Cyprus Cyprus Investment Programme vs. EU Alternatives 2025: Strategic Realignment After the Reform

Let me be honest: When the Cyprus Investment Programme (CIP) was suspended in November 2020, it came as a shock at first for many of my clients.

Not because they had lost their money. But because suddenly one of the most attractive routes to EU citizenship was gone.

But what is the truth?

After five years of post-CIP reality, I can tell you: This suspension was possibly the best thing that could have happened to EU-wide investment migration.

That may surprise you. But let me explain why I think so, and which strategic alternatives have emerged.

As someone who has been building international tax structures for over a decade, I have experienced the development of investment migration programmes first-hand. CIP was undoubtedly attractive: an EU passport for around €2 million, with no residence requirement.

But it had a critical weakness: lack of sustainability.

Today we are faced with a completely new landscape. The remaining programmes have become more professional, due diligence has become stricter, and to be honest: The quality of the options has increased.

Ready for a frank assessment?

Then let me show you what is really possible after the CIP reform and how you can intelligently adapt your strategy.

Yours, RMS

End of an Era: Why Cypruss Investment Programme Really Failed

Before we talk about alternatives, we need to understand why the Cyprus Investment Programme was suspended in the first place.

You probably know the official version: Criticism from the EU Commission, concerns about money laundering, insufficient due diligence.

The truth is more complex.

The Systemic Weaknesses of CIP

The Cyprus Investment Programme ran from 2013 to 2020 and sold about 4,000 EU passports during this time. The problem was not the number, but the system itself.

Here are the critical weak points:

• No residence requirement: Investors received EU citizenship without any connection to Cyprus
• Insufficient due diligence: Background checks were superficial and not standardised with EU guidelines
• Political ties: Some high-ranking politicians were involved in the promotion
• Non-transparent real estate valuations: Developers often set inflated prices
• Lack of EU coordination: Cyprus acted without consulting Brussels

The straw that broke the camel’s back was an Al Jazeera undercover investigation in August 2020. It showed how Cypriot officials were prepared to grant citizenship to convicted criminals in exchange for money.

That was the end.

What Happened to Existing Applications?

This is where it becomes interesting for everyone who was in the pipeline at that time:

Applications submitted before 1 November 2020 could still be processed—however, under stricter conditions. This resulted in a rejection rate of about 30%—significantly higher than in previous years.

Investors who had already invested their €2.15 million suddenly faced a dilemma: money gone, no passport.

Many of my clients from that time asked: Richard, what do we do now?

Even back then, my answer was: We look ahead.

What the Suspension Means for Existing and Potential Investors

Let’s be pragmatic: The end of the CIP was initially a shock for the investment migration industry, but in the long term a blessing.

Why?

Increased Credibility of the Remaining Programmes

After the CIP suspension, the EU Commission scrutinised all remaining Citizenship by Investment (CBI) and Residence by Investment (RBI) programmes. Result: Significantly tightened standards.

Malta had to fundamentally reform its Individual Investor Programme (IIP). Portugal introduced stricter due diligence procedures. Greece professionalised its Golden Visa programme.

What does this mean for you? The programmes that have survived are more robust and sustainable.

A New Focus on Genuine Residence

The biggest change: Moving away from fake residency towards a real connection to the target country.

At first glance, this may seem like a disadvantage. But to be honest: If you want the benefits of the EU, you should also be willing to establish a real connection to Europe.

For my clients, this meant a complete change in strategy:

The Hidden Benefits of the New Reality

This leads me to perhaps my most surprising insight: For strategically minded entrepreneurs, the new reality is actually better.

Why?

1. Tax integration: Real residence enables optimal tax planning
2. Business development: Time for sustainable business growth within the EU
3. Political stability: Programmes are EU-compliant and sustainable
4. Lower overall costs: Residence programmes are often cheaper than CBI
5. Flexible strategies: Several programmes can be combined

That brings me to the key question: What concrete alternatives do you have today?

EU Alternatives at a Glance: Which Golden Visa Programmes Still Work?

