The Council of Ministers have adopted the amended regulations in regards to the Cyprus Investment Programme (CIP) on the 18th of August 2020.
While the CIP remains the same in principle and structure and while many provisions have remained valid, the recently enacted regulations introduced certain new provisions that provide a more straight forward, legally stable and clarified framework.
In particular, the following provisions have been introduced in addition to and/or in replacement of the previous applicable rules:
- a “Supervision and Control Committee” has been established with the aim to regulate the services of the CIP registered service providers. Such Committee’s composition shall include the General Director of the Ministry of Interior, the General Director of the Ministry of Finance and the Representative of the Cyprus Investment Promotion Agency or their Representatives provided that they hold managerial positions, as well as duly experienced and trained administrative personnel.
- a “Naturalizations Control Unit” is established and held responsible for the continuous examination of the citizenship applications, the compliance of all applicants with the applicable regulations and the coordination and/or supervision of the CIP.
- detailed provisions have been introduced for the guidance and supervision of the registered service providers, in order to ensure compliance with the applicable regulations and the code of conduct. Moreover, the authorities, restrictions and obligations of the registered service providers are expressly defined.
- increase of the total amount of the required donations to €200,000, out of which €100,000 must be donated to the Cyprus Land Development Corporation and the remaining €100,000 to one of the following:
- The Research and Innovation Foundation; or
- The Industry and Technology Service; or
- The Fund for Renewable Energy Sources and Conservation of Energy; or
- The National Solidarity Fund.
- it is emphasized that the investment funds must emanate from the Investor’s personal account or from the Investor’s company/ies based and operating abroad.
- investment of funds for the incorporation and/or establishment of a land developing company is not a qualifying investment anymore.
- investments through incorporation or through participation in Cyprus companies and/or corporations and/or businesses based on an investment plan is still a qualifying investment for CIP purposes, provided that such entities have their physical presence and operations in Cyprus. Moreover, substantial activity and significant turnover must be proved, while the number of minimum Cypriot or European employees has been increased to 9.
- the validity of the applicants’ Criminal Record has been increased from 3 months to 6 months from the date of issuance.
- the eligibility of the Investors and their family members is subject to certain exceptions clearly defined. Applicants falling in any of the following categories are not eligible to apply for the CIP:
- politically exposed persons (PEPs), however it only applies to PEPs who hold such a position at the time of the application or within the 12 months prior to the submission of the CIP application;
- applicants who are subject to criminal investigation either in Cyprus or abroad at the time of the application and/or applicants convicted of serious criminal offences, in both cases applicable only for criminal offences punishable with imprisonment of 5 years or more;
- applicants that are connected with natural or legal persons who are included in the Restrictive Measures Lists of the European Union and/or applicants that they were connected (at the time of such inclusion in the List) with natural or legal persons who are included in the Restrictive Measures Lists of the European Union;
- applicants that are connected with natural or legal persons who are included in the Sanctions Lists of the European Union and/or applicants that they were connected (at the time when such sanctions were imposed) with natural or legal persons who are included in the Sanctions Lists of the European Union;
- applicants that are connected with natural or legal persons who are included in the Restrictive Measures Lists of either the European Union or the United Nations, against whom such Restrictive measures remained valid for a period ended up to 12 months prior to the submission of the CIP application;
- applicants who are included in the “Wanted List” of either EUROPOL or INTERPOL; and
- applicants the estate of whom has been seized within the borders of the European Union.
- the application/s of the Investor’s family members can now be submitted either simultaneously with the Investor’s application or at any time after the submission of the Investor’s application.
- it is provided that the parents of the Investor or the parents of the Investor’s spouse, as the case may be, could submit the citizenship application provided that they purchase a residential property of minimum €500.000 not including any applicable VAT.
- it is emphasized that the citizenship may be revoked if any of the economic criteria and/or requirements of the CIP are no longer satisfied.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
Areti Charidemou & Associates LLC