The concept: the entry threshold and the cost of ownership are two different numbers
A country page shows a single figure: $200,000 of contribution, €400,000 of property, €500,000 into a fund. That figure is the price of admission to a procedure, not the cost of the route. Four layers sit on top of it, each with its own logic: non-refundable government charges (application fee, due diligence, interview, issuance of the document), transaction costs on the asset itself (transfer tax, notary, land registry, broker), recurring costs of holding the status (renewals, insurance, upkeep of the property, minimum presence) and the price of exit (exit tax in the country of departure, the liquidity of the asset, the sunk portion of the investment). For a family of three the gap between the shop window and the till runs from 8–10% on a Caribbean contribution to 20–25% on European real estate, while on the fund route the extra layer is stretched over time and is therefore systematically underestimated.
What follows is a layer-by-layer breakdown, with figures taken from official sources as at August 2026, and three worked calculations. One caveat applies to the whole article: government tariffs move by secondary legislation with no transitional periods, so a budget is checked against the date of filing, not the date of decision.
Government fees and due diligence: charged per head, not per family
The first structural error in any budget is to price the fees on the main applicant. Almost every programme tariffs a family per capita, and adding a spouse and a child inflates the government block out of all proportion to the size of the investment itself.
The Caribbean: a contribution plus a fixed set of charges
Under Dominica's official CBIU schedule, the Economic Diversification Fund (EDF) takes $200,000 from a single applicant and $250,000 from a main applicant with up to three dependants; each further dependant under 18 costs $25,000 and each one aged 18 or over $40,000. On top of the contribution: due diligence of $7,500 on the main applicant and $4,000 on every dependant aged 16 or over, a processing fee of $1,000 per application, a certificate of naturalisation fee of $500 per person, and a mandatory interview at $1,000 for everyone aged 16 and above. The schedule states separately that enhanced due diligence is charged extra and that bank transfer charges fall on the applicant — the state must receive the contribution in full. On the real estate route the contribution is replaced by a government fee: $75,000 for a single applicant and $100,000 for a family of up to four.
St Kitts and Nevis holds the Sustainable Island State Contribution at $250,000 for a family of up to four, $25,000 for each additional dependant under 18 and $50,000 for each one over 18. Due diligence is $10,000 on the main applicant and $7,500 on every dependant aged 16 or over; the interview is compulsory for the main applicant and discretionary for dependants of 16 and above. Processing is officially stated at 120–180 days from acknowledgement of the application. The practical point: due diligence fees are non-refundable on refusal, and this is the one category of spend that is guaranteed to burn in the negative scenario — more in the note on vetting the applicant.
The EU: you pay not for a passport but for a card, and again at every renewal
European residence programmes are built the other way round. The investment is usually recoverable (a fund, a deposit) or converts into an asset (property), but the government charge attaches to the issue of the card and repeats at every renewal. For Portugal, the rates applied by AIMA — the Agency for Integration, Migration and Asylum — to the ARI in 2026 are publicly collated as follows: an application analysis fee of €618.60 when filed through the portal (€806.80 in person), €5,325 per person for issuance of the residence title, and €2,663 per person for each of the two renewals in the five-year cycle. That leaves a family of three holding a government bill of roughly €33,000–34,000 across the cycle, whatever the €500,000 is actually invested in.
Greece is cheaper on the fee line — a government charge of €2,000 per application plus €16 for the issue of each card — but it shifts the burden into property transaction taxes (below). Malta's Permanent Residence Programme, per the PwC Malta summary, charges an administrative fee of €60,000, a government contribution of €37,000, €7,500 for each dependant beyond a spouse and minor children, a €2,000 donation to a registered NGO and €100 a year for the card — some €99,000 of non-refundable payments before a cent goes into property.
Agent commission: why it does not show up in the budget
This is the least transparent line of all. In Caribbean programmes the agent does not, as a rule, invoice the client separately: the remuneration is paid by the state or the developer out of the money already handed over. According to an IMI Daily survey, fixed payments to accredited agents per approved client run at around $50,000 in St Kitts, $40,000 in Vanuatu, $30,000–35,000 in Grenada, $35,000 on the St Lucia fund route and $25,000 in Antigua; Dominica is the outlier, calculating the fee as 10% of the contribution. Two practical conclusions follow. First, "no fee for our services" is not a discount but ordinary economics — the remuneration already sits inside the tariff. Second, a real discount can only come out of the agent's share, and a quote below the official tariff means either a rebate from that commission or a practice the region has been actively suppressing since 2024, when the Caribbean states agreed a price floor and a ban on discounting.
