Overseas real estate investment: same capital, two approaches, two different outcomes
This article starts with your family's goals and then maps them against each program. For each program in the final section, we cover 2 things: which families it may suit, and what to weigh before deciding.
Two families, one apartment in Athens, two outcomes
Two families each buy an apartment in Athens at the same price. The documents they sign are almost identical: a sale and purchase agreement, a title transfer, a title deed.
The first family owns the property. The second family, if the investment meets the program's requirements, also gains grounds to apply for residency for the whole family under the laws of the host country.
The difference lies in how the investment is made, not in the amount spent. Each country sets its own conditions, often very specific about property type, location, size, seller, and valuation method.
Some examples of these differences:
- Cyprus requires the property to be a new residence, purchased directly from a licensed developer.
- Türkiye does not accept property previously used for another citizenship application, and requires a valuation carried out under a process designated by the land registry authority.
- Grenada counts only projects on the government-approved list.
- Greece sets investment thresholds by region, along with minimum size requirements.
If the investment fails to meet any one of these conditions, the property is still a legitimate asset owned by the family. The difference is that it does not provide grounds to apply for residency or citizenship.
Why more families are considering this earlier
Two factors are unfolding at the same time, in opposite directions.
On the investor side, our advisory work shows more and more families raising this question earlier than they used to. This is an observation from our advisory practice, not a finding drawn from any statistical dataset.
One way to gauge how concentrated your family's assets are: if a single policy change or a single bout of currency volatility at home would be enough to significantly affect the whole family's financial plan, your assets may be heavily concentrated in one place.
On the host-country side, the number of programs is shrinking. Between 2022 and 2025, 7 residency or citizenship by investment programs in Europe closed entirely and no longer accept new applications under any route — the full list appears below. An eighth program, Portugal's, did not close but removed real estate from its eligible investment options. Each time a program closes, the options available to families who prepare later narrow a little further.
This has happened through successive rounds of policy changes rather than overnight. Countries typically announce changes and apply them to applications filed after the effective date.
So once your family has settled on its goals, it is essential to recheck the requirements in force while the application is being prepared.
Three questions to clarify before exploring programs
Where your assets are currently held
Moving part of your assets outside a single country, a single legal system, and a single currency is a portfolio-structuring decision. At a smaller scale, the question usually comes down to which asset class to choose. At a larger scale, where the assets are held — including which legal system governs them and which currency they are denominated in — becomes worth weighing as well.
This decision has both advantages and trade-offs, and we set out both in full.
On the plus side, those assets no longer share the same market cycle, legal system, and currency as the rest of your portfolio.
On the other side of the ledger, an overseas investment brings additional factors: currency movements that can cut both ways, the cost of managing assets remotely, and liquidity that is typically lower than that of a comparable asset at home.
Your legal status in that country
This is where the biggest difference lies.
If you own real estate without any accompanying legal status, you remain a foreign national in the eyes of that country's law. Your ownership is protected, but it confers no additional rights.
With residency rights, your relationship with the host country changes. Permit holders may live there and access healthcare and education as residents, subject to conditions that vary by country. Crucially for managing your assets, entering the country no longer depends on a separate visa decision each time.
One point is worth clarifying from the outset, as it is easily misunderstood. An investment-based residence permit is not the same as the right to work as an employee in the issuing country. The degree of restriction differs markedly between the 2 countries below.
In Greece, permit holders can be listed as shareholders, hold management positions in a company, and receive dividends; local salaried employment is subject to separate rules.
In Cyprus, the restriction is considerably tighter. Applications under Regulation 6(2) (the Cyprus regulation governing permanent residence for investors) require the main applicant and spouse to sign a declaration that they will not take up salaried employment in Cyprus. Permit holders may receive passive income and act as shareholders or directors within the limits the program allows. Families who intend to take salaried work in Cyprus should choose a different route.
The travel scope that comes with it
This is often seen as a secondary benefit. In practice, travel scope varies considerably between programs and affects both personal plans and asset management. The next section covers this in detail.
Scope of travel by document type
Travel privileges are the most visible part of a new residence permit or passport. What they amount to in practice depends on 2 factors: whether the issuing country is part of the Schengen Area, and whether the outcome is a residence permit or a passport. This section looks at each type in turn.
