The required documents that you will need can be found here, https://vasiliou.law/pdf/cyprus-investment-programme-2019.pdf, in case the project is not completed according to the building permit you obtained or not finished, it is a case that shall be reviewed with its merits in order to find the best possible solution to protect your investment capital and your CBI application.
How can I invest in an ongoing real estate development project for my Cyprus CBI application?
Is it possible to invest in a real estate project that is under construction to qualify for Cyprus’ citizenship-by-investment program? If so, what documents do I need to submit? If the project fails before completion, will my approved application be revoked?
At the time of your application, you will need to show that you have paid the minimum amount of investment. You also need to show that you have obtained a planning permit and a building permit. You will also need to provide quarterly updates in regards to the progress of construction and development. If you fail to show that the project is genuine and the construction is taking place, your application will not be approved and even if is approved, it will be revoked.
The applicant must invest a total of 2 million euros plus VAT as direct investment in the purchase and development of residential real estate, commercial real estate and development projects, including housing units in the tourism sector or other infrastructure projects. Investments must be on land that can be developed and must be accompanied by a development plan that must be approved by the relevant authorities. Land that does not fall in the specific zones will be excluded from the provisions. This investment option allows the applicant to skip the financial requirement of 500,000 euros plus VAT, thus reducing the overall investment as long as this amount is invested in at least one residential property. However, in the event residential property acquired had already been used for the purposes of the Cyprus Investment Program, the requirement for a permanent privately-owned residence property in Cyprus at least 500,000 euros plus VAT. The investment must be maintained for a minimum period of five years. In case where the property is under construction, at least 5% of the total value of the property must be blocked via a bank guarantee. The relevant amount will only be released to the vendor upon completion of the property. In case that the property is not yet constructed, the certified copy of the contract with the developer is necessary. Furthermore, it has the advantage of planning a building of 2 million euros with one flat of 500,000 euros and various one or two bedroom easily rented flats. In case of an investment of over 2 million euros for an unconstructed plot with a building plan including at least one property that equals or exceeds 500,000 euros, the ministry would accept the application without the extra 500,000-euro requirement. In case that there is a mortgage on the property, a bank waiver letter is needed. In case it is a land plot under development, it must be declared as a constructible land. An evaluation certificate from an independent registered land surveyor may be required by the Ministry of Interior or the Ministry of Finance. Relevant documents include a planning permit and a sale agreement.
Please note that the following documents are required for applying for the Cyprus Investment Program under the real estate category: a contract of sale; title deeds or proof of registration of the contract with the lands and the surveys department; proofs of payment of the agreed purchase price; a copy of the wire transfer to a Cypriot commercial banking institution in the name of the seller or the seller's company; an evaluation certificate from an independent registered land surveyor, if required by the Ministry of Interior or the Ministry of Finance; investment plan for the development of the purchased land, if the investment involves the purchase of land under development; a town-planning permit, provided that it is required by the Town and Country Planning Law; a declaration by the mortgage lender in the benefit of whom the purchased property or properties is mortgaged that will waive the mortgage, provided that the investor or the seller will pay the lender the amount in the declaration; a project completion certificate signed by the architect of the project. If the purchased property is under construction, it is required either to maintain an amount equal to the 5% of the purchase value in a special account, or for the seller to issue in the benefit of the purchaser a performance bank guarantee equal to the 5% of the purchase value. If the project does not finish, your application will not be revoked.