At the 2026 US Expats Financial Conference, Adalberto Pucca and Joe Rice of Global Citizen Solutions joined host Hugo Lesser to discuss visa types and Plan B strategies for Americans moving abroad. Adalberto covered citizenship by descent and the golden visa options in Portugal, Malta, Greece and Italy, and Joe covered citizenship by investment in the Caribbean and beyond, followed by an audience Q&A on tax regimes, US passports and family applications.
The following transcript was generated by AI and may contain inaccuracies.
Hugo: Welcome everyone. We’ll just wait two or three minutes and give everyone a chance to join. This is our last session of this year’s conference, and we’ve saved some of the best till last to talk about residency and Plan B. I’m here with Joe and Adalberto from Global Citizen Solutions, also one of our event sponsors.
Great to see you both, and we’re excited to hear your presentation. We were just talking before — you’re both in or around Lisbon. Is that right?
Joe: I’m based in Lisbon, yes. I’ve been in Lisbon for about four and a half years now. But Pucca isn’t. Pucca’s across the pond.
Hugo: Oh, right.
Adalberto: Most of the time I’m in the UK, although I’m actually in our Lisbon office today. So yes, enjoying the sunshine we’ve had here after a few weeks of rain.
Hugo: Rain in the UK or rain in Portugal?
Adalberto: Rain in Portugal.
Joe: And the UK. He brought it with him.
Hugo: I think the rain in the UK is pretty typical, but I heard there’d been some torrential rain in Portugal and really unusual weather recently.
Adalberto: Correct. In the UK, we expect it. Here it was a bit of a surprise.
Joe: But it’s gone now. It’s not coming back. It’s very rare that it happens here. It rains occasionally, but generally year round it’s great.
Hugo: That’s what we say about the sunshine here. It’s gone and it’s unlikely to come back.
Joe: Well, we theoretically get 300 days of sunshine a year here in Portugal.
Hugo: That doesn’t sound bad. Of course, that’s why a lot of people want to move there.
Joe: Exactly. One of the reasons.
Hugo: Among many others. Are you both US citizens as well?
Joe: Just me. I’m a British citizen and an American citizen.
Hugo: And how many offices do you have? As you were saying, the HQ is in Lisbon at Global Citizen Solutions. Is there an office in London as well, then?
Adalberto: We’re technically headquartered in London, but we’ve got offices globally. Our largest is actually in Lisbon, but we have offices in Spain, Greece, Malta, Antigua and Barbuda. So quite a few offices globally — Switzerland now, we opened our Swiss office at the end of last year. And a few new locations are coming up as well.
Hugo: Interesting. And in the US, to cater for people planning a move, or no plans in that direction?
Adalberto: There are plans, although we work primarily with the US market into other global areas.
Hugo: I think the number of people joining is steadying, so let’s begin. I’ll read a little introduction, and then we’ll dive in.
Hello, and welcome to day four of the 2026 US Expats Financial Conference, sponsored by Expat Focus, Wise, Global Citizen Solutions, and Advanced AI Services. We have a fantastic schedule for you consisting of 17 sessions over four days, covering multiple aspects of financial information for Americans living abroad, with perspectives from some of the world’s leading experts in their fields.
Today is the fourth and final day of the conference, and this is our final session of the day. I’m delighted to be joined by Adalberto Pucca and Joe Rice, who will be discussing visa types and Plan B strategies for Americans moving abroad. Adalberto leads sales and business development, and Joe is head of citizenship programs at Global Citizen Solutions.
Global Citizen Solutions provides second citizenship, residency, and relocation strategies for those planning beyond borders. You can find out more at globalcitizensolutions.com. Before we start, please bear in mind that the information presented is for general educational purposes only, and you should always seek your own personalized advice.
Joe and Adalberto will be answering your questions at the end, after their presentation. So please add your questions in the Q&A pop-up at the foot of your screen as and when you think of them. We’ll try to answer them all, time permitting. So without further ado, over to you.
Adalberto: Thank you very much, Hugo. I’ll share a brief presentation about the topic today. We’re discussing Plan B strategies, specifically for Americans moving abroad — the various visa types, and the strategies our clients have been adopting over the last several months in order to give themselves certain advantages globally.