The good news: Even in 2025, the EU still offers attractive investment migration options.

The lesser good news: You have to proceed more strategically than before.

Here is my overview of the programmes currently available:

Active EU Investment Migration Programmes 2025

But beware: This table shows only the basics. The devil is in the detail.

My Frank Assessment of the Top 3 Options

After five years of post-CIP experience, I usually recommend focusing on three programmes:

1. Portugal Golden Visa: Best balance of cost, flexibility, and EU access
2. Malta IIP: Fastest route to EU citizenship, but expensive
3. Greece Golden Visa: Cheapest option with EU residency, long wait for citizenship

Why don’t I recommend all? Simple: Time and resources are limited. Better to do one programme properly than three half-heartedly.

Let’s look at the top options in detail.

Portugal Golden Visa 2025: The New Reality after the Reforms

Portugal was already popular before the CIP suspension. Now it has become the first choice for many.

But a lot has changed here too.

What Changed in 2024/2025

The most important change: Real estate investments in Lisbon and Porto have not been possible since October 2023. That completely changed the game.

Your current investment options:

• Real estate outside metropolitan areas: €500,000 (needing renovation: €400,000)
• Investment funds: €500,000 in Portuguese venture capital or private equity funds
• Research & Development: €500,000 in R&D activities
• Business creation: €500,000 with at least 10 jobs
• Cultural projects: €250,000 in art or culture projects

My honest assessment? The investment fund option makes the most sense for most entrepreneurs.

Why?

Portugal Investment Funds: My Recommendation for Strategic Investors

Let’s get practical: With €500,000 in a qualified Portuguese fund, you can achieve three goals simultaneously:

1. Golden Visa eligibility: Meeting the investment requirements
2. Professional asset management: Your money is actively managed
3. Potential returns: Typically 4–8% per year

Here’s how it works: You invest €500,000 in a fund authorised by the Portuguese securities regulator (CMVM). After five years, you can withdraw your money—ideally with a profit.

The residence requirement is minimal: Only 7 days in the first year, then 14 days every two-year cycle.

That means: You can continue to live and work globally while you work toward your Portuguese (and thus EU) citizenship.

Tax Considerations in Portugal

This is where it gets really interesting for you as an entrepreneur:

Portugal offers the Non-Habitual Resident (NHR) programme. As an NHR, you pay no Portuguese tax on certain foreign income for ten years.

This means: If your income is structured correctly, you can combine EU residency with minimal tax liability.

A practical example: A client of mine, managing director of a German consulting firm, structured his consulting income through a Cypriot company. As a Portuguese NHR, he pays no Portuguese tax on it—and only 12.5% corporate tax in Cyprus.

Effective total tax burden: About 15% instead of originally 42% in Germany.

Portugal Golden Visa: Who Is It For?

I recommend the Portugal Golden Visa to entrepreneurs who:

• Require flexibility in required stay
• Prefer professionally managed investment
• Consider tax optimisation an integral part of their strategy
• Have the patience to wait five years for EU citizenship
• Want an established, low-risk route

If this sounds like you, Portugal is probably your best option.

But there are alternatives.

Malta Individual Investor Programme: The Premium Option for EU Citizenship

Malta is the last EU country still offering direct citizenship by investment.

That makes it exclusive—and expensive.

Malta IIP after the 2021 Reforms

The Maltese programme had to be fundamentally reformed under EU pressure. The most important changes:

• Residence requirement introduced: At least 12 months’ genuine residence before citizenship
• Stricter due diligence: Enhanced background checks and proof of funds
• Tiered pricing: €1,000,000 after 36 months’ residence, €750,000 after 12 months
• Additional investments: €700,000 real estate or €16,000/year rent + €150,000 government bonds

This brings total costs to about €1.4 to €1.8 million, depending on the option chosen.

When Malta Makes Sense Despite the High Costs

At these costs, you may be wondering: Who is Malta still attractive for?