The table below summarizes the travel scope of each type of document, updated as of July 2026:
| What you receive | Where you can travel | How long you can stay |
|---|---|---|
| Greek residence permit | 29 Schengen countries | Greece: for the validity of the residence permit. In other Schengen countries: up to 90 days in any 180-day period |
| Malta permanent residence permit | 29 Schengen countries | Malta: for the validity of the card. In other Schengen countries: up to 90 days in any 180-day period |
| Cyprus permanent residence permit | Cyprus | Stay in Cyprus is governed by the terms of the permit. Travel to Schengen countries requires meeting separate entry rules |
| Grenada passport | 29 Schengen countries, the United Kingdom, China, Singapore, Hong Kong, and many other destinations | Length of stay depends on each country's rules |
| Turkish passport | Many countries outside Europe | Entry into the Schengen Area still requires meeting current visa rules |
The Schengen Area currently comprises 29 countries, following Bulgaria and Romania's full accession on January 1, 2025. Of these, 25 are European Union member states and 4 are non-EU countries: Iceland, Norway, Switzerland, and Liechtenstein. Holders of a residence permit issued by a Schengen country may travel throughout the area under Article 21 of the Convention Implementing the Schengen Agreement.
Since April 10, 2026, all Schengen border crossings have operated the Entry/Exit System (EES), the bloc's biometric entry and exit system. It records fingerprints and facial images and automatically tallies the days third-country nationals spend in the area, replacing passport stamps. The 90/180-day cap is therefore enforced more tightly than before. Under Article 6(2) of the Schengen Borders Code, time spent under a residence permit or long-stay visa does not count toward that cap — a key distinction between a residence permit and a multiple-entry tourist visa.
Three points are worth distinguishing clearly.
Travel rights differ from residence rights. A Greek residence permit allows short stays in France, but does not carry the right to work or settle in France. If your family plans to live long term in another Schengen country, you must still meet that country's own immigration rules.
Both are in Europe, but the scope of travel can differ widely. A Greek residence permit opens up the 29 Schengen countries. A Cyprus permanent residence permit currently applies only in Cyprus. Both countries are European Union members; the difference is that Cyprus is not yet part of the Schengen Area at the time of writing. This is worth clarifying from the earliest stage of research, especially for families who prioritize travel within the Schengen Area.
A passport and a residence permit offer different scopes. A Grenada passport allows entry to the Schengen Area, to the United Kingdom for stays of up to 6 months per visit, and to China, Singapore, and Hong Kong. Since January 2025, Grenadian citizens have needed an Electronic Travel Authorisation (ETA) before traveling to the United Kingdom. A Turkish passport, although it represents full citizenship, does not currently qualify for visa-free travel to the Schengen Area; Turkish citizens still apply for a European visa under current rules, and as of 2026 the visa liberalization process between Türkiye and the European Union has not been completed.
One procedural reform works in applicants' favor. Under European Commission Implementing Decision C(2025) 4694, signed on July 15, 2025, Turkish citizens are considered for Schengen visas on a cascading basis: those who have lawfully used 2 visas in the previous 3 years are considered for a 6-month multiple-entry visa, then successively for 1-year, 3-year, and 5-year visas if they continue to use them lawfully and reapply on time. This is a procedural reform of visa issuance, not visa-free travel.
The value of the Türkiye program lies in citizenship for the investor and eligible family members, and in the relatively short holding period for the investment.
On the E-2 nonimmigrant treaty investor visa to the United States through Grenada citizenship, 3 points need to be stated accurately. First, E-2 is not a pathway to U.S. immigration. Second, under Public Law 117-263, Section 5902(b), signed into law on December 23, 2022, a person who obtained treaty-country citizenship through investment must have been domiciled — that is, have their principal legal home — in that country for a continuous period of at least 3 years before becoming eligible to apply. Domicile is a concept of intent to remain and legal ties; it does not mean continuous physical presence. Third, visa issuance rests with the U.S. government and depends on the outcome of each individual case review. This should be assessed case by case by a U.S. immigration attorney.
A practical approach: before comparing programs on travel criteria, list the countries your family expects to visit over the next 5 years, then check each program against that list. The total number of visa-free destinations a passport offers often does not fully reflect the actual needs of a specific family.
Situations where travel rights prove their value
Travel rights are often understood as a matter of procedural convenience. The 6 situations below show that their value also lies in being able to respond when plans change.
Your child's graduation. Graduation schedules may be confirmed at short notice or change from the original plan. With the right documents already in hand, your family can arrange the trip around the school's schedule.
Family emergencies. Situations such as a relative needing medical care, or needing to be there in person to complete a formality, often cannot be planned weeks in advance.