Firstly, I think it’s important to discuss what a Plan B is. Often the words “Plan B” are thrown out there and there’s a very shallow understanding of what it can offer. It’s not just having another citizenship or another residency. It encompasses a much wider definition.
Yes, it’s about having a contingency strategy — and a well-thought-out one at that. Although there is residency and citizenship planning involved, it can go a little beyond that. Our clients often like to look at it as an insurance policy against what can happen globally. Over the last several years, we’ve seen many events in which people felt comfort in having a second residency or a second citizenship, something they could rely on in the event something were to happen.
But in recent times, our clients are looking at these programs a little differently. It’s become more about succession planning. If they have younger kids, if their children are soon going to university, they want to make sure their children are taken care of. So we look at these programs as a way of long-term security, and also of making sure the wealth our clients have amassed throughout their lives isn’t impacted by global events.
In the same way that in investing most people don’t like to put all their eggs in the same basket, they’re looking at it more broadly now in terms of countries as well — various jurisdictions, in order to provide some more security.
Very briefly: Hugo very kindly gave a little explanation about GCS. We are exactly that — a global mobility consultancy firm. We offer the type of planning we’re going to be discussing today, and the goal really is for our clients to become global citizens, to have a plan of action, and to go to bed and put their heads on their pillows at night feeling secure and safe. That if something were to happen, or if in the future they plan to make a move, they’re able to do so very smoothly.
We touched briefly on the benefits during the definition of a Plan B, but I’ve listed here just some key items our clients often look for. They reach out to us and they say, “How can I enhance my mobility? How can I increase quality of life?” and so on and so forth. These are the reasons why people look for the services that we offer, and it’s why it’s become a key element in obtaining a Plan B. It goes much further than just one or two items.
I wanted to also discuss a few different ways in which Plan Bs can operate. I’ll focus primarily on the residency planning items, and then Joe will come and discuss the citizenship options, particularly the faster citizenship options that are available globally.
But I wanted to start by looking at an area that’s often bypassed when considering these plans, which is citizenship by descent. Whenever a client reaches out to us and we’re doing a more comprehensive consultancy offering, a more comprehensive solution, this is the very first step we take, the first thing we look into.
Citizenship by descent — a lot of us will have it. I, for example, had that through Italian heritage, and I was able to apply for my Italian citizenship by descent. Many of our clients, especially in the US, which has seen many diasporas over the last 150 to 200 years, have family from Italy, from Germany, from Portugal and so on, and are then able to acquire citizenship, provided naturally that they meet the criteria, as it does differ from country to country. This can offer a faster path to citizenship in comparison to the alternatives.
Now, if this option is not available — and often our clients that do citizenship by descent would do that alongside additional programs — we look at residency planning as well. Residency planning, much like the citizenship planning Joe will be discussing later, is a very important element today.
Residency planning, when we talk about Plan B, focuses primarily on golden visas. Golden visas are by definition residency by investment programs. These programs exist in several countries. We’re going to look at a few of them, but in all areas of the globe we have programs that we’re able to offer, from Europe to Latin America, the Middle East, Africa, and all the way to Oceania and Micronesia.
Although we’re going to focus on golden visas and look at these Plan Bs, which are often much more flexible than the alternatives, I also want to discuss passive income visas, digital nomad visas and other alternatives. Although they’re not as flexible, they do offer a fast track to residency, while requiring the individual to reside in those countries.
Portugal
I wanted to discuss Portugal. As you may have heard, we are in Portugal at the moment. Portugal has been a very popular program with our clients, and the main reason for that is that Portugal offers, when it comes to Plan Bs, one of the best golden visas available.
You will have heard that some changes are coming in regards to citizenship, and I’ll discuss that shortly. But as it stands, Portugal has one of only two residency by investment programs that will lead to citizenship flexibly, meaning you do not necessarily need to reside in Portugal in order to become a citizen.
