Investment migration programmes: why the OECD flags more than 100 of them

When reading a ranking of investment migration programmes, most attention falls on capital thresholds and visa-free destinations. A less discussed layer of data bears directly on later reporting obligations: the risk list compiled by the Organisation for Economic Co-operation and Development. This piece describes how that list is built and where it stops.

Investment migration programmes in the OECD files

Investment migration programmes — the familiar pair of citizenship by investment (CBI) and residency by investment (RBI) — are state-run schemes that grant citizenship or residence rights to foreign investors on a path shortened relative to ordinary migration routes.

According to the Organisation for Economic Co-operation and Development (OECD), more than 100 schemes offered by jurisdictions committed to the Common Reporting Standard (CRS) have been reviewed. The purpose is not to rank programme quality, but to identify which schemes could be used to sidestep automatic exchange of financial account information.

The two criteria that flag a scheme

The OECD applies exactly two conditions, and both must be present:

• A personal income tax rate below 10% on offshore financial assets.
• No significant physical presence requirement — specifically, no obligation to stay 90 days or more in the granting jurisdiction.

The reasoning is direct: someone using a scheme to avoid reporting offshore assets typically wants both a low tax rate and no need to actually relocate. A programme that demands genuine residence removes most of that incentive by itself.

A flag is not a finding of illegality

This is the easiest point to misread. A scheme appearing on the risk list does not make it unlawful, nor does it imply that participants are evading tax. The list describes a structural feature — low tax combined with no residence tie — rather than any individual behaviour.

The practical effect sits with financial institutions: where a client relies on a residence document from a flagged scheme, banks are advised to ask further questions to establish genuine tax residence, instead of treating that document as sufficient on its own.

Much of the risk sits with intermediaries

The joint report by the Financial Action Task Force (FATF) and the OECD, published in November 2023, finds that the main weakness lies not in the idea of these programmes but in how they are run.

Four areas are named: heavy reliance on intermediaries, multiple government agencies involved without clear final accountability, scope for abuse by professional enablers, and weak programme governance. These are process variables — and therefore things that can be improved without closing a programme.

Summary

The OECD risk list is an additional layer of data, not a verdict. Read correctly, it answers one narrow question: is this scheme structured in a way that makes tax residence hard to establish. It does not say a programme is good or bad, and it does not replace checking the tax rules of the country where you actually live.

This piece analyses public documents; it is not tax or legal advice. The list and its criteria are updated over time — check the current version from the OECD before relying on it for a specific decision.

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