Last-minute trips. Not every trip is planned months ahead. Having your documents in place gives you more flexibility about when to leave.
Medical treatment. Your family can schedule examinations or treatment around the provider's calendar, rather than depending on visa processing times.
Signing and completing formalities in the host country. A real estate transaction abroad does not end with payment. Depending on the country, the process may include registering the title transfer at the land registry, opening a local bank account, and obtaining a tax identification number. Many banks' know-your-customer (KYC) procedures still require the account holder to appear in person at least once.
Where the investor cannot be present, these steps are usually handled through a power of attorney. Depending on where it is executed, the document may require consular legalization or, between countries that are both parties to the Hague Apostille Convention, an apostille. One condition should be noted: under Article 12 of the Convention, existing member states may object to a new member's accession within 6 months of receiving notification; between the acceding country and an objecting country, consular legalization still applies as before. Check the list of countries where the apostille applies at hcch.net before preparing documents. A power of attorney is valid only within the scope stated in the document; matters arising outside that scope require a new document.
Asset transactions. When you need to be present to review, sign, or complete a transaction, being able to travel on your own schedule lets your family work around the actual timeline.
Between purchase and sale lies a much longer phase: the holding period. A rental property may give rise to disputes with tenants, major repairs, or changes in local rules on rental conditions. This is where a residence permit stands apart from a short-stay visa: not just in the ability to enter, but in being able to enter when needed and stay long enough to get the job done.
When to start exploring
The 4 questions below help you assess whether now is the right time for you.
- Are your family's assets currently concentrated mainly in one country and one currency?
- Over the next 5–10 years, does your family plan to study, do business, seek medical care, retire, or spend extended time abroad?
- Does your family need to travel frequently to a particular country or region?
- Is your family prepared to keep the investment in place for the period the program requires?
| Answer | Next step |
|---|---|
| 3 or more “yes” answers | This is a good time to start exploring programs. First, determine whether your main goal is permanent residence or citizenship, then compare the corresponding options. |
| 1–2 “yes” answers | The need may already be taking shape, but more information is needed to identify the right option. A comparison of programs — requirements, holding period, scope of travel — will be useful at this stage. |
| No “yes” answers yet | If you have no need yet, you can keep track of policy changes for future reference. |
The result above is for reference only, to help you gauge how relevant it is to explore these programs at this time.
In our advisory practice, we commonly see the 6 objectives below, and a single family's case often involves 2 or 3 of them at once:
- Diversifying where assets are held. Moving part of a portfolio outside a single country, a single legal system, and a single currency. This objective is about asset structure and is not necessarily tied to a plan to relocate.
- Preparing for the next generation's education plans. Residence status in a country can change the conditions for accessing that country's education system. Specific conditions vary by country and by level of study, and should be checked for each case.
- Expanding options for where to live and work. Having legal status abroad can shorten preparation time if your family later decides to move.
- Reducing dependence on a single system. Holding assets and legal status in more than one place reduces the impact of a single policy change on your family's entire financial plan.
- Greater convenience in travel. For frequent travelers, the visa-free access that comes with a new legal status can make a significant difference to the time and cost of preparing each trip.
- Long-term planning for the family. Real estate is an asset that can be passed down through generations. In some programs, the legal status tied to the asset also extends to eligible dependents included in the same application.
One point is worth clarifying early: most programs covered in this article do not require investors to relocate immediately after approval. Greece sets no minimum stay requirement, Malta does not require residence, Türkiye requires no residence either before or after naturalization, and Cyprus requires entry at least once every 2 years. This is preparation in advance, not relocation.
Two cases deserve separate attention. The E-2 visa route to the United States through Grenada citizenship requires domicile in Grenada for a continuous period of at least 3 years. And as set out below, if your family plans to naturalize in a European country later, physical residence requirements still apply.
Why real estate is so often the preferred route
Holding deposits or securities abroad diversifies your assets but confers no legal status. Applying for visa after visa meets travel needs but builds no asset.
It is also worth comparing the other investment routes within the same programs. Many countries grant residence status through approved investment funds, government bonds, or setting up a business. These routes lead to a residence permit as well. The difference lies in the form the capital takes: on the financial routes, it sits in fund units or bonds; on the real estate route, it sits in an asset the family can use, rent out, and pass down through the generations.
The host country's law attaches a legal status to a specific type of asset, within a specific scope. Outside that scope, the investment remains a legitimate property holding; it simply provides no basis for an application.