The golden visa in Portugal no longer has an investment in real estate. It hasn’t had one for almost three years now. Investments are focusing primarily on private equity and venture capital funds, but also on donations to cultural and artistic endeavors. Clients often look at it beyond just the golden visa when it comes to the investment, particularly on the funds, because it can offer a good way to diversify their investment into a strong market and a strong currency.
As mentioned, it’s quite flexible, so it only requires an average of seven days per year in order to maintain it. It’s a residency card that’s valid for two years and renewable as many times as necessary, in perpetuity, if the applicant doesn’t wish to obtain citizenship or permanent residency at the applicable stage.
Now, the path to citizenship in Portugal, as I alluded to earlier, is going through a bit of a change. The current legislation permits applications for citizenship after holding a golden visa for a minimum period of five years. There is legislation that’s going to pass very soon that will increase that to ten years. That’s for nationals of countries that do not speak Portuguese or have Portuguese as an official language. The alternative would be seven years.
In any case, the question becomes: does Portugal still remain an attractive option even if it does become ten years? My response is yes. The reason why comes back to that flexibility, because every other golden visa, as you will learn right now in this presentation, requires the individual to reside in the country in order to become a citizen. So these are the reasons why we look at Portugal for the golden visa.
As mentioned, I wanted to look at some alternative visa options. In Portugal, for example, we have the D7 visa, which is a visa for passive income earners. These are very different from the golden visa in the sense that they do not have that same level of flexibility. The holder of a D7 visa is required to live in Portugal in order to maintain it, in order to renew it, and to have a path to citizenship.
Similarly, we have the D8 visa, which is also known as the digital nomad visa, and the D2 visa, which is designed for entrepreneurs who would like to start a business in Portugal and essentially obtain residency and operate that business locally.
Any questions, by the way, feel free to drop them in the Q&A, and we’ll be happy to address them at the end of the presentation.
Malta
Next to Portugal, we have Malta. Malta is a very well-known country in this industry, albeit a very small island down in the Mediterranean. There are two programs in particular I wanted to touch on today.
First, the Malta Permanent Residency Programme, or the MPRP, as we often call it, as it provides permanent residency for life. There are criteria that must be met, but what is interesting about this program is just that — although there are renewals of the residency card, you do hold a permanent residency status for life.
You have a few different options when it comes to this program. You can either purchase real estate in the amount of €350,000, or you can just lease a property in Malta for €14,000 per year for a minimum period of five years. There are government application fees and contributions, which total €97,000. The breakdown is €37,000 as a contribution and €60,000 in admin fees, as well as a charitable donation of €2,000.
Similar to the golden visa in Portugal, it is extremely flexible. As a matter of fact, unlike the Portugal golden visa, which requires a minimum stay of seven days per year, the Malta program doesn’t require any stay at all. There is no minimum stay requirement after you have obtained the residency card.
Very briefly as well, I wanted to discuss a new program that has been made available, which is Malta Citizenship by Merit. This is designed specifically for individuals who have made exceptional services either to Malta or to humanity. Anyone who has been quite successful in their career and is able to contribute to the country can consider this program as well.
Greece
Next we have Greece. I put Greece here particularly because we have a lot of clients who would like to invest in real estate in a country that is quite well known. So the Greece golden visa serves that section of our clientele.
Investments still start at €250,000, although these must meet some requirements, namely to have been converted from a commercial to a residential property. Alternatively, the investment increases to €800,000 if it’s in Athens or the Greek islands, or €400,000 in other areas of mainland Greece. Clients are also looking at new investments in Greece, particularly startups and funds.
Similar to Malta, it has no minimum stay requirement, making it very attractive and providing that Plan B — again, something you can have in your back pocket and use when necessary, or if necessary.
I’ve added here citizenship after seven years residing in Greece, and this is an important distinction. Bringing it back to the discussion on Portugal, where it offers a flexible path to citizenship: although in Greece you can apply for citizenship after seven years, it does need to be seven years of residency in Greece of at least 183 days. So you can hold a golden visa without residing in Greece, but if citizenship is the goal, then you must become a resident de facto in Greece.
Similar to Portugal, we have some alternative visas here if you’d like to move to Greece in the shorter term. We have the financially independent visa, which is the passive income visa, and also the digital nomad visa.