On European routes the picture is inverted: the commission is visible but fragmented. The lawyer takes a fixed retainer, the estate agent a percentage of the deal (market practice in Greece is around 2% from each side plus VAT), the fund a subscription fee and an annual management charge, and the developer a marketing uplift baked into the price of the unit that appears on no invoice at all. There is no verifiable public tariff here, so the only workable technique is to demand written disclosure of every source of the intermediary's remuneration before signing, and to benchmark the price of the unit against comparable stock sold outside the programme.
Taxes and charges on acquiring the asset
Property routes carry the heaviest transaction layer, and none of it comes back on sale. In Greece the buyer pays a transfer tax of 3% plus a municipal surcharge of 3% of that tax — effectively 3.09% of the contract or objective value, whichever is higher; the notary takes 0.8–1% plus 24% VAT, the lawyer 0.5–1%, registration at the land registry about 0.5% plus €12 per entry, and the mortgage registry 0.475% plus VAT. The 24% VAT on new build remains suspended until 31 December 2026. All in, acquisition costs land at 7–11% of the purchase price. Since Law 5100/2024 the programme thresholds are €800,000 in Attica, Thessaloniki, Mykonos, Santorini and islands with a population above 3,100, €400,000 elsewhere and €250,000 for commercial premises converted to residential use and listed buildings under restoration; the investment must be in a single property of at least 120 sq m, and short-term letting through platforms is prohibited — the programme rule itself cuts the yield on the asset. The detail sits in the note on the Greek golden visa.
In Dubai, where property carries a ten-year visa, the Dubai Land Department schedule is simpler: 4% of the transaction value (market practice puts it on the buyer), a registration trustee fee of AED 4,000 plus 5% VAT where the price is AED 500,000 or more, AED 250 for the title deed, AED 250 for the site plan, token knowledge and innovation fees of AED 10 each, a developer NOC at AED 500–5,000, valuation of about AED 4,020 and mortgage registration at 0.25% of the loan. That comes to roughly 4.3–4.5% against Greece's 7–11% — but without the European visa-free leverage.
Legal work, translations and legalisation
This line is small in absolute terms and large in its capacity to blow a deadline. A family file includes police clearance certificates from every country of residence in recent years (in Portugal, issued no more than three months before filing and translated into Portuguese), birth and marriage certificates, evidence of the origin of funds, tax certificates, medical insurance, and confirmation that nothing is owed to the tax authority or social security, dated no more than 45 days back. Every document goes through an apostille or consular legalisation and a sworn translation — and, where processing drags, through re-issue because it has gone stale. That is the real hidden cost: not the first set of documents but the second and the third. Applicants with a Russian footprint carry an extra layer — substantiating the source of funds and surviving bank compliance on receipt of the payment; the specifics are in the review of Russian applicants in investment migration.
The annual cost of holding the status
The recurring layer decides what the route actually costs over the horizon to naturalisation. Its components: renewals (in Portugal, twice in a five-year cycle at €2,663 per person), medical insurance (in Greece, of the order of €180–600 a year per person), upkeep of the property — utilities, building management, the annual property tax (Greek ENFIA is calculated on the objective value; Dubai has no equivalent ownership tax) — tax compliance in the country of status, and keeping a bank account alive.
A separate and almost always unbudgeted item is the opportunity cost of presence. Portugal requires 7 days a year (in practice, 14 days per two-year period); Greece requires no minimum presence at all; Malta's MPRP obliges the holder to keep the qualifying property for five years from the date of the certificate and to maintain accommodation thereafter to keep the status. Seven days a year is not "a week's holiday" — it is flights, a window in the calendar and, with a large family, three diaries to synchronise. And those very days count for nothing towards tax residence, on which see below.
