Bulgaria’s citizenship by investment programme was introduced in its current form in late 2013. In domestic terms, the key innovation was to permit permanent residence leading to citizenship based on an investment of BGN 1,000,000 (approx €512,000) and expedited processing of 2 years where an investment of BGN 2,000,000 (approx €1.02m) was made.
While highly competitive compared to other EU citizenship routes, Bulgarian citizenship by investment has not been promoted by the Government of Bulgaria.
This slowed take-up but there is now evidence of organic and likely sustained demand growth and of an adequate administrative capacity to process applications.
As of September 2018, the cumulated total of applications for citizenship by investment in Bulgaria stood at 193. 95 of these were Standard Track and 98 – Fast Track.
Since the Standard Track requires applicants to hold a residence permit for at least 5 years, most standard applications are only beginning to be eligible.
An average of 18 applications were submitted via Fast Track annually between 2013-2017. In 2018 the annual application rate doubled to 35 on an annualised basis.
Applicants from the Middle East and the ex-USSR make 77% of the Fast Track applications, with most applicants being from Russia. This may be connected to the close cultural connection between the two countries and Bulgaria’s familiarity to Russians.
Around 64% of all Fast Track applications made have been approved by the Ministry of Justice so far. The majority of the remaining Fast Track applications were filed in 2018 and cannot be expected to have reached approval.
The final checkpoint in the process, the Vice Presidential decree, has been passed by 50% of the applications approved by the Ministry of Justice. In another positive sign about improved administrative capacity and procedural familiarity, the data shows that so far in 2018, the Vice President’s office has granted as many citizenships as in the previous 4 years combined.
This information tends to demonstrate that the Bulgarian citizenship by investment is highly competitive compared to other EU countries.
Comparing to Malta, EU citizenship can be obtained within roughly the same timeframe, but with a significantly lower cost. This also applies to Cyprus, where the typical outlay is on an investment in real estate. While the Bulgarian route is not as rapid as the Cypriot one, avoiding the volatility of real estate and the bias accompanying the selection of qualifying real estate by investing in government bonds is highly attractive.
Our team has already successfully assisted a large number of ultra high-net worth, high net worth and affluent applicants, and our clients have so far had a 100% success rate.
If you would like more information, please feel free to contact us at firstname.lastname@example.org.
Stopping the improper use of insolvency proceedings
A client of our dispute resolution team (led by Kamen Shoylev and Yordan Neshkov) was recently the subject of an indirect claim by a Bulgarian bank with which this client has been engaged in a multi-stage dispute. Unusually, the bank acted through a vehicle registered in an African state, which made an unfounded claim in the tens of millions of euros against our client and sought the commencement of judicial insolvency proceedings against this client. The offshore vehicle was chosen to isolate the bank from liability and create certain evidential difficulties for our client's representation.
NBLO succeeded in terminating the insolvency proceedings, with direct loss fully awarded to our client. A second claim to recover our client's indirect losses is currently under way.
Where targeted in this way through insolvency proceedings, a company may be prevented from trading properly (e.g., by suffering restrictions on its financing or being unable to participate in public procurement).
Through our considerable experience in insolvency litigation, both entirely domestic and where there are European and cross-border elements, we are ideally placed to assist clients in resisting such attacks and recovering the real and considerable losses that may be suffered.
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