Italy
Lastly on the visa side, I wanted to discuss Italy, which over the last 12 months in particular has seen huge growth within our teams. We opened a Rome office last month, so we’re very excited about that. But we have been working with the Italy golden visa for a few years now.
Our clients are looking to this program because, again, it has that no minimum stay requirement. But the Italy program is actually the fastest in Europe. You can obtain the residency card in as little as three months, provided that everything is invested and the application runs smoothly, which has been the case for our clients.
The investments range from €250,000 to €500,000 — €250,000 in startups, and there are various different options to invest in the market, and then on the fund side as well.
Similar to Greece, Italy does allow you to obtain citizenship, but it takes ten years instead of seven, and it does require you to reside in Italy for those ten years. The alternative visas here, again — you can see a theme — are the elective residence visa, which is the passive income visa, and the digital nomad visa, also available in Italy.
Now, on the citizenship side, I think Joe, you’re best placed to discuss this as our head of citizenship programs. But if you have any questions regarding planning for residency, I’ll be happy to respond in the Q&A. Thank you. Joe?
Citizenship planning
Joe: Hi. Thank you, Pucca. My speech is a little more streamlined, so it probably won’t be as long as Pucca’s. But the first thing we’ll talk about is citizenship planning.
As Pucca mentioned before, what clients are looking for is something for the future, for succession, for future generations, and this is becoming bigger and bigger. What we’re seeing with clients now is that it’s not necessarily just about getting something now — it’s about family and future generations and planning for them. There’s lots going on in the world, so this is becoming more and more popular.
People didn’t necessarily think before that they needed another citizenship, or a permanent residency somewhere. But now a lot more people are thinking about it. Even people who go through with the process knowing that maybe they’re never going to need to use this citizenship or this passport want to have something there just in case, and they want to set up their family and future generations.
In the programs I’m going to talk about, I’m going to talk a lot about the Caribbean. There are other countries such as Turkey, Vanuatu and Nauru. They all come under the citizenship by investment umbrella, so it’s a little more streamlined, and they’re very similar across the board.
Citizenship by investment programs are great short-term options, and they can help when you’re waiting for a residency program. If you’re looking at Europe, and it’s going to take maybe five or ten years to get that citizenship, then the Caribbean programs are very, very fast. It’s good to have one of these while you’re in the process of doing the residency program leading to citizenship in Europe, for example. It gives you something as a great Plan B.
You have it, you can relax knowing you have something in your back pocket. Maybe you’ll use it, maybe you won’t. It opens up opportunities for real estate, having a holiday home, purchasing real estate for rental purposes, and lots of other advantages such as tax advantages. A lot of these places we’ll talk about are crypto friendly. So it really gives you many different options.
The other good thing about these passports from the Caribbean specifically is visa-free access. There are a lot of people from countries where maybe their passport isn’t particularly strong, and a lot of business people who travel for business and have to apply for visas every time they travel. Citizenship in the Caribbean, for example, gives visa-free access to the United Kingdom, Hong Kong, Singapore, and all of the Schengen Zone. So it makes it much easier for them to travel for business.
The Caribbean programs
Within the Caribbean, we actually cover five Caribbean countries or islands: St Kitts and Nevis, Antigua and Barbuda, St Lucia, Grenada, and Dominica. All of these have similarities in the way you can invest to get citizenship.
They all have the option to donate. You can donate to a government fund, which helps with things like healthcare, education, infrastructure, roads and things like that. They also all — all but one, and that one’s getting it very soon — have real estate options, which are called a fractional share. So you’re investing in a luxury resort, a hotel, or a condominium. It doesn’t mean you own the property.
Most of the developments will actually give you time. You can stay there throughout the year — one or two weeks, some even more — and you own a fractional share. Generally that needs to be kept for a certain amount of time before you can resell it, and that’s generally between five to seven years.
Two of the islands have private or sole ownership of property for real estate, and that’s Antigua and Barbuda, and St Kitts and Nevis. These are great options for those who want to have a holiday home, or maybe spend the colder months from their country in a warmer climate and then get a rental income for the rest of the year. The starting price for that is $600,000 — this is all in American dollars, sorry.
