Ireland’s Immigrant Investor Programme (IIP): Changes on the horizon?

Monday, December 19, 2022

Introduced by the Irish Government in 2012, the Immigrant Investor Programme (IIP) enables investors from outside the European Economic Area make an investment or donation in Ireland in exchange for a right to reside and work in Ireland for the investor and their immediate family.

2022 saw a significant increase in the number of applications made under the IIP.

In 2021, there were 243 applications from Chinese Nationals alone and, since the start of this year, there have been 785 applications, three times the amount of 2021.

The rise in numbers is seen as a sign of anxiety among potential future applicants that a formal review of the programme, which has just concluded, could lead to significant changes to the programme in the future. These changes could include an increase in the minimum investment size. The Department of Justice, which is responsible for administering the programme, has declined to comment on the findings of the review as they are still under consideration.

Some commentators had suggested that the programme might be closed altogether. However, it is now considered that any speculation as regards the closure of the programme is inaccurate. The programme is more likely to be refined. However, when, and how this will be done remains unclear.

Under the current Immigrant Investor Programme, an individual may apply to become an investor in the Immigrant Investor Programme once the following requirements are satisfied:

• The investment made must be beneficial for Ireland and in the interest of the public
• The investment amount must be legally acquired and owned by the investor
• The investor must be of good character and must not have been convicted of criminal offences in any jurisdiction
• The investor must be able to demonstrate net worth of at least two million euros

There are four different investment options currently available:

1. Enterprise Investment: a minimum of 1 million euros invested in an Irish enterprise for a period of at least three years.
2. Investment Fund: a minimum of 1 million euros in an approved investment fund for a period of at least three years. These funds must be approved and regulated by the Central Bank.
3. Real Estate Investment Trusts: a minimum investment of 2 million euros in any Irish Real Estate Investment Trusts, listed on the Irish Stock Exchange, for a period of at least three years.
4. Endowment: a minimum of €500,000 to a public project benefiting the arts, sports, health, culture, or education. The endowment may be €400,000 per investor if there are more than 5 applications.

Amid moves to close citizenship-by-investment schemes in other countries it is worth emphasising that the IIP is not a visa scheme or a citizenship scheme. The IIP offers successful non-EEA applicants a Stamp 4 Immigration permission for themselves and their immediate family members to live and work in Ireland for an initial two-year period and which can be renewed thereafter.

Philip Lee LLP has considerable experience advising both investors and recipients in relation to the Immigrant Investor Programme. If you would like to discuss the IIP with us please contact Anna Hickey, corporate partner or Cian Moriarty, immigration team.

Article available in Mandarin here.