The other side of the picture should also be set out in full. Property bought under a program carries restrictions that ordinary property does not. In Greece, Golden Visa property may not be let on a short-term, home-sharing basis; only long-term leases are permitted. A breach leads to revocation of the residence permit and an administrative fine of €50,000 per property. This restriction applies to property purchased under the criteria of Law 5100/2024; property purchased before the law took effect is subject to different rules, so each case must be checked against its purchase date. In Türkiye, the title deed is annotated with a 3-year transfer restriction. These are the conditions that allow the investment to serve as the basis for an application.
One point worth noting: 2 properties with the same price in Greece can still produce 2 different outcomes if one of them is located in an area subject to a higher investment threshold. Choosing the right property matters as much as determining the right investment amount.
Distinguishing residence rights, permanent residence, and citizenship
This is often not fully understood, and clarifying it early helps a family identify the right group of programs to explore.
Some investors assume that holding a residence permit for enough years will eventually lead to citizenship. In practice, the 2 are governed by separate sets of rules. A family that holds a residence permit for many years without actually living in the country will find that, when it comes to meeting naturalization requirements, it is essentially starting from zero.
The key distinction lies in how time is counted. An investment-based residence permit is a legal residence status. What does not count toward a naturalization application is time not actually spent residing in the country. Because the program sets no minimum stay requirement, a permit holder can maintain status for years while rarely being present in the issuing country, and that period does not count. Whether time spent holding an investment-based residence permit counts varies by country and must be checked individually. Beyond residence requirements, naturalization applications in European countries also involve language proficiency and other integration requirements.
From there, the right group of programs becomes clear. If the goal is citizenship within a defined timeframe, the group to explore is citizenship-by-investment programs — Grenada and Türkiye, covered below. If the goal is residence rights and property in Europe, the European programs are a better fit, with the caveat that residence rights do not automatically lead to citizenship.
| Points to distinguish | Actual rules |
|---|---|
| Time holding a permit vs. naturalization requirements | Naturalization requirements are based on actual residence, not on how long the permit has been held |
| Scope of a residence permit issued by a Schengen country | The permit grants residence in the issuing country; in other Schengen countries, it allows short stays only |
| Right to work in the issuing country | An investment-based residence permit does not equate to the right to work as an employee. Cyprus is stricter than Greece: the main applicant and spouse must commit not to engage in paid employment |
| Use of program property | Some programs set their own limits, such as the rules on short-term rentals in Greece |
| Transferring the asset and the effect on status | In residence programs, maintaining the investment is a condition for keeping status; in citizenship programs, citizenship already granted does not depend on continued ownership after the commitment period |
Policy context, 2022–2025
The list of available programs is narrower than it was 5 years ago, especially for real-estate-linked routes. The contraction has occurred in both groups: citizenship and residence.
Citizenship-by-investment programs within the European Union. Cyprus ended its citizenship-by-investment program on November 1, 2020. On December 4, 2025, the Cyprus Parliament repealed the provision allowing the Council of Ministers to grant citizenship by exception. As for Malta, on April 29, 2025, the Court of Justice of the European Union ruled in Case C-181/23 that the country's citizenship-by-investment program was incompatible with European Union law; Malta enacted Act XXI of 2025, published in the Official Gazette on July 24, 2025, abolishing that program framework. The Cyprus milestone falls outside the 2022–2025 window covered below, because the country's citizenship program ended in 2020.
Residence programs. The United Kingdom closed the Tier 1 (Investor) route at 16:00 on February 17, 2022. Ireland closed the Immigrant Investor Programme on February 15, 2023. The Netherlands abolished its program for foreign investors, effective April 17, 2024. Spain abolished its investor residence route under Organic Law 1/2025, no longer accepting new applications from April 3, 2025.
Citizenship programs outside the European Union. Bulgaria abolished its citizenship-by-investment route, with the law published in the Official Gazette on April 1, 2022. Montenegro ended its citizenship-by-investment program on December 31, 2022.
In total, 7 programs closed permanently in the 4 years from 2022 to 2025:
- United Kingdom — Tier 1 (Investor), February 17, 2022
- Bulgaria — citizenship by investment, gazetted April 1, 2022
- Montenegro — citizenship by investment, December 31, 2022
- Ireland — Immigrant Investor Programme, February 15, 2023
- Netherlands — foreign investor route, April 17, 2024
- Spain — Golden Visa, April 3, 2025
- Malta — citizenship by investment, gazetted July 24, 2025
Portugal is a separate case: narrowed, not closed. Law 56/2023, effective October 7, 2023, removed real estate from the list of eligible investments. Fund investment, job creation, scientific research, and cultural project routes still accept new applications. For families whose goal is real estate, Portugal is closed; for families willing to accept a financial route, it remains an option.