It’s a very simple process, very similar to the donation route. They all basically have the same way of the process working: filling out some application forms, supporting documentation, and then just applying and waiting for what’s called the approval in principle.
Now, some of the islands have different options which do suit people specifically. St Lucia, for example, has a government bond option. It’s the only island with a government bond option, and that’s a $300,000 non-interest-bearing government bond, which you receive back after six years. This works very well for those people who want to invest and get a return.
When we talk about investment, people are often saying, “What return do I get on my investment?” For us, and for me personally, I believe that you’re investing in your future by getting the second or third citizenship. But there can be returns, whether it’s real estate or whether it’s this government bond option.
Dominica has the donation and the real estate fractional share option. And Antigua and Barbuda has a second donation option, which is actually great for larger families. It’s called the University of the West Indies Fund, and it’s specifically for six or more applicants, and it basically makes it the most cost-effective program for larger families. You also get a year’s scholarship to their university for one of the applicants.
As you can see, each island has similarities, but there are slight differences in the investment path. The other differences are the speed of processing times — the path to citizenship and how long it takes.
Right now, it’s always a race in the islands. Right now St Kitts and Nevis has the fastest processing time. From submission of your file — and that means once your paperwork is all filled out, everything is reviewed and submitted — they can get to the approval in principle stage in as little as 120 days, which is incredibly fast.
That approval in principle stage means you’re approved for the program, and that’s when you would either donate or pay for the real estate that you purchased. Then you go to the passport stage. The passports are produced, and then couriered to an address of your choice. So although you get to the approval in principle stage in as little as 120 days, it does take maybe three or four weeks after that to get the passports ready and couriered to your home.
Along with that, there are other benefits to these programs. It’s not just the visa-free travel or purchasing real estate and having a second home. There are tax-free advantages. They’re very crypto friendly. Most of the tax advantages, I would say, apply if you’re moving there and becoming a permanent tax resident, which is generally the same as a lot of other countries at 183 days per year. But even if you’re not a permanent resident, there are still tax benefits: no income tax, capital gains, wealth, or inheritance tax.
These programs also work so well when you’re looking to do the other programs, as I mentioned before, because you have it so quickly.
Beyond the Caribbean
If we can move on, Pucca — if we can go to the next slide, seeing as your hands are on the special button.
There are numerous citizenship programs across the world, and more and more coming every day. The other ones we’re going to talk a little about are Vanuatu, Turkey, São Tomé and PrÃncipe, which is one of the newest programs, and Nauru. And then we have a few new programs on the horizon, which are St Vincent and the Grenadines, Botswana, and the widely awaited Argentina, which hopefully is coming soon. There’s lots of talk about it, and I think people are very anxious for it to start.
Vanuatu, São Tomé and Nauru are incredibly fast to citizenship. São Tomé, three months to citizenship. Vanuatu, similar — three months — and also Nauru. To be honest, there’s nothing faster than that.
The difference with these citizenship programs is that they don’t have the visa-free access that the Caribbean programs do. These programs are specific for certain types of people who are looking for asset management, for example. Vanuatu is very crypto friendly. So it’s a specific program that specific people are looking for.
It’s also a great stepping stone to another citizenship or another residency, because having another citizenship means you can apply for either residency or another citizenship. So they’re great options. They all only work through the donation option. For example, São Tomé is $90,000 for their donation, so it’s incredibly cost-effective and incredibly fast.
It only recently started, and there are great numbers coming through in applications, and now we’re seeing the success of the passports being granted. So we believe that’s going to be a very big program.
Then Turkey. Turkey has always been a very popular program for real estate. There are great real estate options in Turkey. It starts at $400,000, and the good thing about this is it doesn’t have to be in one property. So you can purchase two properties, two apartments, in different areas of Turkey. There are generally areas that you’re supposed to buy in — Istanbul obviously is one of the main areas to purchase — and it’s great for people who want to have real estate but don’t necessarily need to live in the country.