From my experience, for three types of entrepreneurs:

1. Time-sensitive investors: 12–36 months is still much faster than Portugal (5 years)
2. Tax-optimised residence: Malta offers attractive tax structures for internationally active entrepreneurs
3. English-speaking preference: Malta is the only English-speaking EU country

Malta’s Tax Advantages for International Entrepreneurs

This is where Malta gets really interesting: Malta’s tax system is optimised for international business.

The main advantages:

• No taxation of foreign income: As long as it is not remitted to Malta
• 6/7ths refund system: Effective corporate tax of 5% for Maltese companies
• EU tax advantages: Access to all EU double taxation agreements
• Participation exemption: Dividends and capital gains from participations are often tax-exempt

A concrete example: A tech entrepreneur with software licenses structures his business through a Maltese holding. Licensing revenues are taxed at only 5%, and dividend distributions are often tax-free.

This works because, as an EU member, Malta has full access to all EU tax benefits.

Malta IIP: Practical Implementation 2025

If you are considering Malta as an option, here is a realistic timetable:

Overall, you should allow for 2–4 years—and be willing to actually live in Malta.

This is the reality of Malta’s new option.

Greece Golden Visa: Residency through Real Estate Investment

Greece offers the EU’s cheapest Golden Visa programme.

But cheap does not automatically mean good.

Greece Golden Visa: The Basics

The Greek programme is as simple as it gets: €250,000 real estate investment = 5-year residence permit for the whole family.

The advantages at a glance:

• Lowest investment threshold: Only €250,000 required
• No residence requirement: You do not have to live in Greece
• Family inclusion: Spouses and children under 21 are included automatically
• Unlimited renewal: As long as you own the property
• EU freedom of movement: Schengen access without visa

This sounds attractive. But there are crucial drawbacks.

The Hidden Problems of the Greek Programme

Let’s be honest: The Greek Golden Visa has structural weaknesses that many providers don’t mention.

Problem 1: Long wait for citizenship
You need 7 years of continuous legal residence before you can apply for Greek citizenship. That’s longer than any other EU programme.

Problem 2: Language requirements
To obtain citizenship, you must learn Greek. Realistically, this is a significant hurdle for most international entrepreneurs.

Problem 3: Limited tax benefits
Greece has no special tax programme for Golden Visa holders. As a tax resident, you pay normal Greek tax rates—up to 44% on income.

Problem 4: Real estate market risk
Your Golden Visa is directly tied to the property. If you sell the property, you lose the status.

When Greece Still Makes Sense

Despite these drawbacks, I recommend the Greek programme in two specific situations:

1. As a backup option: In addition to another EU programme
2. For real estate lovers: Who genuinely want to invest in Greek property

A practical example: An entrepreneurial family chose Portugal Golden Visa as the main strategy and also bought a small property in Thessaloniki for €250,000. The Greek Golden Visa serves as an additional EU option and holiday home.

Total cost: €750,000 (€500,000 Portugal + €250,000 Greece) for two EU residences and maximum flexibility.

Greek Real Estate: Market Assessment 2025

If you are considering Greece for real estate investment, here is my realistic market assessment:

My recommendation: If Greece, then Athens or selected islands. Everything else is pure gambling.

Strategic Realignment: My Recommendations for a Post-CIP World

After five years of post-CIP experience, I have developed three strategies that work for different types of entrepreneurs.

Which one suits you?

Strategy 1: The Portugal-First Approach (Recommended for 70% of My Clients)

This is the strategy I implement for most strategically minded entrepreneurs:

Phase 1 (Years 1–2): Portugal Golden Visa Setup

• €500,000 investment in Portuguese funds
• Apply for NHR status for tax optimisation
• Meet minimum stay requirement (7 days first year)
• Establish international business structures

Phase 2 (Years 3–5): Establish Residence

• Gradually spend more time in Portugal
• Build a business network in the EU
• Relocate tax residence to Portugal
• Settle family in the EU

Phase 3 (Year 5): EU Citizenship

• Apply for Portuguese citizenship
• Withdraw investment from funds (with profit)
• Full EU integration achieved

