European Citizenship and Caribbean Citizenship: Eight Differences

European citizenship and Caribbean citizenship by investment programs are the cream of the crop among the world’s investor immigration initiatives. Although both regions offer distinct advantages, notable differences between them may sway individuals toward one over the other. This article will outline some key variations, enabling you to make a well-informed decision between Caribbean and EU citizenship.

What EU and Caribbean citizenship by investment programs are available?

Before delving into the differences between European citizenship vs Caribbean citizenship programs, let’s identify which countries offer a citizenship by investment program in each region.

Eight Differences Between European and Caribbean Citizenship by Investment Programs

1. Minimum investment

Minimum investment thresholds are generally the easiest way to distinguish Caribbean and European citizenship programs. Of the five Caribbean countries offering citizenship in the CBI industry, Dominica’s program is the cheapest, requiring a minimum investment of $200,000.

On the other hand, European programs offering EU citizenship start at a much higher investment thresholds overall. The Malta Citizenship by Naturalization for Exceptional Services by Direct Investment program (CES) requires a minimum investment of €690,000. Austria’s citizenship by investment program is specifically designed for high-net-worth individuals, with a minimum investment of €2 million to obtain an EU passport.

Nevertheless, European citizenship by investment programs offered by countries outside the European Union require much lower investments to obtain a European passport. Foreign investors can obtain European citizenship in Moldova with an investment worth €100,000. A €200,000 investment in North Macedonia will fulfill the requirement to obtain second citizenship.

Here’s a table comparing the investment requirements for European and Caribbean investor citizenship schemes, including applicable fees.

2. Investment options

The fundamental aim of a country introducing a citizenship by investment program is to introduce investments that bolster social and economic progress. Common investment options include:

• Contributing to a national fund
• Purchasing real estate
• Establishing a business that provides jobs
• Purchasing government bonds

In the Caribbean, investments typically follow a standardized approach, predominantly involving a non-refundable contribution or a government-approved real estate investment. Antigua and Barbuda also provides the unique option of investing in the University of the West Indies Fund. Foreign nationals can establish new enterprises in St Lucia related to industries such as gastronomy, education, or infrastructure development to earn Caribbean passports.

European citizenship, particularly EU citizenship by investment programs, offers less diversity in investment options than Caribbean citizenship by investment programs. Malta’s investor citizenship scheme provides only one option: Property investment combined with a government contribution and philanthropic donation.

The investment criteria for Austria’s citizenship by investment program are less clear-cut than other citizenship programs in other European countries; however, candidates are typically evaluated based on their substantial contribution to the economy through a business investment that creates employment opportunities.

Turkey is an outlier among European citizenship by investment countries as its citizenship program has five investment options, including real estate investment, purchasing government bonds, job creation, and bank deposits.

3. Travel freedom

Many European and Caribbean nationals with golden passports enjoy enhanced travel freedom, with visa free access to many countries and regions, including Canada, the UK, and the Schengen Area. The sole difference is that European citizenship allows unrestricted access to more countries and territories than the Caribbean.

Golden passports from an EU country like Austria or Malta offer golden passport holders the highest level of visa free travelling, accessing the most visa free travel treaties established by European Union member states.

An EU passport is the only Golden passport available through citizenship by investment, granting visa free travel through visa exemption to the United States, Australia, and New Zealand. Most alternative European passports, including the Moldova and North Macedonia passports, provide enhanced visa free travel to foreign nationals acquiring second passports, albeit not to the extent of visa free travel and visa exemption provided by Golden passports issued in EU countries.

A Caribbean second passport offers a comparable level of visa free access, although with minor distinctions in visa free travel arrangements. According to the Global Passport Index, a St Kitts and Nevis Caribbean passport holder has the strongest Caribbean passport. St Kitts and Nevis passport holders have visa free access to 154 countries, including the UK and EU member states.

A Caribbean passport from Grenada offers visa free access to China, a visa free travel privilege not extended to holders of St Kitts and Nevis and EU passports. Antigua and Barbuda recently joined China’s visa free regime, adding to the Antigua and Barbuda passport 151 visa free countries.