For the Turkey program, you do actually need to visit two or three times during the process. But you can have those properties and live in one, rent the other, or rent both properties. The rental market in Turkey is great. You only need to keep the property for three years before reselling it, which is also a very short time.
It’s very easy to rent property in Turkey, especially somewhere like Istanbul. They have great universities. There are always students looking for rental apartments. And owning the property, you basically have all the rights. It really works in what we call the landlord’s favor.
Travel requirements and new programs
Now, as I mentioned about having to travel to Turkey three times during the process — generally in all the Caribbean programs, Vanuatu, São Tomé, and Nauru, the program is fully remote, so it’s a very easy program to apply for.
With the Caribbean, there is one program at the moment, which is Antigua and Barbuda, that has a residency requirement of five days within the first five years of becoming a citizen. The other programs are going to be following suit. We’re not sure exactly when — we’re still waiting for the definitive answer and the official announcement. But we believe, from what we hear, it’s going to be 30 days within the first five years of becoming a citizen.
We’ve also heard that if, for example, there are three people on the application, that 30 days can be split between the three different applicants. So it’s not 30 days each, it will be 30 days split between three people. That makes it easier as well. But in general, the programs are fully remote.
Vanuatu brought in new biometrics for the passport, and it strengthens the passport — it’ll be similar to passports across the world. So now you have to give biometrics for Vanuatu, and you do actually have to travel for that. There are a few different places you can travel to. You can travel to Vanuatu. You can travel to Dubai. You can travel to Hong Kong or New Caledonia.
They’re also very progressive in the way they’re thinking about people not being able to travel. Some people are too busy to travel, so they have the option that a passport officer can actually fly to the country where you reside, and the biometrics will be taken there. Obviously that’s a great benefit.
New programs on the horizon: St Vincent and the Grenadines, we believe, is going to be coming out in the second or third quarter of the year. And that’s going to be, as we know it, very strong. It will have visa-free access — fingers crossed. It does have it now: visa-free access to all of Europe. The reason I say fingers crossed is that things do change. These programs are governed, and they have to follow strict guidelines. But as we know right now, I think it’s going to be a very strong passport, and I think it’s going to be a very popular program.
Botswana is a new program that’s again on the horizon, and we are getting quite a few inquiries about it. I think what’s happening in this world of global mobility and migration is that people are really looking for different options. It’s not just Europe, and it’s not just the Caribbean. They’re really seeing how they can diversify and give advantages to themselves, spouses, children, future grandchildren — so these future generations can grow up with more options, and have more options without even having to think about it.
Argentina, we think, speculatively, is going to be a very popular program. It’s been long awaited. There are still lots of decisions being made. I think once it actually gets going, it’s going to be at the forefront of these programs. We’re ready and able — we’re sitting back waiting with bated breath for it to happen. That should be coming soon as well.
So the programs on the horizon, we’re thinking probably second or third quarter. You can’t quote me on that, unfortunately. We’re hoping with fingers crossed, like a lot of people out there.
One other thing to mention was how these programs work — for example, I touched on it lightly with Vanuatu, São Tomé and Nauru. There are certain countries that have restricted lists of who can apply. So very recently, Russian citizens weren’t allowed to apply to Nauru. But at the moment, in São Tomé they can apply. So really, there’s a program out there for everyone, for wherever you’re from.
These programs even accommodate stateless individuals, because some people are stateless. Refugees can apply as well. These processes might get more in depth and a little more difficult, but these programs really are there to help people and give people more advantages with global mobility.
I think a lot of these new programs that are coming up, they’re realizing what it can offer and how it can help the country or island, or wherever it might be, which is why a lot more people are looking into it.
We also get a lot of people calling us and saying, “I’ve heard about this,” but they don’t really know about it. What we do is sit with people and talk to them about what they want, what their end goal is, and how we can help them. It’s really letting them know what could work for them.
Alongside that, a lot of people will come to us with one idea — “I want this program” — but when we talk to them, we realize, no, that’s not the program for you. That doesn’t give you all the advantages you’re looking for. How about this? Or how about this country for citizenship while you’re doing residency? So it’s really working out what the individual needs and planning it for them, and the succession planning, and trying to get it right for them.