The list above does not include Cyprus, because the country's citizenship program ended in 2020. Nor is this a complete list for all of Europe.
Every program still in force has been through at least one round of adjustment. Greece raised its investment thresholds under Law 5100/2024 but kept the program running, while retaining a lower-threshold route for heritage buildings and change-of-use property, regardless of location. Cyprus maintains its permanent residence program. Malta maintains its permanent residence program and consolidated its fee structure under Legal Notice 146 of 2025. In the Caribbean, 5 countries of the Organisation of Eastern Caribbean States agreed on a common minimum investment threshold effective July 1, 2024.
It is worth being clear-eyed about one point: no group of programs is immune to policy change, including those tied to real assets. Spain, and Portugal's real estate route, are cases in point. So rather than asking which program is the most stable, a more practical question is this: if the program changes, in what form would the family's capital remain? This is why we favor routes where the main capital sits in an asset held in the investor's name. When policy changes, ownership of the asset stays with the family, and the asset's value continues to move with the market.
Programs IMM Group currently advises on
The programs below are still in force, have clear legal outcomes, and each has a route tied to a real asset held in the investor's name. Malta and Grenada also offer routes that do not create an asset — the lease option and the contribution route, respectively — covered in their own sections.
Every program involves background vetting and checks on the source of wealth. Whether residence rights or citizenship are granted depends on each program's requirements, the outcome of the eligibility assessment, and the decision of the competent authority. Processing times can vary between countries and from case to case. Investment amounts, fees, and application requirements are adjusted from time to time, so they should be discussed directly, with an updated comparison at the time you get in touch.
Indicative capital ranges for the 5 programs
The table below sets out the minimum investment for an application to qualify. This is the investment capital only; it does not include background vetting fees, government fees, legal costs, or notarization costs — the total actual cost of an application is higher than this figure.
| Program | Minimum investment (as of July 2026) | Source |
|---|---|---|
| Greece | €800,000 across the entire Attica region, the Thessaloniki regional unit, Mykonos, Santorini, and islands with more than 3,100 residents; €400,000 in the rest of the country. The property must be at least 120 m² and the investment must be concentrated in a single property. The heritage building or change-of-use route: €250,000, available nationwide with no geographic restriction. | Article 64 of Law 5100/2024; stegasi.gov.gr |
| Cyprus | €300,000 plus VAT, for new housing purchased directly from a licensed developer. This route also requires proof of annual income from foreign sources: €50,000 for the main applicant, plus €15,000 for a spouse, plus €10,000 for each dependent child. | Regulation 6(2), Cyprus Ministry of Interior — mip.gov.cy |
| Malta | Purchase property from €375,000 or lease from €14,000 per year. Plus a €60,000 administrative fee, €7,500 per dependent, a €37,000 government contribution that applies to both the purchase and lease options, and a €2,000 charitable donation. A minimum net worth of €500,000 is required, of which at least €150,000 must be liquid financial assets. | Legal Notice 146 of 2025 — residencymalta.gov.mt |
| Grenada | A National Transformation Fund (NTF) contribution from US$235,000, or investment in a government-approved project from US$270,000 plus administrative fees. The common minimum investment floor set by the Organisation of Eastern Caribbean States is US$200,000, effective July 1, 2024. | cbi.gov.gd; pressroom.oecs.int |
| Türkiye | US$400,000 or the equivalent value, as determined by a valuation process designated by the competent authority, with a 3-year transfer restriction annotated on the title deed. | invest.gov.tr |
Figures are current as of July 2026. Investment amounts and fees are adjusted periodically; please ask for the latest figures when you contact us.
Residence programs in Europe
Greece — a Schengen member with no minimum stay requirement
Greece issues a residence permit to investors, renewable as long as the investment is maintained, with no minimum stay requirement. The property is held in the investor's name. Investment thresholds vary by area: €800,000 across the entire Attica region, the Thessaloniki regional unit, Mykonos, Santorini, and islands with more than 3,100 residents; €400,000 in the rest of the country. The property must be at least 120 m², and the investment must be concentrated in a single property rather than split across several.