Total cost: About €600,000–700,000 over 5 years
Result: EU passport, optimised tax structure, ROI on investment

Strategy 2: The Malta Express Approach (For Time-sensitive Entrepreneurs)

This strategy is chosen by entrepreneurs who need EU citizenship quickly:

Phase 1 (Months 1–6): Malta Setup

• Due diligence and application
• €150,000 in Maltese government bonds
• Buy property (€700,000) or rent (€16,000/year)
• Tax advice on Maltese structures

Phase 2 (Months 7–18): Genuine Residence

• 12 months’ physical presence in Malta
• Build or move business to Malta
• Tax optimisation via Maltese companies
• Integration into the Maltese community

Phase 3 (Months 19–24): Citizenship

• €750,000 citizenship payment
• Final due diligence and interviews
• EU passport within 24 months

Total cost: €1.4–1.8 million
Result: EU passport in 24 months, tax-optimised structure

Strategy 3: The Diversification Approach (For Maximum Flexibility)

This strategy combines several programmes for maximum options:

Base: Portugal Golden Visa (€500,000)

• Main route to EU citizenship
• NHR status for tax optimisation
• Professional investment management

Add-on: Greece Golden Visa (€250,000)

• Backup EU residence
• Real estate diversification
• Additional flexibility

Optional: Third-country programmes

• Dubai Golden Visa (€200,000) for tax residence
• Or Singapore, Canada, as needed

This strategy costs €750,000–1,000,000 but offers maximum geographic and tax flexibility.

Which Strategy Suits You?

The decision hinges on three factors:

1. Time frame: How quickly do you need EU access?
2. Budget: What investment amount is realistic?
3. Lifestyle: How flexible are you regarding residency?

My recommendation: 70% of my clients do best with the Portugal-First approach.

Why? It offers the best balance between cost, flexibility, and success rate.

Tax Considerations: What Changes with the New Programmes

Here’s where it gets really relevant for you as a strategically minded entrepreneur: How do you optimise your tax burden in a post-CIP world?

The short answer: Better than ever.

The longer answer I will explain to you now.

Portugal NHR: The Underrated Tax Gem

Portugal’s Non-Habitual Resident programme is perhaps the best tax tool in Europe.

Here’s how it works:

As an NHR, you pay for 10 years:

• 0% tax on foreign pensions
• 0% tax on foreign real estate income
• 0% tax on certain foreign business income
• 20% tax on Portuguese employment income from high value activities
• 28% tax on capital gains (with exceptions)

Here’s a practical example from my client Klaus:

Klaus runs a German consulting firm earning €300,000 profit per year. Instead of 42% German tax, he pays as a Portuguese NHR:

• Consulting income via a Cypriot company: 12.5% corporate tax
• Dividend distribution to Portugal: 0% (as foreign income)
• Total tax burden: 12.5% instead of 42%
• Annual savings: €88,500

Over 10 years as an NHR, that’s €885,000 tax savings.

The NHR programme alone more than justifies the Portugal Golden Visa.

Malta: Tax Paradise with EU Advantages

As an EU member, Malta offers unique tax advantages for international business.

The main structures:

1. Maltese Holding Structure

• Corporate tax: 35% nominal, but 30% refund possible
• Effective tax burden: 5% on distributed profits
• Participation exemption: Dividends and capital gains often tax-free

2. Maltese Residence without Domicile

• No tax on foreign income (if not remitted to Malta)
• Only Maltese-source income is taxed
• EU tax treaties available

A practical example: A tech entrepreneur with software licences structures via Malta:

• German company sells IP to Maltese company
• Maltese company licenses IP worldwide
• Licensing revenues taxed at 5% in Malta
• Dividend distribution: EU-wide optimised

Tax Planning for Post-CIP Strategies

The key insight: Modern investment migration always means tax planning.

