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February 26, 2025 21 mins

Want a different passport? Wish you lived somewhere with a better tax policy or even better weather? With enough money, it is possible. It’s called citizenship by investment, a process of gaining permanent residency by purchasing property or investing in the economy. On this week’s episode of Merryn Talks Money, host Merryn Somerset Webb speaks with Dominic Volek, group head of private clients at Henley & Partners, about why expats are deciding to move—and which countries have the best offers. 

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Speaker 1 (00:02):
Bloomberg Audio Studios, podcasts, radio news.

Speaker 2 (00:17):
Welcome to Meron Talks Your Money, the personal finance edition
of Merin Talks Money and these bonus podcasts we talk
about the best strategies for making the most of your money.
I'm Meren sumst Web Bloomberg UK Wealth Editor at Large,
and this week we are discussing citizenship by investment. Well
more than that, we're discussing how you get out of
the UK, out of the US, out of which have

(00:38):
a country you're living in where you don't want to
pay the taxes, you don't want to put up with
the weather, whatever it is. How you get out of
those countries into a country in which you would prefer
to live. Now, some countries allow experts to obtain permanent
residency if they buy a property or if they invest
in the economy in some way. How is that a
good idea? What countries have the best programs? Now? Every
year Henley and Partners release a comprehensive benchmarking of the

(01:00):
world's most important residence programs. And with me to have
a look at that list and other things, is Dominic Follock,
Group Head of Private Clients at Henley and Partners. Welcome, dominic.

Speaker 3 (01:10):
Thank you very much.

Speaker 2 (01:11):
Right, let's start I think I might have given some
hints of this in my own production, but let's start
by talking about why it would be that someone would
like to leave the country in which they hold citizenship originally.
What are the drivers here?

Speaker 3 (01:27):
It's a very good question. I would say the majority
of the families that we work with are not necessarily
looking to relocate, and so usually when we sit down
to have a discussion around what's known as investment migration, right,
so we're talking about the industry where you can acquire
either residents by investment this is Golden Visa's Green cord

(01:50):
in the US, or permanent residents in other countries, or
we're talking citizenship by investment, which is of course giving
you the right to a passport of that kind of
as well. And it there's a lot of reasons why
people want to explore these things. In the UK, you know,
probably a bit more relevant last year, as I always said,
it's not about relocation in tax and the UK last

(02:11):
year it was all about relocation in tax. So those
are the two biggest drivers, at least for our clients
in the UK last year.

Speaker 2 (02:18):
So if I hang on saying it's not about relocation,
What is it about If you don't want to relocate
to another country, why do you want a residence right
to another country? Why do you want a passport for
another country if you don't want to live there?

Speaker 3 (02:30):
Very good question. So the overriding reason is optionality. So,
if you're wealthy, you fully understand the idea of diversification. Right. So, no,
you know, individual that is high net worth or above
has all their eggs in one basket. You're invested in
real estate, bonds, equity, all sorts of alternatives like crypto

(02:50):
and wine and whiskey funds, and so therefore, it makes
no sense that if you're diversified in terms of your assets,
that you're limiting yourself to one single jurisdiction, one single government,
and whatever challenges might be in that jurisdiction. So this
idea of diversifying your domiciles, having the ability to spend

(03:10):
three to four months in three to four different countries,
depending on the weather, depending on potentially tax or depending
on whatever geopolitical challenges might be at play. That's the
ultimate flexibility for the type of clients that we work with.

Speaker 2 (03:26):
Okay, so you bo't have plants who have residency and
more than two countries.

Speaker 3 (03:30):
Correct, correct, So the idea of a portfolio is the
large trend that we see. So our biggest market last
year and probably been growing significantly over the last two
years is Americans. And these are not Americans leaving the
US or renouncing their American citizenship. It's more a case
of them realizing that it makes sense to have Plan

(03:51):
B and probably Plan C and Plan D because who
knows what's going to happen, what the next government's going
to do. Of course, we saw an interesting election results
at the end of last year in the US, and
that resulted in a lot of people realizing that you
should have an alternative option. It's like an insurance policy.
And as JFK said, you don't fix the roof while
it's raining, right, you fix the roof while it's shining,

(04:13):
And so why risk not having these things in place
when you need it?