There is also a separate route at €250,000 for heritage buildings and properties converted to residential use, available nationwide with no geographic restriction. This route is less often recommended because it comes with construction obligations and a hard deadline — and, for the same reason, it faces less competition. For change-of-use properties, the conversion must be completed before filing the residence permit application. For heritage buildings, the owner may not sell the property until restoration is complete. The actual total cost is therefore higher than the nominal investment amount, and construction costs should be budgeted from the outset.
Greece is part of the Schengen Area, so the residence permit allows short stays in other Schengen countries, for up to 90 days in any 180-day period.
May suit: families who want to own property in Europe, need to travel within the Schengen Area, and have no immediate plans to relocate.
Worth weighing if: the family intends to work as employees in Greece; plans to operate the property as a short-term rental; or expects a fixed timeline for recovering capital, since the investment must be maintained for as long as the residence permit is held.
Cyprus — indefinite permanent residence in the European Union, and a development still unfolding
Cyprus issues a permanent residence permit with no expiry date under Regulation 6(2) (the regulation governing permanent residence for investors in Cyprus). On the residential property route, the minimum investment is €300,000 plus VAT, for new housing purchased directly from a developer. The application includes proof of annual income from foreign sources, scaled to the number of family members, along with an obligation to submit periodic evidence that the investment is maintained. The property is held in the investor's name. Presence requirements are minimal: at least one entry into Cyprus every 2 years. The program requires the main applicant and spouse to sign a declaration that they will not take up salaried employment in Cyprus.
On travel access, Cyprus is a European Union member but not yet part of the Schengen Area as of this writing. A Cyprus permanent residence permit therefore does not yet carry short-stay rights within the Schengen Area.
Cyprus's Schengen bid has passed the European Commission's technical evaluation and is now at the stage of awaiting a political decision. The European Commission adopted its report on Cyprus's readiness in July 2026 and is expected to refer it to the Council of the European Union in September 2026. The decision on accession rests with the Council and requires unanimity among the states that fully apply Schengen within the Council. No date has been set. The Council's decision and the lifting of internal border controls are 2 separate milestones.
If this process is completed, Cyprus permanent residence permits would in principle fall under the common Schengen framework. Whether permits already in circulation would be recognized directly or would need to be reissued, and the effective date, would be determined by Cyprus and the Council at that time. This is a development still unfolding, not a settled outcome, and it should be treated as a reference point rather than the main basis for a decision.
May suit: families who prioritize property ownership and permanent residence status in a European Union member state, and who accept the obligation to enter Cyprus once every 2 years.
Worth weighing if: travel within the Schengen Area is the top priority at this time.
Malta — a program that allows leasing alongside the purchase option
Malta grants permanent residence under the Malta Permanent Residence Programme (MPRP). Investors choose between purchasing property from €375,000 or leasing from €14,000 per year, maintained for at least 5 years, together with the mandatory fees and contributions set out in Legal Notice 146 of 2025, and must demonstrate a minimum net worth of €500,000, of which at least €150,000 must be in liquid financial assets. The program has no residency requirement. Malta is part of the Schengen Area.
If the lease option is chosen, that outlay is an expense and does not build an asset. In return, the total capital required is significantly lower than under the purchase option.
May suit: families who want permanent residence status in a Schengen country with a lower total capital outlay, and who accept that the property outlay may be an expense rather than an asset.
Worth weighing if: the main goal is to diversify assets internationally in that case, only the purchase option meets the objective.
Second citizenship programs
Grenada — the broadest travel access in this group
Grenada grants citizenship to the applicant and eligible dependents in a single application. Grenada's definition of dependents is broader than Türkiye's, covering eligible parents and grandparents. The program has 2 routes that differ in nature: investment in a government-approved real estate project from US$270,000 plus administrative fees, or a contribution to the National Transformation Fund (NTF) from US$235,000. The contribution is non-refundable and does not build an asset — but it remains a reasonable choice for families whose goal is citizenship and for whom preserving the capital is not a priority.
A Grenada passport allows entry to the 29 Schengen countries; to the United Kingdom for stays of up to 6 months per visit, with an Electronic Travel Authorisation (ETA) required before the flight; and to China, Singapore, and Hong Kong. Grenada also has a bilateral investment treaty with the United States, which provides the basis for E-2 visa eligibility, subject to the 3 points discussed above.
The most recent precedent is Vanuatu: on November 8, 2022, the Council of the European Union decided to suspend in full its visa waiver agreement with that country, ending visa-free travel for Vanuatu nationals with effect from February 4, 2023, citing risks from its citizenship-by-investment program. This does not mean Grenada will follow the same path, but it shows that the June 1, 2028 date is a real milestone, not a formality. For families considering the Grenada route, this is a reason to build filing timing into the plan rather than leave it open.
