3 min read
Historical archive — not a current route. This matter was completed under the former Cyprus Investment Programme, which stopped accepting new applications on 1 November 2020. Cyprus does not now sell citizenship through property or other investment…

Written by Eleni Philippou, Senior Partner
Cyprus Bar Association (since 2001)
Historical archive — not a current route. This matter was completed under the former Cyprus Investment Programme, which stopped accepting new applications on 1 November 2020. Cyprus does not now sell citizenship through property or other investment. Property purchase may be relevant to a separate Regulation 6(2) permanent-residence application, but residence does not buy or guarantee citizenship.
Mr. J, an Asian businessman, invested in Cyprus real estate and applied under the then-existing Cyprus Investment Programme. The facts and deadlines below describe that closed historical programme and must not be used as present eligibility or timing guidance.
Mr. J had identified two investment options of different values. The first option was to buy three luxury villas under construction for €2,000,000 plus VAT. The second option involved acquiring a sea-front plot in Paphos for €6,500,000 to construct eight custom-made villas for holiday and short-term rentals.
Mr. J contacted us to assist with his property acquisition in Cyprus, transferring the purchase money, and filing the necessary application under the Cyprus Investment Program for him and his family to obtain a Cypriot passport.
The Cyprus Investment Programme described in this case study was abolished on 1 November 2020. Cyprus no longer offers citizenship through investment. This account is retained as a historical case study; property investment today can support permanent residency rather than citizenship.
The matter was urgent as Mr. J contacted us only 25 days before changes to the Cyprus Investment Program, which introduced a government grant of €150,000. To save this amount, we needed to complete due diligence on the properties, banking due diligence, and transfer the money to Cyprus before the deadline.
To provide Mr. J with flexibility and meet the minimum investment required for his citizenship application, we drafted a framework agreement with the seller. This agreement allowed Mr. J to buy the three villas while maintaining an option to purchase the seafront plot in exchange for the villas and the difference in money. Additionally, Mr. J received an option for the seller to rent the sea-front properties at a specific price, with the tenancy terminable annually by Mr. J.
We concluded the due diligence, signed and lodged the purchase agreements for the three luxury villas with the Land Registry, and completed banking due diligence, bringing the €2,000,000 plus VAT to Cyprus within 15 days. We filed the citizenship application just before the deadline, allowing Mr. J to avoid the €150,000 donation.
No new application can use these former thresholds, donations, deadlines or processing steps. Current investors must use a live residence route and, if relevant later, satisfy the separate naturalisation legislation.
Soon after, Mr. J decided to exercise his option to purchase the sea-front project with an associate under a jointly owned company. We incorporated their company, drafted a shareholders’ agreement, assisted in exercising the option, concluded the necessary cancellation and purchase agreements, and are monitoring the licensing and construction of the project.
Under the former programme, Mr. J and his spouse received Cyprus passports approximately 11 months later. This historical outcome is not available to a buyer today and is not evidence that a current property purchase or residence application leads to citizenship.
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Senior Partner
Senior Partner specializing in real estate and conveyancing, contract law, and wills, estate planning, and probate. Leading the firm's Property Department and serving as AML Compliance Officer.
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