Both regions allow citizens to travel visa-free and without passports to other countries within the region, particularly in the Schengen Area. The only distinction is that European citizens have unrestricted access to more countries and Caribbean citizens.

Here is a table of the number of countries European or Caribbean passport holders have visa free access to.

Regarding freedom of movement differences between European and Caribbean citizenships, EU passport holders have freedom of movement and the right to establish permanent residency in 27 European Union countries. In contrast, Caribbean passport holders from member states of the OECS (Organisation of Eastern Caribbean States) have freedom of movement and the right to establish permanent residency in 7 OECS countries. However, Caribbean passport holders with a CARICOM Skills Certificate can move freely between 20 CARICOM countries.

4. Due diligence

Citizenship by investment is like any other means of acquiring citizenship in a country. They signify the highest level of status achievable by individuals; hence, investors must meet specific criteria to obtain citizenship in European and Caribbean countries. These criteria include:

• Having a valid passport
• Holding a clean criminal record
• Proving a legitimate source of investment funds
• Not being from or having ties to prohibited countries

While each European and Caribbean country offering citizenship by investment has strict eligibility criteria, Caribbean countries offer citizenship by investment without the requirement to visit the country during the due diligence process to be granted citizenship. An investor can become a Caribbean citizen and gain a Caribbean passport through an entirely remote citizenship application.

In contrast, to gain EU citizenship by investment, applicants must visit the country during the application process to fulfill the due diligence criteria. Furthermore, the non-EU member states of Moldova and North Macedonia also require applicants to visit the country to qualify for second citizenship by investment. Only Turkey allows investors to obtain citizenship and a second passport without visiting the country beforehand.

5. Processing time

An appealing aspect of all the countries offering citizenship by investment is that it significantly reduces the time to attain citizenship. Most non-natural-born citizens acquire citizenship through naturalization, which requires a long period of permanent residency before being eligible-normally five to ten years. Citizenship by investment in most countries reduces this timeframe to a few months.

The best Caribbean citizenship by investment countries will grant a second passport the fasted, with investors able to obtain Caribbean citizenship and Golden passports within four to five months. European citizenship by investment countries outside the European Union also offer fast processing times. Investors can expect to receive a European passport from Moldova, North Macedonia, or Turkey within two to six months.

Obtaining citizenship in an EU country takes at least 12 to 36 months. Malta’s CES program grants EU citizenship after 36 from the lowest minimum investment amount and after 12 months for the highest investment. Austria has the longest processing time to receive golden passports, with citizenship granted after 24 to 36 months.

6. Tax benefits

Several Caribbean countries, like the Cayman Islands and the British Virgin Islands, are known for being tax havens. Although the five Caribbean countries offering Caribbean citizenship by investment are not entirely tax free, they offer significant tax benefits over European citizenship by investment countries.

Foreigners who purchase Caribbean real estate to obtain Caribbean citizenship in St Kitts and Nevis or St Lucia are not required to pay personal income tax. None of the five Caribbean countries impose capital gains, wealth, or inheritance tax. Successful applicants of Caribbean second citizenship programs can further optimize their taxes through no worldwide income tax.

The table below illustrates the tax advantages of obtaining Caribbean citizenship by investment.

7. Business opportunities

Business opportunities across both regions vary; however, the decision to obtain citizenship in one over the other may hinge on the specific industry in which you operate. Investors in the tech industry may find EU citizenship more appealing due to the region’s robust technological infrastructure, access to talent pools, supportive regulatory environment for technology startups, and membership in the world’s largest single economy.

Those seeking real estate investment will find that the Caribbean real estate market presents the most opportunities at reasonable prices. Moreover, lucrative investments in the tourism industry of Caribbean countries are abundant, and many government-approved real estate projects offer commercial property investment while qualifying for Caribbean citizenship.

8. Geography and climate

All Caribbean countries offer a tropical climate and a vastly different way of life than European countries. Life on Caribbean islands consists of year-round sunshine and hot weather in green and luscious landscapes. In contrast, Europe features distinct seasonal changes, with hot, dry summers and cold winters.

