Donation, real estate, government bonds: the CBI investment routes explained

Acquiring citizenship by investment does not mean buying a passport. It means meeting an investment condition set out in law. How these programmes work in principle, which countries offer them and how the application runs is covered in Buying citizenship. After that comes the decision that sets your total price: the form your investment takes.

Citizenship by investment: the five types of investment at a glance

Every programme defines in a law or regulation which forms of investment it recognises. At heart there are five:

On top of that come the government fees in every case: application, processing and due diligence fees, payable with the application and never refunded. Their level differs from one type of investment to the next, and that is often exactly where it is decided which route makes sense for you. The fees of every open programme side by side are on the costs page.

The basic rule is simple: the less capital comes back, the lower the entry point. If you want to pay a fixed sum and be done with it, choose the donation. If you want to park wealth, choose real estate, bonds or a deposit, and accept a higher amount and a holding period in return.

The donation: the direct route to citizenship

In the legislation the donation is usually called a contribution: a fixed sum paid into a state fund that is not repaid. You have nothing to manage, nothing to rent out and nothing to sell later. Once you pay, your investment condition is met.

Add to these Vanuatu, with the Development Support Program from 130,000 USD for a single person, and Cambodia, with a donation to the national budget of 12,000,000,000 KHR through the Ministry of Economy and Finance. Antigua and Barbuda also offers a contribution to the UWI Fund for the University of the West Indies campus: 260,000 USD for families of six or more, processing fees included.

What happens to your money

The funds pay for public projects. For its Economic Diversification Fund, Dominica names the building of schools, the renovation of hospitals and a national stadium, along with projects in tourism, information technology and agriculture. St Kitts and Nevis names local food production, green energy, economic diversification and social protection for its contribution. So your contribution is not a fee to an authority but capital for building up a small country that, in return, takes you in as a citizen.

Timing matters for your planning. São Tomé and Príncipe expressly asks for the donation only after approval in principle. Until then you pay only the filing fee of 5,000 USD per application. If you are not approved, the large sum has never left your account.

Sierra Leone: a programme fee held in escrow

Sierra Leone takes its own path. Instead of a donation you pay a programme fee that sits in an escrow account until naturalisation. If the naturalisation cannot be completed, it is refunded in full, except for filing and processing costs. The most affordable option is Solo Entrepreneur, for single applicants without dependants, at a 95,000 USD programme fee, or 103,750 USD together with the filing and processing fees. If you want to bring your family, you choose Fast Track Citizenship from 140,000 USD for the main applicant, with spouse, children, parents, grandparents and siblings.

Citizenship by real estate investment: amounts and holding periods

On the real estate route you buy a government-approved property, usually in a hotel or resort development, and hold it for a period set by law. After that it is yours, with no strings attached.

In St Kitts and Nevis you can also buy an approved private single-family home from 600,000 USD instead of an apartment, likewise with a seven-year holding period. Grenada additionally accepts a share in a holiday property with several buyers from 270,000 USD per share, plus a 50,000 USD government contribution.

Approved projects, not the open market

In the Caribbean, only a property that the authority has approved for the programme counts. That protects you: the state vets the project before it may take on investors, and publishes the approved developments. St Lucia, for example, lists A'ILA Resorts Villas & Residences and Canelles Resort.

Türkiye works differently. There, any apartment or built plot from 400,000 USD counts, provided an annotation is entered in the land register that you will not sell for three years. A purchase before completion counts too, if you pay the full price in advance and a notarised preliminary contract with the same restriction is entered in the land register. Before buying, you exchange the foreign currency at a bank in Türkiye, which sells it on to the Central Bank. The route step by step is described in Turkish citizenship through real estate.

The holding period: what it means for you

The holding period is the price of getting your capital back. In St Kitts and Nevis you may not sell for seven years. If the property is sold earlier, it no longer counts for any later application, unless the Federal Cabinet accepts that substantial further investment has been made in the unit. Antigua and Barbuda allows a sale before the five years are up only if you buy another approved property in the country instead.

Dominica has the most detailed rules on resale: three years from naturalisation, but five years if the buyer wants to use the property to apply for citizenship themselves. So if you plan to sell to a future applicant later, you plan with five years.

If you also see the island as a place to live or a holiday home, the licence requirement, purchase costs and buying process for foreigners are covered in Buying property in Dominica and Buying property in Antigua and Barbuda (both in German).

Donation or real estate: what adds up for you

What counts is not the entry amount but what is gone at the end. Calculated for you alone, with investment and government fees, excluding purchase costs:

This is how the totals break down:

• Dominica: 1,000 USD processing, 7,500 USD due diligence, 1,000 USD interview and 500 USD certificate; on the real estate route, a further 75,000 USD government fee.
• Antigua and Barbuda: 10,000 USD processing, 8,500 USD due diligence and 300 USD passport.
• St Lucia: 2,000 USD processing and 8,000 USD due diligence; on the real estate route, a further 30,000 USD administration fee.
• St Kitts and Nevis: 250 USD application fee and 10,000 USD due diligence; on the real estate route, a further 25,000 USD fee after approval.

