has to submit a report to the plenary. The names of all naturalised persons are then published in the Belgian Official Gazette.

But to become a citizen one has to pass the language requirement of either French, German or Dutch when applying for citizenship.

The only similarity with the scheme proposed by the Maltese government is that non-EU persons can apply for a residence permit under the 'investor' or 'business' category. The requirements include forming a new Belgian company with an office and provide employment.

As an owner of the company, you can easily qualify for the Belgian residence permit. It usually takes three to eight months to get the residence permit issued to investors who form their company. Initially you will have a temporary permit with a one-year validity and thereafter you will need to renew the residence permit annually for three years, after which you will qualify for a 'permanent residence permit'.

These people can subsequently apply for citizenship but have to follow the result which apply to other immigrants, including refugees.

CANADA

Canada stopped its investor programme after a number of abuses were uncovered in 2012. The scheme was "paused" to enable the government to make important changes to its economic immigration programs before accepting more applications.

Canada's Immigrant Investor Program was set up with the aim of attracting experienced business people contribute to Canada's growth and long-term prosperity.

To be eligible for permanent residency investors had to show that they have business experience, have a net worth of at least C$1.6 million (€1.1 million) that was gained legally and be ready to invest C$800,000 (€568,000).

Subsequently, Citizenship and Immigration Canada used to divide the investment between participating provinces and territories. This was used for projects to develop their economies and create jobs for five years.

If the application was approved, a permanent resident visa was issued within 30 days.

Permanent residents must reside in Canada for three years out of four years prior to applying for Canadian citizenship.

To retain their status as permanent residents, they must be physically present in Canada for two out of five years with few exceptions.

In 2012 Citizenship and Immigration Canada (CIC) began the process to revoke the citizenship of up to 3,100 citizens who obtained it fraudulently. The investigation revealed that permanent residents were using the services of unscrupulous immigration representatives to fraudulently establish evidence of residence in Canada while living abroad most, if not all, of the time. "Canadian citizenship is not for sale. We are taking action to strip citizenship and permanent residence status from people who don't play by the rules and who lie or cheat to become a Canadian citizen," Minister Jason Kenny said in September 2012.

PORTUGAL

Through the Golden Residence Permit for Investment, foreign investors are awarded residency status can become full citizens after five years.

Although the Golden Residence Permit does not grant citizenship, it gives its beneficiaries access to the Schengen Area. The programme is available to all foreign national investors who are not citizens of the European Union.

To qualify, the investor will need to make an investment in Portugal, either privately or through a company conducting at least one of the following investment operations in Portugal. These are required to make a capital investment with a minimum value of €1 million in a Portuguese company or establish a Portuguese company that employs more than 10 people; or acquire real estate with a minimum value of €500,000.

The holders of the Golden Residence Permit have all benefits of the Schengen Visa, entitling the holder freedom of movement in the 26 member states. After the fifth year, the permit holder may apply for Portuguese citizenship and a passport, which will bestow upon the holder all the rights of an EU national including free movement of peoples in all the EU member states, including the United Kingdom and Ireland.

SINGAPORE

Potential applicants for residence status must have a three-year track record of business and entrepreneurial experience. They must also prove annual revenues of more than $160 million (€118 million) in real estate and construction-related industries or revenues of about $40 million (€30 million) for all other industries.

With such foundations, candidates can then apply to Singapore's sole track to permanent residency, the Global Investor Program. This scheme requires an investment of nearly $2 million (€1.5 million). The funds can go towards starting a new business or expand one already in operation. Money can also be routed to an approved list of funds that help grow targeted industries ranging from nanotechnology, healthcare and clean energy.

Coupled with low tax rates, applicants who successfully gain permanent resident status can then access education subsidies for their children, child-care subsidies and tax deferrals. Cons for permanent residency include mandatory military service for second-generation males who are also permanent residents.

ST KITTS & NEVIS

Strangely omitted from Scicluna's list is the Caribbean nation of St Kitts & Nevis which offers the most similar scheme to the Maltese one.

The Citizenship Program of St  Christopher (St Kitts) and Nevis was established in 1984 and requires applicants to make an economic contribution to the country. In exchange, they and their families are granted full citizenship.

To qualify for citizenship, the applicant must make either an investment of at least US$400,000 (€297,000) in one of the approved real-estate developments in addition to paying government fees, other fees and taxes, or alternatively making a contribution to the Sugar Industry Diversification Foundation (SIDF, a public charity) starting from US$250,000 (€185,000) for a single applicant). However, this includes all government fees.

AUSTRIA

Surprisingly, Scicluna also refrained from mentioning Austria, the only EU country which offers high net worth investors the opportunity to obtain citizenship and an EU passport immediately without prior residence requirements on the basis of an investment in the country.

But unlike what is being proposed in Malta, Austria offers citizenship only to those who offer a substantial investment.

Under the citizenship-by-investment program, "economic citizenship" can be offered to foreign nationals who invest a minimum of €3 million donation to a public project or private project of public interest, recognized as providing extraordinary benefits. Citizenship can also be offered to anyone who makes a recoverable minimum investment of €10 million in economy of Austria.