CBI or residency: which route for your plan?

Citizenship by investment grants a nationality and a passport. It generally requires no presence, and it confers no tax advantage in itself.

Residency by investment grants a right of residence. It may require presence, and it does not bring tax residency with it either, since tax residency follows its own criteria.

Finally, a preferential tax regime grants a tax treatment. It requires effective tax residency and a formal application, and it is the only one of the three to have any effect on tax.

These three schemes are independent. Confusing them is the cause of almost all badly designed plans, and the confusion is fuelled by a commercial offering that presents them together.

A fourth notion is worth adding, often confused with the previous three: permanent immigration residence, which ends the need for renewals and secures a move. It is generally obtained after years of temporary residence, and it cannot be bought.

It is this, and not a passport, that meets the need for legal security of a family settled abroad for the long term. Mexico grants it at the end of its temporary residence, Portugal and Spain after five years of legal residence.

The value of a second passport is measured relative to your own. For a French national, this gap is practically zero compared with the Caribbean programmes: about 145¹ destinations for Dominica, about 154² for Saint Kitts and Nevis.

The legitimate reasons are therefore narrow: diversifying nationalities, a fallback option, transmission to children, or specific access that no other document provides.

Grenada is the only case of the latter type among the Caribbean programmes: its nationals can apply for the US visa for treaty investors, which a French national cannot do on the basis of their original nationality.

The Grenadian contribution amounts to $235,000³, against about $200,000⁴ in Dominica and $230,000⁵ in Antigua and Barbuda: the price difference no longer justifies the choice; only the intended use does.

Finally, the main risk of this asset class is revocability: Vanuatu lost its European visa exemption, and its passport fell to about 95⁶ destinations.

For a French national, residency by investment is pointless within the European Union: freedom of movement allows them to live there without conditions.

It makes sense outside the Union, when it is the only practical route: the 10 years⁷ Emirati permit obtained through a property worth at least from AED 2,000,000⁸, or the 25 years⁹ Caymanian certificate.

It also makes sense when it is the prerequisite for a genuine move, which will then open tax residency and, where applicable, a preferential regime.

It makes no sense, however, as a substitute for actually moving: a residence permit held without presence changes neither tax domicile nor taxation.

One practical criterion settles the matter quickly: if the scheme under consideration requires no presence, it will produce no tax effect. This rule is mechanical, and it eliminates most commercial offers without having to examine their details.

1. Determine the real need: mobility, the right to reside, or tax treatment.
2. Check whether freedom of movement already meets it, which is the case throughout the European Union.
3. Choose the scheme that meets the identified need, and that scheme alone.
4. Measure what France continues to collect as long as the departure is not effective.
5. Look at the price last: it no longer distinguishes between comparable programmes.

The fourth point is the one dealt with last, even though it decides everything. Article 4 B of the French General Tax Code sets out four alternative criteria, and meeting just one is enough to keep French tax domicile. Neither a passport nor a residence permit changes anything — only a genuine, documented move does.