Now it gets interesting. With the donation in Antigua and Barbuda, 248,800 USD is spent. On the real estate route it is only 18,800 USD in fees, if you sell the property after five years at the purchase price. In St Kitts and Nevis it is 260,250 USD against 35,250 USD, in St Lucia 250,000 USD against 40,000 USD, in Dominica 210,000 USD against 85,000 USD.

Three factors decide how the numbers work out for you:

1. The resale price. Whether you get the same price after the holding period, more or less, depends on the project, the location and the market.
2. Purchase costs and running costs. Transfer tax, notary, management and maintenance come on top of the government amounts.
3. The income in the meantime. Many approved projects are hotels and resorts. If your unit is let, your capital earns income during the holding period instead of just sitting there.

If you want the citizenship and not the house, the donation is the simplest route: one payment, no management, no sale. If you want to park capital in real assets anyway, real estate often brings a large part of your outlay back.

Government bonds: park your capital instead of spending it

Government bonds are the route for anyone who wants neither to donate nor to manage a property. You lend the state money, hold the bond for a fixed period and then get it back.

Türkiye: government bonds from 500,000 USD

The implementing regulation to the Turkish Citizenship Law expressly names, in Art. 20(2), the purchase of government bonds worth at least 500,000 USD, held for three years. The currency is what matters: before the purchase, the foreign currency is sold to a bank in Türkiye and from there to the Central Bank. The amount is invested in government bonds in Turkish lira. So your capital sits in lira for three years, and the exchange rate decides how many euros or dollars you end up with.

The regulation also allows you to switch between types of investment to complete the required period. So you are not tied to a single investment for three years. The programme details are on the Türkiye page.

St Lucia: National Action Bonds

On its overview, St Lucia's Citizenship by Investment Unit lists the National Action Bonds: interest-free government bonds that stay registered in the applicant's name for five years from first issue, for the applicant with any number of dependants. Every route to St Lucia is set out in St Lucia: donation, real estate or government bonds.

Interest-free means the bond costs you the return your money would have earned elsewhere over five years. In return you get the capital itself back, with no property market and no hunt for a buyer.

Business, bank deposit, funds: the routes for entrepreneurs and investors

For larger fortunes and for entrepreneurs, some programmes offer routes on which your capital does productive work.

Antigua and Barbuda: On your own, you invest at least 1,500,000 USD in an approved business. In a joint investment, at least two people invest 5,000,000 USD together, each at least 400,000 USD. You transfer the money within 30 days of the approval letter.

St Lucia: An approved business project requires 3,500,000 USD and at least three permanent jobs for a single investor, or 6,000,000 USD jointly, with at least 1,000,000 USD per applicant and six permanent jobs.

Türkiye: Besides real estate and bonds, Türkiye recognises five further forms: a fixed capital investment of 500,000 USD, a bank deposit of 500,000 USD for three years, units in real estate or venture capital funds of 500,000 USD for at least three years, 500,000 USD in a private pension for three years, and a business employing at least 50 people.

Jordan: Here the route runs exclusively through businesses and the capital market, for instance an existing business outside the capital region from 350,000 JOD in average fixed assets with ten Jordanian employees, a new productive project there from 500,000 JOD in paid-up capital with jobs, or shares on the Amman Stock Exchange from 1,500,000 JOD, held for five years. The conditions are on the Jordan page.

Cambodia: An investment of 4,000,000,000 KHR of your own capital in a project in a priority sector, with an investment licence.

These routes pay off above all if you want to invest in the region anyway. Then the investment for citizenship becomes an investment you would have made without it.

Which type of investment suits your family?

With every dependant the calculation shifts, and it shifts differently for each type of investment. With the donation, the base amount covers a small family; beyond that, each further dependant costs extra:

• Dominica: 250,000 USD for you and up to three dependants, then 25,000 USD per child under 18 and 40,000 USD per dependant aged 18 or over.
• St Lucia: 240,000 USD for you and up to three dependants, then 10,000 USD under 18 and 20,000 USD over 18.
• St Kitts and Nevis: 250,000 USD for up to four people, then 25,000 USD under 18 and 50,000 USD from 18.
• São Tomé and Príncipe: 95,000 USD for two to four people, then 5,000 USD per dependant.

The real estate route looks different. In St Lucia the 300,000 USD minimum applies to any number of dependants; only the administration fee rises. For a large family with adult children or parents, real estate can therefore cost less than the donation, even though the entry point is higher.

Which programmes take parents and grandparents, and where the age limits lie, is set out in Bringing parents and grandparents. The family rules of every programme at a glance are on the family page.

What happens to your German passport, and what comes next

Whichever way you invest, you keep your German passport. Since 27 June 2024 you no longer lose German citizenship when you acquire a foreign one. The former retention permit (Beibehaltungsgenehmigung) has been abolished.

What you acquire with the investment is more than a travel document. A visa or a residence permit is a permission that a state can refuse or withdraw. Citizenship is a right you can rely on for life, for yourself and for the children you include in the application.

And the investment does not rule out the other great route. Naturalisation through residence is, in the end, the free and often better path to a further passport, but it takes years and requires genuine residence. The investment gives you second citizenship today, while you build up naturalisation in parallel. How the two fit together is explained in CBI and naturalisation: why you should pursue both. What the application looks like from the first step to the oath is on the process page, and what a second passport means for your taxes is under taxes.

Frequently asked questions