The minimum period you must hold a property purchased for a Citizenship‑by‑Investment (CBI) programme is governed by two separate rules: one that binds the seller (when they may resell) and one that binds the property (whether it can be used again for another applicant). The length of each period, the event that starts the clock, and the penalties for early disposal vary across the Caribbean programmes that offer a real‑estate route and Turkey’s comparable scheme.
Dominica – Two consecutive sub‑regulations
- Seller restriction: Property may not be resold until 3 years after citizenship is granted.
- Property restriction: The same property cannot be used for a subsequent CBI application until 5 years after the original citizenship grant.
- Effect: After three years the owner can sell to a non‑CBI buyer; a CBI buyer must wait five years.
Antigua and Barbuda
- Restriction: Property cannot be resold for 5 years from the purchase date (unless the buyer acquires another approved project).
- Penalty for early sale: Citizenship is revoked and the investor is disqualified from further participation.
- Exit option: The penalty is lifted if the investor simultaneously purchases another qualifying asset of equal value.
Grenada
- Seller restriction: Owner may not dispose of the property until 5 years after citizenship is granted (section 11(3)).
- Property restriction: A new applicant may use the same property only after the original owner’s five‑year period has expired (section 11(4)).
- Penalty: No explicit sanction for early sale in the legislation.
Saint Lucia
- Restriction: Property may not be sold or transferred for 5 years after citizenship is granted (Regulation 10(8)).
- Property reuse: The regulations are silent; there is no explicit allowance or prohibition for a later CBI applicant to use the same property.
- Penalty: No specific penalty for early disposal is stated.
Saint Kitts and Nevis – Seven‑year rule and cabinet approval
- Seller restriction: Property may not be sold to another CBI applicant for 7 years from the date the legal title is issued (Regulation 29(22)).
- Property restriction: Even after seven years, a sale to a CBI buyer requires either:
- designation as an Approved Private Home, or
- Cabinet approval confirming substantial additional investment (e.g., further construction or renovation).
- Penalty: Not specified; the sale simply cannot proceed without meeting the additional conditions.
Turkey – Title‑registry block
- Minimum investment: Property must be valued at USD 400,000.
- Seller restriction: Title deed is annotated to prohibit resale for 3 years from the registration date.
- Property restriction: A property may be used for a CBI application only once; subsequent applicants cannot rely on the same property.
- Penalty for early sale: Removing the three‑year block results in loss of citizenship.
Early‑sale consequences in the Caribbean
- Antigua and Barbuda: Early disposal triggers automatic revocation of citizenship and disqualification, unless the investor simultaneously reinvests in another qualifying asset.
- Dominica: Early sale leads to citizenship revocation, possible disqualification, and the transaction being declared null and void (or damages payable if voiding is impossible).
- Grenada & Saint Lucia: No explicit penalty for early sale is codified; citizenship can only be revoked for fraud, criminal conviction, or conduct bringing the country into disrepute.
Practical checklist for prospective buyers
- Confirm which rule applies to the specific unit (seller vs. property restriction) and obtain written confirmation from the programme office.
- Identify the start date of the holding period – purchase date, title registration, or citizenship grant – as these can differ by programme and affect the actual duration.
- Verify prior use of the property; in Dominica, Saint Kitts and Nevis, and Turkey a property already used for CBI cannot be reused.
- Consider programme longevity: the EU has asked the five Caribbean states to phase out their CBI schemes by 1 June 2028. A seven‑year restriction in Saint Kitts and Nevis, for example, may extend beyond the programme’s expected lifespan.
Understanding the distinct seller and property restrictions, their start points, and the associated penalties is essential before committing to a CBI‑linked real‑estate investment.
Source article: www.imidaily.com