I’m not sure if I have another slide, or if we’re handing back to Pucca, because I’ve been talking for a while.
Adalberto: No, we don’t have another slide, but we do see our lovely global presence there — just showing you some of the countries we’re located in, that we deal with. So thank you for listening. I believe we’re probably going to some Q&A right now, hopefully.
Q&A
Hugo: Thank you both very much for that excellent presentation. We have at the moment from our audience just one question in the Q&A pop-up. So if you have more questions — citizenship, second citizenships, visas for any of those countries mentioned, or possibly general questions about other countries — drop them into the Q&A now, and we’ll do our best to answer them.
Let’s start with this question. “If you want to become a citizen of Malta, Greece, or Italy, as I understand you said I must reside a certain amount of days each year in those countries. But which would have the most advantageous tax rules?”
So maybe an outline of how much time is required to spend in each of those countries as part of the programs. And then, if you’re able to comment on the tax side, whether there are any tax advantageous programs in those countries.
Adalberto: Sure. In terms of time spent in country, for Italy, as mentioned in the presentation, it’s ten years where you need to reside for at least 183 days for each one of those years. Similarly, in Greece, the same number of days per year, but there just for seven years.
Malta, frankly, unless you’re going to do the citizenship by merit route and you qualify for that very exclusive program, the time spent in Malta will likely be north of ten or 15 years before citizenship can be obtained. You can apply after five years — that is the legal requirement, five years residing in Malta full-time, meaning at least 183 days a year. However, I have personally never seen anyone who has lived in Malta for less than maybe 12 or 15 years being able to successfully obtain citizenship.
Now, as far as taxes, yes, there are tax programs that try to attract high-net-worth individuals into those countries. However, as to whether one country would be more beneficial than the other, that depends on each individual’s circumstances.
Italy, for example, has a flat tax program of €200,000. That’s likely going to increase. Similarly, Greece also has a flat tax program. And Malta has what we call a non-dom regime, where you’re only taxed on what is remitted to Malta. If I’m not mistaken — and please don’t quote me on this, because I am not a tax expert; we do have tax experts on the team, but that is not my expertise — you do have to pay an annual tax of, if I’m not mistaken, €15,000, and then on whatever is remitted to Malta as well. But global income is not taxed.
Hugo: When you mentioned the €200,000, was that Italy?
Adalberto: Italy.
Hugo: And is that the minimum income to qualify, and then you pay a flat tax of €200,000?
Adalberto: That’s not the minimum income, that’s the minimum amount of tax that you pay. So it is for individuals who are paying a higher amount of tax. Naturally you start thinking about the progressive tax rates in certain countries like the UK, like the US, where an individual who perhaps is on the highest six figures would likely be paying above that.
I know it sounds a little high, but everything is relative. If they are paying €400,000, €500,000, €600,000 in taxes every year, a €200,000 flat tax would save them a significant amount of money.
Hugo: And does Portugal still have a — it used to have a quite well-known one, but I think it was replaced. Is there still a tax advantage program that’s perhaps more successful than the Italian one?
Adalberto: Right. Portugal used to have the NHR, the Non-Habitual Resident scheme, where individuals would only pay a flat tax of 20% of their income. There were some great advantages as well, like 0% tax on dividends and 10% tax on pensions. However, that has now come to an end.
It has been replaced by what people in the market call NHR 2.0, although that is very restricted to certain activities — academics and such. But it does offer some attractive advantages as well.
Hugo: Interesting. So I guess it’s just part of the planning process, isn’t it? The best thing to do is schedule a consultation with somebody at your firm and explore the options based on your situation, your goals, and what the options are — and it depends how flexible you are. Of course, some people want to move to Spain, or to Portugal, or to a particular country. But certainly in terms of residence, some people are more flexible and looking for advantages and paths to citizenship next.
And of course, as you were saying, I think it’s worth noting again that you don’t need to become a citizen to reside long-term in any of these countries — I’m thinking more of European countries — as long as you have your residency visa. Citizenship is a bonus. And I suppose for Americans particularly, if they’re considering renouncing, or just having options, as you say, the Plan B.