Speaker 2 (04:17):
Okay, interesting if you're an American and you do not
renounce your US citizenship with citizenship, which most very well
off people wouldn't want to do anyway, because there are
big exit penalties, right, correct, So you have to have
to pay your tax forward on departure, so you hang
onto your passport. But that means that in the main
Americans are not getting other residencies and other citizenships for

(04:38):
tax reasons because they would continue to be liable for
US tax correct correct.

Speaker 3 (04:42):
So for them what happened in the US, it was
actually COVID that sort of kickstarted things because in the
initial lockdowns, Europe said, if you're an American citizen, you
cannot enter Europe. And so if I'm worth a hundred
million dollars with a private jets and homes in Europe,
I don't like the fact that I can't travel right.
So but if I had a citizenship from Saint Kitts

(05:03):
and Nevus, or I had a Portugal Golden visa, or
I had citizenship from Malta, I could get on my
private jet and fly to Europe. So it was the
initial lockdowns in COVID that I think a lot of
wealthy American families realize they were a bit more exposed
than potentially they thought. And that's where it started. And now,
of course it's becoming more and more mainstream there. So

(05:23):
the typical American client, we have a lot of them,
will get citizenship in the Caribbean. Europe is very much
part of the portfolio. So if they if they have
the financial capacity, then Austria and Malta for EU citizenship,
which gives them settlement rights across the whole of Europe,
something that Brits lost after Brexit. All the golden visas

(05:45):
in Spain, Greece, Portugal, Italy very attractive. We have a
lot that then throw in something like a golden visa
in Dubai and the ultimate billionaire Boltole. Part of that
portfolio is to get permanent residents down in New Zealand,
which is is far away from all the chaos in
the world, and so that's what we see some families

(06:05):
putting into place.

Speaker 2 (06:08):
Will you just go back a tiny bit and define
golden visa for us?

Speaker 3 (06:12):
So golden visa is usually residents by investment. So you know,
there's lots of different terms thrown around, but the overall
industry considers it consists of two areas, citizenship by investment.
There's only about twelve or thirteen countries where you can invest,
pass the necessary due diligence checks and directly become a

(06:32):
citizen and have the right to get a pass for
then you have thirty or forty sort of legal, transparent,
attractive successful residents by investment programs. And part of that
you have golden visas, where the premise is again you
invest and in return you get the right to reside
in that country. But the beauty of a golden visas

(06:53):
the physical presence requirements are usually little to none. So
you can get a golden visa in Greece or it's
and there's no physical presence required in order to maintain
your residence there. In Portugal, you need to effectively spend
just a week a year to keep your golden visa.
If you have a Dubai golden visa, you get it
for ten years. There's no physical presence required at all.

(07:15):
So that's why it's a golden visa. It's an investment
linked residence permit, but with little to no physical presence required.

Speaker 2 (07:23):
Okay, So basically all you're doing is you're paying up
front for the right to go to that country if
you feel like it or something goes wrong in your.

Speaker 3 (07:30):
Own country exactly, and of course it's often every family
is unique, right, so it might be to get the
kids there to study, right, So education, educating your kids
in some of these countries, it's often much better idea
to do it under a Golden visa or an investor
visa rather than a student visa, because the US is
a classic example. So the US of course has a
high demand for it for the education, the schools and

(07:52):
the universities in the US, and so a lot of
the families we work with, particularly in Asia, they send
their kids there on a student visa that qualify and
then what right they either have to try and get
an H one B visa or some type of a
work permit, which is not so easy anymore. But if
they had sent them on what the US has the
EB five investor visa, So if you invest eight hundred

(08:14):
thousand dollars, you get a conditional green card your child
can go and study, and then they qualify with not
only a degree, but also a green card, permanent residence
or maybe even citizenship if they've spent enough time.

Speaker 2 (08:26):
Wow, it's amazing what money can buy you. Right, let's
look at the best places for this. So I want
to move on to younger people in a minute. But
let's say you brarely can afford to pay to buy
this kind of residency, this safety, etc. What comes top
of the list.

