European Citizenship Options for Americans in 2025

Malta the last remaining Citizenship by Investment Programme in Europe

Dr. Priscilla Mifsud Parker | 14 Nov 2024

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In recent years, Americans spend more time in Europe, expand their businesses outside the US, acquire holiday homes or yachts in the Mediterranean, and open their children to European colleges and universities, the European job market or European sports clubs. To achieve this, Americans seek to revive their American ancestral roots or explore opportunities for European citizenship by investment routes. Malta ticks all the right boxes as an entry point to Europe and discretely comes out on top.

Reasons why Americans seek European Citizenship

Americans seek European citizenship for a number of reasons.  A second citizenship in the EU grants an American the right to relocate, live, study, work, invest, do business, and retire in any one of the member states of the EU. For children, this opens up access to the European job market, access to European schools, colleges and universities, as well as the ability to join European sports clubs. For high net worth individuals, this allows them a Plan B option to the move to another tax jurisdiction and to legally expatriate from the US (US legal and tax advice should be sought to ensure all legal observing the appropriate legal and tax obligations applicable upon exit.)

So what is European Citizenship?

European citizenship is not a standalone citizenship. When we refer to European Passports we refer to a passport issued by one of the 27 member states of the European Union. Nationality of any one of the member states in the EU gives rise to ‘European citizenship’ a term that describes the rights granted to citizens of all EU member states in all the EU member states other than their own country of nationality.  ‘European Citizenship’ translates into the enjoyment of rights enshrined by the treaties establishing the European Union, including the freedom of movement of persons, goods and capital and the freedom of establishment.

Routes to European Citizenship for American Investors / Entrepreneurs

While some Americans are blessed with European ancestry that may, in some cases entitle them to claim their ancestral European nationality, eligibility is often limited, the process bureaucratic and this route to European citizenship is often difficult due to burdensome process of sourcing old birth certificates. A more preferred route for investors or business families is to acquire citizenship by investment in a European country that allows a route to naturalisation as a citizen of that country, by investment.

Malta, a Mediterranean island state in the EU enjoying a family-friendly, safe environment and the lowest unemployment rate in Europe, is the last remaining country in the European Union allowing investors to naturalise after holding legal residency for 3 years, reduced to 1 year in cases of a higher exceptional investment.  Malta defends European Union objections to this investor route by maintaining a robust due diligence process to ensure that only fit and proper investor families are offered the privilege of naturalising as Maltese citizens. (Under EU law, the EU cannot interfere in matters of citizenship as these are left entirely within the remit of each member state). 

Under Malta’s Rules for Naturalisation by Direct Investment, the privilege of naturalising as a Maltese citizen is only extended to an American family upon successfully completing all the eligibility requirements.  These include evidence of personal, social, and commercial integration during the 3 or 1-year legal residency period. A minimum physical presence in Malta of 30 days or more is also required during the first year which is very practicable given Malta is very accessible and provides a pleasant location for relaxation or remote working.  It is only upon receiving the last approval that the American investor must make the one-time non-refundable direct investment (€600,000 - €750,000) to the Government (these funds are managed and deployed in projects of national importance for the social and economic development of Malta).

Cyprus, an island member state used to allow investors to naturalise through the purchase of a portfolio of €2.5 million in real estate.  Unfortunately, this programme closed in 2020 and political will is lacking for a return of some form of Cypriot investor citizenship.

Until 2023 when the Golden Visa by real estate was closed, Portugal granted a ‘Golden Visa’ that is legally-speaking a one-year temporary residency renewable every year, subject to demonstrating a minimum physical stay of 7 days.  For American families who settle in Portugal, demonstrate integration in Portugal (9 months a year presence in Portugal, children’s schooling in Portugal) and pass the Portuguese language test, this opens the opportunity of applying to Portuguese citizenship.  Citizenship is not an automatic right though and is subject to these integration and language requirements which not all American families are able to meet, hence the popularity of the Malta route that is shorter, better defined.

Malta: Legal and Tax Considerations

English is an official language in Malta and also the language of education, business and finance. Malta does not impose any language tests in its investor routes to residence or citizenship. Unlike many other European countries, Malta does not apply worldwide taxation to persons resident in Malta for tax purposes. Malta does not have any wealth taxes, property taxes, inheritance taxes or entry/exit taxes.  For Americans, Malta has a double tax treaty with the US.

European Citizenship Lawyers

Our European citizenship lawyers advise our American HNW and UHNW clients on the various citizenship and immigration routes in Europe according to the specific objectives or circumstances of the individual.  We dedicate personal attention to each client and oversee each citizenship case individually.  We help our clients assess which European citizenship route best suits their objectives and whether they qualify under the relevant laws.  As Maltese citizenship agents with extensive experience of Maltese citizenship and investor immigration for Americans, we offer a holistic coverage of all immigration and relocation and all relevant tax and legal services under one roof.

ACC Immigration Advisors (Malta company registration number C-44042) is duly authorised to act as a licensed Malta citizenship agent in terms of the Agents (Licences) Regulations, 2020 (L.N. 435 of 2020) and bound by the “Licence Agreement and Code of Conduct and Ethics for Agents” entered into with Community Malta Agency, under official Malta licence number AKM-ACCA.


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Key Contacts

Dr Priscilla Mifsud Parker

Advocate, Tax Consultant, Licenced Agent, Malta

+356 22056422

Dr Antoine Saliba Haig

Advocate, Malta

+356 22056446

Claudia Cilia Buhagiar

Senior Private Client Advisor  

+356 22056124

Julia Tirazona

Advisor

+356 2205 6409

Pauline Gouder

Residency & Citizenship Manager

+356 22056105

Roberta Anastasi

Senior Private Clients Advisor

+356 22056105