The views expressed herein are solely those of the writer.
By Isaac Legair, Barrister.
In an article published on 16th December 2025, I put forward the case for residence by investment (RBI) as a viable and superior alternative to citizenship by investment(CBI). The first of these schemes is invariably referred to as a“golden visa”, while the second is often nicknamed a “golden passport”. Such schemes are fully described in authoritative academic articles and publications such as found in this link:
https://www.lse.ac.uk/social-policy/Assets/Documents/PDF/working-paper-series/WPS-02-24-Kristin-Surak.pdf
Subsequent to the publication of my earlier article, there has been huge tectonic shifts in the foundations of the international mobility landscape, resulting in the creator of CBI schemes (St Kitts and Nevis) who first devised this scheme over 40 years ago, succumbing to pressure from the USA and EU, with the result that they (St Kitts/ Nevis) will now introduce a residential requirement for all applicants who wish to obtain such facilities. The link to that article is available here:
https://citizenx.com/insights/residency-requirements-st-kitts-nevis-citizenship-program/
Consequently, citizenship by investment along historical lines is now dead! No longer can islands sell off their most valued patrimony to persons they have never met, or amongst whom they have never lived. The days of receiving a golden passport by courier from an OECS state and then flying off to live in Canada or the UK are now over.
A residence requirement now heralds residence byinvestment, under which the applicant buys (hopefully) characterful accommodation (condominium or apartment) in designated zones within the island in which he aspires to become a citizen. He then goes to live in that island for some minimum period and is later fast tracked to citizenshipwithin a shorter time than the statutory seven-year period, in the case of SVG.
With RBI, the issue of personal taxation now plays a central and pivotal role in the choice of jurisdiction in which potential clients are likely to express an interest. Under the (now old) CBI system, the issue of taxation carried little or no relevance, as clients immediately shipped themselves abroad after obtaining their new passport. However, under RBI, applicantscome to reside in their new country, if only for a few years, and in the process become tax resident there. To the new applicant citizen, this carries no cost if the issuing country does not levy an income tax (e.g. as is the case in Antigua and St Kitts/ Nevis).
However, no fiscally prudent international investor will wish to take up residence (and by implication, tax residence) in any island which does not offer anenvironment which is free of personal income tax. It would be a great absurdity, if for example, a client was to leave his home country where the rate of personal tax is e.g. 15%, only to find himself in an OECS state that levies say 25%.
Why take up residence in a highly taxed OECS state when this client could live a tax-free life in Antigua or St Kitts/ Nevis?
Another matter is the issue of the physical real estate that clients are expected to buy. Invariably, many are prepared to buy apartments etc, off plan before the property has beenbuilt. Such decision to buy being made based on computer-generated images (so called CGI’s). However, there must at least exist approved plans for building in desirable areas. Crucially, such projects must be in the hands of international developers with a high reputation for delivery and in possession of strong balance sheets and solid lines of creditwith their bankers. Again, no prudent investor will make advance payments for a not yet built property, unless the developer is of the highest calibre, and under arrangements where advance payments are held by independent escrow agents or trustees.
Considering such significant paradigm shifts in the international mobility landscape, within the last two months,the SVG government and its officials currently working on the legislation for implementing RBI would do well to first consider the practical and economic factors below. They should now:
1. Begin the process of finding and zoning suitable geographic locations where these apartments, condominiums etc could be built.
2. Begin negotiations with reputable and credit worthy international developers who have a proven track record ofdelivering these high-quality residences within budget and timescale.
3. Examine the changes that must now be made to the Income Tax Act, so that SVG is adequately able to compete with St Kitts/ Nevis and Antigua in attracting potential applicants. This may require granting a permanent exemption from income tax to any person buying into the RBI scheme. This could be accompanied by charging a fee for a lifetime tax exemption certificate as part of any RBI scheme.
4. Revise, update and amend the relevant financial services legislation that will help to attract international investors to SVG, and thereby reverse the bastardization of the Business Companies Act and International Trusts Act, inflicted by the last administration.
Finally, if in the process, a suitable example to follow is required, they should adopt the tried and tested formula used by Barbados and the Bahamas.
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