Speaker 3 (08:43):
So from a purely residence perspective, the way that we
do the ranking is for all the countries that have
some form of investment migration in place, we analyze them
based on a number of factors. Reputation of the country,
the quality of the life, processing time of is very
interesting to those who apply the compliance requirements investment requirements,

(09:04):
whether it's attractive or not from a tax perspective, So
that's how we do the ranking. Based on the current ranking,
we have Greece at number one, So Greece has a
very attractive Golden Visa program. You know, it takes a
lot of boxes in terms of quality of life. The
investment starts at just two hundred and fifty thousand euros.
Greece is also interesting from a tax perspective. They have

(09:27):
a lump sum tax regime similar to what Switzerland and
Italy has. So this year Greece sits at number one.

Speaker 2 (09:34):
When you say lump some taxation policy, what do you mean.

Speaker 3 (09:37):
So Greece has a policy like Italy does where you
effectively agree to pay a single lump sum of tax
every year. So in Greece it's one hundred thousand euros
in Italy it's two hundred thousand euros and if you
pay that lump sum, you can be a tax resident
and they won't tax you on your worldwide income.

Speaker 2 (09:56):
So if you're a rich person living in the UK,
you can go to Greece, get one of these residencies,
become tax resident Angry and only pay one hundred thousand
euros at tax every year.

Speaker 3 (10:07):
Correct, So it is it is interesting for those that
are paying, you know, in the higher tax brackets for
how long a lot of them It depends on the country.
So some of them, you know, provide these types of
benefits only for you know, ten to fifteen years, Like
the non domin in the UK was fifteen years, and
if you look at the foreign incomes and game regime
that the UK is introduced now you know, four years,

(10:29):
it's not particularly attractive to wealthy individuals that are looking
to really you know, set down their roots and make
a life in a country. Other countries, you know, offer
much longer term such tax benefits, Portugal being incredibly popular
over the years they've had their non habitual residence that
was only available for the first ten years. But people

(10:50):
are more and more mobile, right, So if I'm going
to sit and be tax efficients in Portugal for ten years,
then I can move on to Dubai maybe or maybe
Italy in the future. But taxes, of course an important one.

Speaker 2 (11:00):
Yeah, if you know you've got a high earning period
ahead of you, if you know you've got four or
five years or even ten years when you're going to
be in a very high earning stage of life and
then that's going to end, it makes sense to move
to someone that's not going to overly tax you on that, right,
So that's one reason to do it.

Speaker 3 (11:13):
Especially if you have some sort of liquidity or cash
out of the business. Then of course the planning around
this becomes incredibly important.

Speaker 2 (11:21):
So Greece was number one. What comes after Greece.

Speaker 3 (11:23):
Greece is followed by Switzerland and Italy. I guess we've
already touched on both of those. Also very interesting from
a tax perspective, Portugal, which was at the top of
the list for a long time and is sitting joined
third place next to Italy, as well as the UK.
The UK. You know, the UK had an incredibly interesting
investi visa, the Tier one investor visa, which was sort

(11:47):
of two five or ten million pounds but of course
that was terminated a couple of years ago. I think
the UK is probably missing an opportunity now by not
having something to compete in an industry which becomes more
and more competitive. And then in fourth place, we've got
a tie with Australia. Australia also has curtailed their investor

(12:09):
visas to a certain extent, but if you're a high
performing global talent industry accoladed great CV, you can actually
get permanent residents in Australia based purely on your experience
and your credentials. And Canada also tied forth with Australia.
In Spain, Canada has a very interesting startup visa, So

(12:30):
if you have an innovative idea or you have the
right profile, you can set up a startup, work with
some of the incubators in Canada and that gives you
a path to permanent residents. Spain has had a very
successful Golden visa, although that's actually going to close now
in April, so the Spain Golden Visa will also cease
its operations in April. And then in fifth place you've

(12:53):
got the UAE, which of course has an incredibly successful
Golden visa regime not only for investors. If you're willing
to invest two million durhams so about five hundred and
fifty thousand US into real estate, you can also do
a fixed deposit with a bank. Or again if you're talented,
if you're a senior executive and you earn over thirty
thousand durhams a month, you can also get a ten

(13:15):
year Golden visa. So the UAE really is very much
courting not only investors, but skills and talents globally. And
that's why it's also seen, you know, the highest inflow
of millionaires. It's been at the top of the list
the last three years in terms of net inflow of
high networth individuals.