The tax footprint: when a residence permit quietly becomes residence
Status does not by itself create tax residence — the test is factual almost everywhere: 183 days, centre of vital interests, permanent home. But the combination of a home in the country, growing presence and family on the ground moves the question from formal to factual faster than the holder expects; the mechanics are set out in golden visas and tax residency and in the primer on the tests for residence. The practical side: jurisdictions with a light presence requirement (Greece at zero days, Portugal at seven) are deliberately engineered so that the status does not drag residence behind it, whereas countries where a home is rented or maintained year-round hand the tax authority the material for an argument. The second footprint is tax on holding and on leaving the asset: annual ENFIA in Greece, capital gains tax on a non-resident's disposal, withholding on fund distributions.
The price of exit: exit tax, liquidity and sunk money
The most underestimated part of the budget is the money paid on parting — with the former status and with the asset itself. It breaks into three independent components.
Exit tax in the country of departure. Spain, under article 95 bis of the LIRPF, taxes unrealised gains on shares and holdings on a change of residence where the taxpayer has been a Spanish tax resident for at least 10 of the last 15 years and holds a package with a market value above €4m, or above €1m where the stake is 25% or more; on a move within the EU or EEA the recognition of income is deferred for up to ten years and falls away if in the meantime the holdings are not sold, residence does not leave the EU/EEA and the notifications are filed. The United States taxes not departure but renunciation: under the IRS expatriation rules, a covered expatriate is one whose average annual net income tax for the five preceding years exceeds a threshold ($206,000 for 2025 and, on the 2026 inflation adjustments, $211,000), or whose net worth reaches $2m, or who fails to certify tax compliance on Form 8854 (a $10,000 penalty for non-filing); the mark-to-market regime excludes $890,000 of gain for 2025 and $910,000 for 2026. The wider map is in exit taxes: an overview and the note on US expatriation.
Liquidity of the asset. A contribution to a state fund is non-refundable by definition — it is a price, not an investment. A unit in a private fund comes back on the fund's exit schedule, not on the investor's wish: the horizon of Portuguese closed-ended funds is usually longer than the five-year residence cycle, and selling early is normally possible only at a discount. Property returns money through a sale — with the next buyer's transaction costs embedded in the price, and on whatever market happens to exist on the date of disposal; and selling before the mandatory holding period expires destroys the basis of the status.
The risk attaching to the status itself. That, too, has a price. In its judgment of 29 April 2025 in Case C-181/23, European Commission v Republic of Malta, the Grand Chamber of the Court of Justice held Malta's citizenship-by-investment scheme incompatible with Article 20 TFEU and Article 4(3) TEU: transactional naturalisation, where EU citizenship is granted in exchange for predetermined payments, breaches the principle of sincere cooperation between member states. Spain abolished its golden visa by Organic Law 1/2025 with effect from 3 April 2025. On 17 November 2025 the Council of the EU approved a new visa suspension mechanism in which a third country operating a citizenship-by-investment scheme without a genuine link to the applicant is named expressly as a ground: an initial suspension of 12 months, extendable to 24. Portugal, by Organic Law No. 1/2026 (published 18 May 2026, in force from 19 May), extended the period to naturalisation to 7 years for nationals of the Community of Portuguese Language Countries and 10 years for everyone else, counted from the issue of the residence card rather than from the filing of the application; cases lodged before 19 May 2026 are decided under the old rules. All three episodes say the same thing: the economics of a route calculated over a five-year horizon can be rewritten by the legislature halfway through. More in the notes on status risk, Caribbean CBI programmes to 2028 and the visa suspension mechanism.
Three worked calculations for a family of three
Assumptions: a main applicant, a spouse aged 16 or over and a child under 16; all amounts at official tariffs as at August 2026; private remuneration is given as a market marker and is not a verifiable public figure.
