The definition of a "link" in this case corresponds to companies/funds (and/or their assets) that possess or plan to possess investments made exclusively in the republic of Cyprus. The assessment of the "validity" of the link is being assessed and approved by the Ministry of Finance. With regards to whether a multi-national company with an office in Cyprus is eligible, in my view its acceptance by the Ministry of Finance is remote, unless it can be proven that the multi-national company actually operates (employees, etc.) and invests in the republic of Cyprus (i.e., it can display that it has a contribution in the country's economy). The above is my view and from my experience. However, an official request/application could be sent to the Ministry of Finance to verify the matter.
How does the purchase of alternative investment funds work for the Cyprus citizenship-by-investment program?
I know I can purchase funds or other financial assets linked to Cyprus for my program. I can also purchase financial assets with companies linked to Cyprus. But how much of a link does there need to be? Who or what defines it? What about a multinational with an office in Cyprus, for instance?
The government of Cyprus introduced the Cyprus investment program (the CIP) in an effort to boost the economy, bring foreign investments into the country, create new opportunities for investors and create new jobs for employees. The investment in order to qualify needs to be direct investment into Cyprus economy. A fund to qualify for investment under CIP needs to have authorization from Ministry of Finance, and in order for the fund to receive that, authorization of the above should criteria is essential. Therefore, the multinational fund you are mentioning must have an investment policy for Cyprus which must be proven by a business plan. Also, ongoing reporting regarding the investment may be requested. Therefore, the establishment of an office and hiring of employees will not result to the outcome you intent to have. There are already licensed funds that offer attractive guaranteed returns and provide you with exit strategy after the five years required by the CIP.
With regards to AIFs please note that applicant must purchase units of at least 2 million euros from eligible alternative investment funds (AIFs) and/or registered alternative investment funds (RAIFs). The eligibility criteria for the AIFs are: established in CY, licensed and supervised by CySec, investing in Cyprus, such investments are in accordance with the naturalization scheme or approved by the Ministry of Finance. Generally speaking, there is the possibility to ask the ministry whether a particular AIF or RAIF is compliant/ eligible. With regards to investment of financial assets of Cyprus companies or Cyprus organizations, the applicant must invest a minimum of 2 million in acquiring, participating in organizations or companies established and operating in Cyprus. Such organizations or companies must have a physical presence in Cyprus, significant activity and turnover, and employ at least five Cypriot nationals or European citizens. Investment in the shipping sector are now eligible based on measurable criteria to be determined by the Ministry of Finance and the shipping department. A multinational with a Cyprus registered branch that fulfills the above requirements is likely to be eligible, provided that a strong business plan is also submitted. Additionally, there are ways of structuring the investments so as to be eligible and relevant meetings with the ministry can be arranged in order to fulfill certain requirements or for the ministry to impose conditions in order to accept the investment. Generally speaking, the ministry is interested to promote serious and strong investments into the economy, so the presentation and the rationale of the structuring is taken into account. Another priority is R&D, so relevant projects will also be strongly considered by the ministry. Please note that a combination of the criteria of investment is also possible, so in this respect hedging is also possible.
In general, all investments have to be directly associated with Cyprus. The alternative investment funds have to be registered and regulated in Cyprus (e.g., CySec) and the investment for the purposes of citizenship has to be carried out in Cyprus (not abroad). The underlying purpose is for Cyprus to benefit directly from the investment. As with any type of investment, so will alternative investment funds and their investments be evaluated in order to ascertain that the investment program's criteria are strictly met. For the time being, it is also important to note that there are impending amendments to be effected on May 15. As far as the "link" is concerned, it would be best if you could elaborate, so that a specific answer may be provided. The information regarding the multinational with an office in Cyprus is also minimal for us to provide you with a tangible answer. Please keep in mind that citizenship is personal. This means that the individual applying will be the center of attention. From this point of view, it will have to be evidenced that the individual applying is the actual investor and the basis for success of the application shall be whether any individual has met the program's criteria. Therefore, through the structure of the multinational with an office in Cyprus, it has to be evidenced that the applicant meets the criteria. The Committee of Supervision and Control of the Cyprus Investment Program is the body responsible for the program and applications for citizenship.