Speaker 2 (13:31):
Who are the people who are looking for these programs
the most You've mentioned Americans. Clearly the British are very
much on the move at the moment that the very
rich are on the move to try and avoid taxation,
and the young are on the move because they're finding
it difficult to get high paying jobs because housing is
so expensive, etc. On this right number the other day
saying are surveying that thirty percent of eighteen to twenty

(13:52):
four year olds in the UK would like to leave
the UK.

Speaker 3 (13:55):
Yeah, so if you look at it based on a
nationality wise, I can tell you you know, we've got
sixty officers around the world, so we've got a pretty
good finger on the pulse of who's doing what. Last year,
our top five was number one Americans. As I mentioned,
they were about twenty three percent of all our business
last year, so a really high percentage of Americans, not

(14:17):
necessarily as I said, on the move, but certainly looking
at getting alternative second citizenship and residents. That was followed
by you know, probably some of the more expected markets India, Philippines,
Turkya and number five was the UK for US last year,
both non doms you know, looking to move on to
the next step, but also a lot of Brits themselves

(14:41):
that started with Brexit, where you know, the settlement rights
in Europe were no longer there and so those not
even ultra high networth but mass affluent Brits who you
know had retirement plans in places like Portugal and Spain
and Greece are very interested in the golden visas there.

Speaker 2 (14:55):
Now, okay, and let's look at the young then where
are they going? I mean, I think I listen as
a board of hearing about my three days in Dubai.
But I was fascinated to see how many young Brits
they were there as something like two hundred thousand British
people in Dubai now and an awful lot of those
people are very young. And then if you flick through
the papers, you'll see almost every week you'll see a

(15:15):
story of where the young are going. Why thirty somethings
like me and moving down under. I'm moving to Malta,
you know, etcetera, etcetera. There's loads of it. There are
young workers flee UK to gain tax breaks in the Netherlands.
You know, there's headline after headline after headline. Where is
the easiest my best place for the young to go
if they want to get out of the UK, build

(15:38):
their CV, get some work, live a better lifestyle.

Speaker 3 (15:41):
Yeah, so I think you know, Dubai. The UAE, I mean,
the UAE is not just to buy, right, I would
Aaby Russell Kaimer really interesting jurisdictions within the UAE. But
clearly a lot of them are coming into the Middle East,
depending on what sort of industry they're in, you know,
is amazing sort of construction roles and that type of thing.

(16:02):
In places like Saudi we do still see a lot
of these sort of nomads, you know, freelancers that are
very much working on a laptop. Places like Malaysia and
Thailand from a cost of living perspective also interesting for
tax reasons are very common. And in Europe I guess
you know the same ones like Spain and Greece and Malta.

(16:22):
In these places they also have very attractive nomad visas,
digital nomad visas. You don't have to be high net
worth and you know, investing to get a golden visa.
In some of these places, we see quite a bit
of interest into some of the si of Central American
countries like Panama, Costa Rica. We see quite a lot
going from the US into Central and South America. I

(16:43):
would say that's probably the main ones. But it's it's about,
you know, places like to buy. Of course, there's lots
of wealthy coming there, but there's a lot of teaching jobs.
There's a lot of real estate agents, you know, and
they're for sure the Brits are are piling in it
at numbers like they've never seen before.

Speaker 2 (17:00):
Now, if you could choose any of the countries that
you recommend to your clients. Say you were one of
your clients, and here's this huge menu of amazing places
you could live. Which would you choose based not just
on the environment, but also on the physical environment, on
the taxed environment, and the political environment. What would be
your country?