For US citizens, the Caribbean lies on the doorstep of the United States. Flight times from Caribbean citizenship by investment countries to the US take three to four hours. Malta is the nearest European country with a citizenship program to the United States and has a flight time of over 11 hours.

Why You Should Consider the Differences Between European and Caribbean Citizenship by Investment

While gaining citizenship in Europe or the Caribbean has its strengths, the choice between European and Caribbean citizenship programs is determined by your specific preferences, priorities, and objectives. You may consider factors such as:

• Investment thresholds
• Investment options
• Residency requirements
• Visa free travel
• Tax implications
• Ease of applying
• Freedom of movement
• Dual citizenship
• Political and economic stability

Knowing the key differences between regions and countries offering citizenship by investment is crucial in making informed decisions.

European vs Caribbean Citizenship Programs: Which one is right for you?

Beyond considering the investment amount required and other related criteria, the decision ultimately depends on your plans, preferences, and goals.

• Seeking a fast Plan B passport? A Caribbean citizenship by investment program will provide the quickest route.
• Looking for the most visa free travel options? An EU citizenship program will offer the most powerful passport.
• Exploring ways to optimize your taxes? St Kitts and Nevis citizenship by investment offers the best tax environment, with no income tax, capital gains, inheritance, or wealth tax.

Additionally, Caribbean islands and European nations offer distinctive lifestyles. In Europe, you’ll find state-of-the-art infrastructure and breathtaking historical architecture, whereas the Caribbean offers a more tropical paradise setting.

The two regions also exhibit varying degrees of economic and political stability, each with its own considerations regarding safety and security. Investors should remember that specific social and economic factors may be more pertinent to particular countries than broader regions.

Frequently Asked Questions about European Citizenship and Caribbean Citizenship

Is dual citizenship allowed in European countries?

Most European countries allow dual citizenship, including Malta, Moldova, North Macedonia, and Turkey. Austria offers the only European citizenship by investment program that does not allow dual nationality. Investors are required to renounce their original citizenship to gain EU citizenship in Austria.

Does the Caribbean allow dual citizenship?

All five Caribbean islands officering CBI programs permit dual nationality, allowing applicants to obtain Caribbean citizenship while maintaining their original citizenship.

How does Caribbean citizenship impact travel and visa-free access?

By obtaining Caribbean citizenship through a citizenship by investment program, individuals can gain visa free travel privileges to numerous countries worldwide. A Caribbean passport from Grenada provides visa free access to China and Russia, whereas a St Kitts and Nevis passport offers visa free travel to 153 destinations worldwide.

Investors should note that Caribbean citizenship programs have previously impacted visa free travel access. There have been campaigns to suspend visa exemption for certain countries with citizenship programs.

The European Commission examined Dominica’s citizenship by investment program and removed the country from the list of visa-exempt countries due to concerns over the program’s integrity and the potential for individuals to exploit it for illicit activities, such as illegal immigration and money laundering.

What are the tax implications of obtaining citizenship in a Caribbean country?

Caribbean taxes in citizenship by investment countries are typically favorable for successful applicants. Many Caribbean citizenship by investment countries offer friendly tax regimes, including low or zero income tax rates and no inheritance or capital gains taxes, lowering the overall tax burden for a new Caribbean citizen.

Will Caribbean passports lose EU access?

How many countries you can travel to on a Caribbean passport, or any passport for that matter, can change based on visa free travel agreements. The European Union is considering tightening its visa waiver program, potentially affecting visa free access for citizens of five Caribbean nations offering citizenship by investment programs.

This move aims to enhance security measures and curb illegal migration. Dominica passport holders, including native-born Dominican citizens, have lost visa free access to the EU countries.

Nevertheless, several Caribbean islands have enhanced their due diligence process to obtain a Caribbean passport by investment, preventing any compromise on security standards and granting citizenship to individuals seeking to exploit its travel privileges illegally.

Which Caribbean country is easiest to get citizenship?

The Caribbean has several Golden Visa countries that offer golden passports to investors. Applicants and their families, including specific dependent adult family members, can obtain dual citizen status in countries like St Kitts and Nevis, Antigua and Barbuda, and Dominica within 12 months through investments, including purchasing approved real estate or government bonds or contributing to a national development fund.