May suit: families whose goal is a second citizenship and who need travel access to multiple regions, including Europe, the United Kingdom, and China.
Worth weighing if: the main goal is access to the United States. E-2 is a nonimmigrant visa and requires at least 3 years of continuous domicile in Grenada a legal-ties requirement that families should have a U.S. immigration attorney assess separately before building it into their plans.
Türkiye — the shortest investment holding period in this group
Türkiye requires a minimum investment of US$400,000 in real estate. The program grants citizenship to the applicant, spouse, and minor children. Children aged 18 and over may only be included if there is medical confirmation of an inability to support themselves; there is no extended dependent category based on financial dependence. A child who turns 18 while the application is being processed is assessed by their age on the filing date. The applicant's parents are not eligible to join under this route — unlike Grenada, where eligible parents and grandparents may participate.
The property value must be determined through a valuation process designated by the land registry authority. Investors commit to holding the asset for 3 years, with a transfer restriction annotated directly on the title deed. This is the shortest holding period among the programs covered in this article. The program has no residency requirement, either before or after naturalization.
On travel access, a Turkish passport does not currently have visa-free access to Schengen, so the program's strength lies outside Europe.
May suit: families who want citizenship through real estate investment with a relatively short holding period, and whose capital remains in an asset that can be transferred after 3 years.
Worth weighing if: travel within the Schengen Area is the top priority, or the application includes an adult child who does not qualify as a dependent.
Investment holding period — comparison table
This is where the programs differ most clearly, and it is also the point that tends to come into focus at a later stage.
| Program | Investment holding period | After the commitment period |
|---|---|---|
| Türkiye | 3 years | May be transferred; citizenship already granted is unaffected |
| Grenada — approved project route | 5 years | The 5-year requirement relates to resale to another program investor, so that the property remains eligible. Citizenship already granted is unaffected by the transfer. Specific conditions are set by each approved project and should be checked against the project contract |
| Grenada — contribution route | Not applicable | Funds paid are a cost and are non-refundable |
| Malta — purchase option | 5 years | Before transferring, check the conditions for maintaining status that applied at the time of application |
| Malta — lease option | For as long as status is held | The outlay is a cost and does not create an asset |
| Greece | For as long as the residence permit is held | The investment must be maintained continuously; a transfer affects the status of the permit |
| Cyprus | For as long as status is held | Similar to Greece, with a periodic obligation to submit evidence that the investment is maintained |
A point worth noting: citizenship programs have a clear end point, while residence programs are tied to maintaining the investment for as long as status is held. For families focused on when capital can be recovered, this is a useful way to compare programs alongside the initial investment amount.
The table above covers the investment holding period and does not reflect investment performance. The transfer price depends on the market at the time of the transaction and is affected by local liquidity and exchange rates.
How IMM Group supports each application
Step one: assess the family's objectives and current position. Where the family's assets are held and in which currency they are valued; what legal status the family already holds beyond their original citizenship; and what travel access they currently have. These 3 points often reveal that the family's actual needs differ from what they first had in mind.
Step two: define the legal objective. Residence or citizenship. This is the decision that narrows the list of options the most and, as discussed above, the 2 objectives do not automatically convert into one another.
Step three: choose the program that fits the first 2 steps, and only then consider the investment amount, application requirements, timeline, and costs.
For families that have worked through these 3 steps, the next conversation usually focuses on 2 or 3 programs rather than the entire list.
Conclusion
When a family's assets and plans span several countries, choosing where to hold those assets becomes a decision that needs a clear assessment framework: define the family's objectives first, then compare them against each program.
This approach may suit families whose assets are concentrated mainly in one country and one currency; who have long-term plans that extend beyond their current borders; who see international travel as part of the whole family's plans; and who accept the investment holding period each program requires.
Consider other options if you prioritize steady returns or regular income from the investment; plan to work or run a business directly abroad right after obtaining residence; need full rights to live and work in a specific country from the outset; or need high liquidity for your capital. In these cases, long-term residence routes or skilled migration routes for a given country may be a better fit.
On timing, processing can take from a few months to more than a year, and the investment holding period is measured in years. Preparing early gives the family more options when needs arise.
Finally, foreign real estate is not the objective of this strategy. It is the form that allows the capital to be held as an asset the family can use, even if the issuing country changes its policies. Its value depends on whether the family's objectives were clearly defined before the asset was chosen.