So another question is about this: if you already have a US passport and you gain a new citizenship, do you lose your US passport?
Joe: Go on then, I’ll take that one for you, thanks. No, you don’t lose your American passport. A lot of these countries also allow for multiple citizenships. For example, I have a US passport, I have a British passport. I’m a resident in Portugal, and eventually I’m going to go for citizenship — I need to learn the language first, that would help. So there are plenty of countries where you can have multiple citizenships.
I think also, to what you were saying earlier about consultations and booking a call, it’s very important to really explore the options. We do it all the time. People call and it’s just a conversation to see what they’re thinking and to give them options. More often than not it’s people saying, “Oh, I didn’t know that,” or, “I didn’t know there was a program here, and I didn’t know I could do this. I didn’t know I didn’t need to relocate.” So it’s really exploring all the options about citizenship, residency, and more.
Hugo: There’s a good new question that’s just come in. Is the golden visa minimum investment amount per person? What about for couples?
Adalberto: No, it’s not per person. How it works is you have the main applicant. That main applicant is responsible for making the investment, and the family will go through what we call a family reunification process under the golden visa. So no, you don’t need to make two €250,000 investments. One will suffice. But the smaller government fees, that then becomes per person, although it does differ from country to country.
Hugo: Thank you. So to our audience, please do type any more questions into the Q&A pop-up. One question in the meantime, which I think is always quite interesting, is: which countries do you see the most Americans moving to, and what sort of reasons are behind those particular countries?
Adalberto: That’s a very interesting question. We have American clients who are moving to certain countries, while at the same time we also have American clients who are just looking for a Plan B, who are just looking for a second citizenship or a second residency.
When talking about moving to different countries, Portugal for a very long time had been very popular, and it continues to be. But recently we’ve also seen other European countries become extremely popular. I mentioned Italy during the presentation, because really over the last 12 months I was actually quite surprised at the number of clients looking at Italy.
Spain as well, although the golden visa in Spain did end. There are alternative residency programs where you must reside in the country for a very long period of time in order to maintain it — again, close to that 183 days per year.
But interestingly, Latin America — so Uruguay, Paraguay, Brazil, Argentina — these are countries that are becoming increasingly popular with our American clients, and that’s for a mixture of reasons, from taxation to quality of life and low cost of living. So there are clients who are now spreading around the world, rather than what it was 10 or 15 years ago, where Europe would have been the main focus. We have clients now going quite globally.
Hugo: Really interesting. And have you seen a big pickup in the number of people moving and applying for visas and looking for a Plan B in the last year or so?
Adalberto: It has increased. This increase has been quite steady over the last several years. But yes, over the last 12 months in particular, our team has been very busy. Joe has as well, on the citizenship side.
Something we have noticed particularly over the last six to nine months is something Joe touched on in the presentation, which is a multi-jurisdictional approach. Ultimately they want a European passport, because that gives them freedom of travel across the EU. However, they want to hedge, they want to cover themselves in the short term, so they go for a Caribbean passport.
We had, interestingly as well, a case very recently of Canadian clients who wanted to live in Switzerland but were worried about geopolitics, so they also obtained residency in Uruguay whilst at the same time applying for citizenship in the Caribbean.
So it’s very important, as mentioned, that we do not just engage on a program-specific discussion with our clients. The very first question I like to ask clients is, “What is your main objective? What is your goal? What are your concerns?” And then everything comes out of that — a strategy that is bespoke, that is specific to their needs.
Hugo: Makes sense. So Kathy asks: do you assist US citizens applying for visas for Germany?
Adalberto: Not for Germany — we’re not there just yet. Although we will very soon be able to offer German citizenship by descent, as we have had many inquiries coming in, particularly from North America. But not for visas, unfortunately.
Hugo: Fantastic. Well, I think that’s all the questions. So it just remains to say thank you very much, Joe and Adalberto, for an excellent presentation. And thank you to our audience for joining us. This wraps up this year’s US Expats Financial Conference. So thank you all once again, and I hope you have a great rest of your day.