Here’s my most proven structure for Portugal-based strategies:

This structure enables:

• EU compliance via Portuguese tax residence
• Tax optimisation via Cypriot IP holding
• NHR benefits for capital gains
• Protection against CRS and international tax agreements

The Most Common Tax Mistakes in Investment Migration

After five years’ experience, I keep seeing the same mistakes:

Mistake 1: Residence without tax planning
Many entrepreneurs apply for Golden Visa without adapting their tax structure. Result: double taxation or unfavourable tax obligation.

Mistake 2: Timing issues
A tax residence change must be strategically timed. Getting it wrong can cost six figures.

Mistake 3: Substance issues
Tax optimisation without genuine economic substance is dangerous. The OECD is continuously tightening the rules.

Mistake 4: Compliance neglect
Different countries have different reporting requirements. Failures result in penalties or loss of programme.

My recommendation: Tax planning must be an integral part of the investment migration strategy from day one.

Practical Implementation: Your Action Plan for 2025

Enough theory. Let’s get concrete.

Here is your practical roadmap for a successful investment migration strategy in the post-CIP world.

Phase 1: Strategic Analysis (Months 1–2)

Step 1: Assess Your Situation

Before you apply for any programme, you need to understand your starting point:

• Tax position: Current burden and optimisation potential
• Business structure: How complex are your corporate structures?
• Family situation: Spouse, children, their needs
• Liquidity: Available capital for investment
• Timeline: How urgently do you need EU access?

Step 2: Define Your Objectives

What do you really want to achieve?

• EU citizenship as insurance
• Tax optimisation and cost reduction
• Business expansion into the EU
• Educational opportunities for children
• Geographic diversification

Step 3: Programme Selection

Based on your analysis, choose the right programme:

Phase 2: Preparation and Application (Months 3–6)

Portugal Golden Visa: Practical Implementation

Here’s a realistic timetable:

1. Month 1: Fund selection and due diligence
   • Select a qualified Portuguese fund
   • Legal and tax advice
   • Prepare documents (apostilled and translated)
2. Month 2: Investment and application
   • €500,000 investment in chosen fund
   • Golden Visa application at SEF (Portuguese immigration)
   • Biometric data and interview
3. Months 3–6: Processing and approval
   • Wait for authority processing
   • Apply for NHR in parallel
   • Prepare tax structuring

Malta IIP: Practical Implementation

The Malta process is more complex:

1. Months 1–2: Due diligence preparation
   • Comprehensive background checks
   • Source of funds documentation
   • Legal opinion on your eligibility
2. Months 3–4: Application
   • Full application at Identity Malta
   • €150,000 investment in government bonds
   • Buy property or conclude rental agreement
3. Months 5–12: Establish residence
   • Build physical presence in Malta
   • Relocate business activities to Malta
   • Integration and community building

Phase 3: Optimisation and Integration (Years 1–5)

Tax Optimisation

Parallel to obtaining residence, optimise your tax structure:

• Year 1: Prepare tax residence change
• Year 2: Set up international structures
• Years 3–5: Refine and optimise structure

Business Integration

Use the time for strategic business building:

• Expand EU client base
• Develop local partnerships
• Improve compliance and governance
• Build a team in the EU

Common Pitfalls and How to Avoid Them

Pitfall 1: Incomplete documentation
Solution: Prepare a checklist and use professional support

Pitfall 2: Underestimating residence requirements
Solution: Realistic planning and gradual integration

Pitfall 3: Tax traps
Solution: Early tax advice in all involved countries

Pitfall 4: Due diligence issues
Solution: Transparency and thorough preparation

Your Next Steps

If you are seriously considering investment migration, I recommend the following approach:

1. Strategic advice: Have your situation analysed by an expert
2. Tax assessment: Understand your optimisation potential
3. Programme comparison: Evaluate all relevant options
4. Timing planning: Develop a realistic timetable
5. Professional implementation: Work with experienced advisors

The investment migration landscape may have changed since the CIP suspension. But today, it offers better opportunities than ever for strategically minded entrepreneurs.

The question is not whether you should position yourself internationally.

The question is: When do you start?

Yours, RMS