Speaker 3 (17:21):
I would certainly go with Malta. It gives me, it
gives me, and it gives you know, anyone interested, the
ultimate flexibility because of course it's an island state. It's
a great travel document. So I'm a South African, so
you know, my Green Mumber doesn't is not very useful
to me as a travel document. I need a visa
to most places I go. So with the multi spo sport,

(17:41):
I can travel visa free pretty much anywhere in the world.
And the way I travel, that's quite useful. It's the
settlement rights. It gives me twenty seven EU member states
that I can base myself in. You know, certain people,
of course have a view on Europe currently as well,
so I wouldn't say it's the be all and end all,
but at least it gives me too many seven possible jurisdictions.

(18:01):
I can live, my kids can go and study, I
can work and of course, within that, there's probably three
or four that are also very interesting from a tax
perspective if I actually physically go and become tax residents.
So Malta is always sort of the top of it.
I explained, it is the top shelf option, but of
course it depends whether you have the financial ability to
participate or not.

Speaker 2 (18:22):
Yeah, I was letting, I was letting you have unlimited
funds that when I offered you the choice of the world,
we should say that one of the reasons why that
Malta program is so wonderful is because your firm designed it.

Speaker 3 (18:33):
Right, it is, but that is why it's so wonderful, right.

Speaker 2 (18:37):
Yeah, so you knew exactly what you wanted when you
designed it. Anything we've messed any visas, We haven't talked
about any countries that either the old or the young
or family should be looking.

Speaker 3 (18:46):
At another sort of maybe we haven't mentioned it been.
One of the latest citizenship by investment programs to launch
is actually an incredibly interesting one in Naaruru, which is
one of these islands in the South Pacific, and they've
actually created a climate resilience fund so you can actually
donate to climate resilience efforts that effectively will save the

(19:08):
island and in return you get citizenship of this island.
So it's a really sort of innovative way to you know,
address climate change challenges instead of just debating it at
COP twenty nine. You know, some of these islands are
actually taking their destiny into their own hands.

Speaker 2 (19:24):
But what a citizenship of NRI give you?

Speaker 3 (19:26):
It's visa free access to the UK, to Ireland, to
the UAE. So again places that me, as a South African,
I need to get in a queue and apply for
a visa. So here I can do something good for
the environment in a country and in return get a
citizenship and passport. That's quite useful for me as an
international business person.

Speaker 2 (19:43):
Interesting, and what does it cost?

Speaker 3 (19:45):
It's about one hundred and thirty five thousand dollars is
the cost to is the contribution to the fund that
incrementally increases if I want to include my wife and
my children. But it's around one hundred and thirty to
one hundred and seventy thousand dollars all in.

Speaker 2 (20:00):
Quite interesting, isn't it, Because that that doesn't seem that
much to get visa free access to say the UK,
I learned etc.

Speaker 3 (20:08):
Exactly exactly, And of course if you are worth you know,
fifty million dollars, then it's an absolute deal and loves
the same. It's the same even if you look at
it at a country like Malta, right, Malta, of course,
because it's EU. The capital art lay gets up to
about a million euros. But again, you know, if you,
if you, depending on who you're speaking to, if I'm

(20:29):
worth a hundred million dollars, what's a better legacy for
me to leave to my children? Is it another million
euro in the bank, another million euro in real estates,
or actually European citizenship which gives them unfitted access to
Europe that gets passed down to all future generations. I
think that's a significantly more interesting investment of my money
than you know, another apartment in London.

Speaker 2 (20:52):
Yeah, absolutely, Okay, I think our listeners might have thoughts
on this. Send emails and thoughts on all these things
to the usual address, which i'll read out in a
man Thank you everybody, Dominic, thank you so much for joining.
Our sales are absolutely fascinating. And now I'm worried I
haven't got enough passports. We can help you with it,
of course you can, but let's talk later. Thanks for

(21:12):
listening to this week's MEREN Talk to Your Money. If
you like our show, rate review, and subscribe wherever you
listen to podcasts. Also, be sure to follow me and
John on x or Twitter at meren sw and John
Underscore Stepic. This episode was produced by some Asadi Production
Sport by Moses and Questions and comments on this show
and all our shows always welcome. Our show email is

(21:33):
merin Money at Bloomberg dot net
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