The most immediate next step is to answer the 4 questions above, then have an IMM Group advisor compare your answers against each program.
Frequently asked questions
1. How does investing in foreign real estate under a program differ from simply buying property abroad?
An ordinary property purchase is a transaction that is complete once title is transferred. With a program-based investment, the same property can also serve as the basis for the family to apply for residence or citizenship, depending on the program. What is assessed is the type of property, the seller, the location, and how value is determined — not just the amount of capital. If the investment fails to meet one of the conditions, the property remains lawfully owned by the family but does not come with a basis for applying.
2. How many countries can you travel to with a Greece Golden Visa residence permit?
A Greek residence permit allows travel within the 29 countries of the Schengen Area. In Greece, you may stay for the validity of the permit. Across the other Schengen countries, stays are limited to a maximum of 90 days in any 180-day period. This is a short-stay right and does not include the right to work or settle in another country. If the family plans to live long term in France or Germany, they must still meet that country's own immigration rules. The Malta permanent residence permit offers a similar scope because Malta is in the Schengen Area. The Cyprus permanent residence permit currently applies within Cyprus.
3. Does an investment-based residence permit allow you to work in that country?
An investment-based residence permit does not equate to the right to work as an employee in the issuing country, and the 2 countries impose different restrictions. In Greece, permit holders may be registered shareholders, hold management positions in a company, and receive dividends; salaried employment is subject to separate rules. In Cyprus, the Regulation 6(2) route requires the main applicant and spouse to submit a declaration that they will not take salaried employment in Cyprus; permit holders may earn passive income and act as shareholders or directors within the limits the program allows. Families intending to take salaried employment in Cyprus should choose a different route.
4. When should a family start looking into these programs?
Four questions can help you assess your situation: are the family's assets concentrated mainly in one country and one currency; over the next 5–10 years, does the family plan to study, do business, seek medical treatment, or retire abroad; does the family need to travel frequently to a particular region; and is the family prepared to maintain the investment for the period the program requires? With 3 or more “yes” answers, this is a good time to decide whether the objective is residence or citizenship. With 1 or 2 “yes” answers, a side-by-side comparison of the programs can give you a firmer basis for deciding.
5. Do you have to relocate abroad?
Most of the programs covered in this article do not require you to relocate immediately after approval. Greece sets no minimum stay requirement, Malta does not require residence, Türkiye requires no residence either before or after naturalization, and Cyprus requires a visit at least once every 2 years. Two cases need separate attention: the E-2 visa route to the United States through Grenada citizenship requires at least 3 years of continuous domicile in Grenada; and if the family later plans to naturalize in the country that issued the permit, physical residence requirements still apply. Each program's maintenance requirements should be re-verified at the time of application.
6. Does holding a residence permit for enough years qualify you for citizenship?
Residence and citizenship are 2 separate legal statuses, governed by 2 different sets of rules. Most residence-by-investment programs do not impose a physical residence obligation, while ordinary naturalization applications require many years of physical residence along with language and integration requirements. What counts is time physically resident in the country, not time holding the permit, and whether time spent holding an investment-based permit counts at all varies by country. If the objective is citizenship within a defined timeframe, direct citizenship programs are a better fit.
7. How do Grenadian and Turkish passports compare in travel access?
The Grenadian passport allows entry to the 29 Schengen countries for stays of up to 90 days in any 180-day period, and to the United Kingdom for up to 6 months per entry — since January 2025, an ETA (Electronic Travel Authorisation) is required before the flight — as well as China, Singapore, and Hong Kong. The Turkish passport does not currently offer visa-free access to the Schengen Area; Turkish citizens still apply for European visas under current rules, and the EU–Türkiye visa liberalization process had not been completed as of 2026. The strength of the Türkiye program lies in granting citizenship to the applicant's immediate family and its relatively short investment holding period. Visa-free lists and electronic travel authorization requirements can change over time, so check again before each trip.
8. How long must the investment be held, and can it be transferred afterward?
This differs between the 2 groups of programs. In the citizenship group, the commitment period has a clear end date: 3 years for Türkiye and 5 years for the Grenada real estate route; after this period, transferring the investment does not affect citizenship already granted. In the residence group, specifically Greece and Cyprus, the investment must be maintained for as long as the family holds that status; transferring it affects the family's residence status. Malta requires a minimum holding period of 5 years, and the conditions for maintaining status should be verified at the time of application. In all cases, the transfer price depends on market conditions at the time of the transaction. Some programs also set conditions on who may acquire the investment.