| Item | Contribution: Dominica EDF | Fund: Portugal ARI | Property: Greece, €400,000 |
|---|---|---|---|
| Headline threshold | $250,000 (family of up to 4) | €500,000 | €400,000 (outside premium zones) |
| Is the money recoverable | No | Yes, on the fund's exit schedule | Through a sale of the property |
| Government and DD fees per family | ≈ $16,000 (DD $11,500, processing $1,000, interviews $2,000, naturalisation $1,500) | ≈ €33,800 (analysis, title, two renewals for three people) | ≈ €2,050 (€2,000 fee plus cards) |
| Acquisition taxes and charges | — | — | 7–11% of price: ≈ €28,000–44,000 |
| Intermediary remuneration | Inside the tariff (10% of the contribution in Dominica) | Fund subscription and management fees plus lawyer | Broker ≈2% plus VAT, lawyer 0.5–1% |
| Minimum presence | None | 7 days a year | None |
| Annual upkeep | Effectively nil | Renewals plus insurance plus tax compliance | ENFIA, utilities, building management |
| Time to naturalisation | Citizenship immediately | 10 years (7 for CPLP nationals) from 19.05.2026 | 7 years of residence under the general rule |
| Uplift over the headline figure | ≈ 6–8% | ≈ 8–12% (excluding fund fees) | ≈ 8–12% |
The table is best read from the last row together with the third: the route with the lowest government fee (Greece) carries the highest total uplift because of transaction taxes, while the route with the highest fee (Portugal) spreads it over five years and therefore looks cheaper than it is. The Caribbean contribution is the dearest in absolute terms but the most predictable: the whole sum is known on the filing date, and once the passport is issued it generates no further spend.
Questions and answers
Why an agent's budget is almost always lower than the actual outlay
Because it captures only the payments that pass through the agent. What typically sits outside it: bank charges on transferring the contribution (the state must receive the full amount, and the shortfall is collected from the applicant), apostilles and sworn translations, re-issuing certificates when processing drags, property transaction taxes, insurance and renewals, and flights for biometrics and interviews. Ask for the budget in two columns — payments to the state and payments to private parties — with the trigger date of each payment set out.
Is the money returned if the application is refused
Partly, and layer by layer. Due diligence, processing and interview fees are never returned — they pay for work performed. A contribution to a state fund is normally paid after approval in principle, so on refusal it is simply never paid. The investment in a European residence programme goes in before the decision but remains yours: the fund unit or the property does not disappear; what is lost is the basis for the status and the fees already paid. In the worst case a family of three on the Caribbean route loses about $16,000 of official charges plus the cost of the documents.
Which is dearer over five years, a fund or property
On European routes the costs are comparable but differently distributed. Property demands 7–11% on top immediately, after which it generates almost no government charges and in theory returns the capital on a sale. A fund attracts no acquisition tax but claws the difference back through Portuguese fees (roughly €33,000–34,000 for a family of three per cycle) and its own subscription and management charges, and its liquidity is tied to the fund's exit schedule rather than to your decision.
Can an investment status make me tax resident
Not on its own — residence is settled by a factual test: days of presence, centre of vital interests, permanent home. That is precisely why programmes with a nil or token presence requirement (Greece with no minimum stay, Portugal with 7 days a year) are designed so that the status does not pull residence with it. The risk comes from the facts on the ground: a home maintained year-round, family in place, presence creeping upwards. The key asymmetry: the days that are enough to keep the residence permit do nothing to build up tax residence if you happen to want it for a tax regime.
How much to budget for the price of exit
This is the most individual line of all. If the country of departure is Spain and you were resident there for 10 of the last 15 years with a holding worth more than €4m (or more than €1m at a stake of 25% or above), article 95 bis of the LIRPF requires unrealised gains to be recognised on the change of residence, with deferral of up to ten years on a move inside the EU or EEA. For US citizens and long-term residents, giving up the status triggers mark-to-market under section 877A, with a $910,000 exclusion for 2026, once the thresholds of $211,000 of average annual tax or $2m of net worth are crossed. The liquidity part of the exit price is calculated separately: the discount on an early sale of a closed-ended fund unit, and the buyer's transaction costs embedded in the resale price of a property.
How stable are the tariffs and the programme rules themselves
They are not. In the last eighteen months: Spain abolished its golden visa with effect from 3 April 2025; on 29 April 2025 the Court of Justice held Malta's citizenship programme contrary to EU law; on 17 November 2025 the Council of the EU made citizenship-by-investment schemes a ground for suspending visa-free travel; and from 19 May 2026 Portugal extended the period to naturalisation to 10 years for most applicants, counted from the issue of the card. Plan so that the value of the route does not rest entirely on one rule the legislature can change in the middle of your five-year cycle.