According to the Cyprus Council of Ministers' decisions dated Sept. 13, 2016, Jan. 9, 2018 and May 21, 2018, concerning the Cyprus Investment Program based on article 111A (2) of the civil registry law 141(I)/2002, a non-Cypriot citizen may obtain Cyprus citizenship if he/she fulfils one of the financial criteria, e.g., by investing in real estate developments including tourist developments. Nevertheless, a potential investor apart from the financial criteria must also fulfil other criteria. Among these criteria are the requirements to obtain permanent residency in Cyprus through an investors' immigration permit as well as owning a permanent, privately owned residence of at least 500,000 euros, plus VAT. Therefore, in reply to your question, under the Cyprus Investment Program, there is no requirement for having a "significant presence" in Cyprus. The relevant requirement stipulates that investors' should obtain an immigration permit as well as a permanent, privately-owned residence of at least 500,000, plus VAT. It must be noted, though, that in case where the investor invests exclusively in residential units in satisfaction of the financial criteria, it will not be required to purchase another privately owned residence, provided that one of the residential units has a value of at least 500,000 and that it will be maintained by the investor throughout his/her life.
How does Cypriot law define “significant presence” when it comes to a citizenship-by-investment business?
I wish to build a small hotel in Cyprus and obtain citizenship through this investment. Assuming I can get all my local permits and hire the right number of Cypriots, will my new hotel be considered “significant” enough to be used in my citizenship application? What does the government consider “significant”?
The investment that you are planning to do in Cyprus is indeed considered significant. The invested funds shall be channeled toward the financing of the investment objectives of these companies exclusively in Cyprus, based on a specific investment plan. It requires significant activity and turnover and employ at least five Cypriot or citizens of European Union member-states. In addition, the employees of the companies need to have legally and continuously resided in Cyprus during the five years preceding the application submission date. Once you meet the above requirement, which you are aware of and the whole investment of 2 million euros is used for the hotel in Cyprus, then you will need to purchase a permanent residence of 500,000 euros and your application shall be approved without any difficulties, provided that all the KYC and AML requirements are fulfilled.
The law does not provide a definition of significant investment, but it provides for the minimum amount which must be invested in order for an applicant to be eligible to apply. Provided that your investment is a minimum of 2 million, you will be eligible.
In order to apply for the second criterion of the Cyprus Investment Program (CIP), the applicant should have made a purchase or should have participated in companies or organizations established and operating in the Republic of Cyprus with investment costs of at least 2 million. The invested funds shall be channeled toward the financing of the investment objectives of these companies exclusively in Cyprus, based on a specific investment plan. The applications shall be evaluated to verify that the companies or organizations have proven physical presence in Cyprus, with significant activity and turnover and employ at least five Cypriot or citizens of European Union member-states. Therefore, the business should have an actual physical presence in Cyprus (the hotel to be located and operating in Cyprus) and employ a minimum five European Union citizens, among other employees. The hotel should have an actual activity and significant turnover to create business.