Governments Are Not Closing Residency by Investment. They Are Rewriting What Counts as an Investment.
Investor migration is changing fast - and governments are becoming increasingly selective about where capital goes.
In my latest briefing, I look at recent developments in 🇵🇦 Panama, 🇱🇻 Latvia, 🇨🇳 China and 🇳🇿 New Zealand, and what they mean for investors and advisors.
JURIS Editorial
Latvia, Panama and New Zealand changed their investor rules within days of each other. None shut the door. All three moved capital away from buying existing homes and toward vehicles the state can steer.
On 15 September, Latvia's new Immigration Law came into force and closed the real estate (€250,000) and bank deposit (€280,000) routes to a residence permit after sixteen years. Applications lodged by 14 September are reported to be assessed under the old rules.
The following day, Panama's Executive Decree No. 17 took effect. A resale property now needs US$500,000 to qualify for the Qualified Investor visa. A new, first-sale property stays at US$300,000. In between, on 9 September, Immigration New Zealand announced that Build to Rent developments will join the Active Investor Plus Growth category from December 2026, through approved managed funds only.
Three governments, three continents, one direction. This isn't a housing policy. It's a steering policy.
What changed, and what did not
Latvia keeps a company route, but it now grants two-year permits instead of five. A new €150,000 fund route, placed through a state-created alternative investment fund manager for at least five years, exists in law but is reported as not yet fully operational. The Cabinet can also suspend new investor permits for up to five years for a given country or region.
Panama's decree, dated 8 September, replaces Decree 722 of 2020. Investments already perfected under binding contracts keep the old thresholds if the application is filed within six months of entry into force. Appraisals can be required when the cadastral value does not reflect the property's real condition, and beneficial ownership must be proven.
New Zealand has announced, not implemented. The programme says further details on eligibility, structures and timing will follow before the change takes effect.
The pattern behind the dates
In my view, the common thread is not the asset class. It is who chooses. In Latvia the state creates the vehicle. In Panama the rule favours new construction. In New Zealand the money goes through approved funds. The applicant no longer picks the asset; the programme does.
The stated reasons differ, and that matters. Panama's decree is described as favouring new construction for its employment effect. In Latvia, the opposition to golden visas has centred on security and money-laundering risk. Three data points are a signal, not a law of nature.
What they share is timing. The window is the asse
What this means for clients and advisors
The qualifying investment is the variable, not the programme. Re-check the definition of "qualifying" before any funds move, not when the file is submitted.
Grandfathering windows are hard deadlines. Latvia's closed on 14 September. Panama's runs six months from entry into force, which points to mid-March 2027 (my calculation from the reported dates). New Zealand's has not opened.
Pooled vehicles change the risk. Liquidity, fees, lock-in and exit are different from owning a flat. Latvia's fund route ties capital up for at least five years.
Political risk survives approval. A bill filed in Latvia on 3 September would remove even the new fund route. It is only a bill, and elections are due on 3 October, but it shows how quickly a replacement can itself be challenged.
A residence permit is not a tax decision. Residence rights and tax residency are separate questions with separate tests.
The Takeaway
The question is no longer "which programme?" It is "which definition of investment will still apply when the transfer clears?" Governments rewrite that definition faster than plans get executed.
Keep dates in the file. Build in layers. Leave no single point of failure.
The briefing :
Panama: Qualified Investor visa: resale property now needs US$500,000
Executive Decree No. 17 of 8 September 2026 raises the property minimum for resale to US$500,000. First-sale new-build and off-plan property stay at US$300,000. It replaces Executive Decree No. 722 of 2020. Values can be checked by appraisal, and beneficial ownership must be shown when investing through entities.
Why it matters: anyone planning a resale purchase under the old US$300,000 rule now has a six-month clock, or a higher threshold.
Latvia: Golden visa property and deposit routes end; a state-run fund route is created
The new Immigration Law entered into force on 15 September 2026. The €250,000 real estate and €280,000 deposit routes are closed. The company route remains at €50,000 or €100,000 plus €10,000 to the state, but the permit is now two years, down from five. A €150,000 fund route is written into the law but is reported as not yet fully operational.
Why it matters: a 16-year route is gone, and the replacement cannot yet be used. Russian and Belarusian citizens are reported as barred from both investment pathways.
China : State Council Order No. 841 takes effect: exit bans, and a duty on intermediaries
The official text sets exit bans of six months to three years in specified cases, such as administrative detention for fraudulent documents or illegal border crossing, and overseas criminal activity endangering national security. Bans for export-control violations have no fixed duration. Authorities must give written notice with reasons and remedies, except where national security or a criminal investigation could be compromised.
Why it matters for advisors: Article 10 requires intermediaries to refuse cases where public officials or military personnel try to obtain foreign nationality or overseas residence irregularly, and to report them. Press coverage that says "never told why" is stronger than the notice rule in the text. Have Chinese counsel confirm the article wording before relying on this summary.
New Zealand: Active Investor Plus adds Build to Rent, through managed funds only
Immigration New Zealand announced that Build to Rent developments will be an eligible option in the Growth category. Investors will access them only through approved managed funds meeting governance and capability requirements.
Why it matters: another example of the state defining the vehicle. Not yet operational; eligibility, structures and timing are still to come.
🇳🇱 Netherlands The 36% tax on unrealised gains: direction reported, details in conflict
Media report based on sources
The official timeline confirms that the Second Chamber passed the Box 3 Actual Return bill on 12 February 2026, with 1 January 2028 as the planned start. IMI Daily, citing Bloomberg, reports that the cabinet has abandoned the 36% tax on unrealised gains and will propose a tax on realised gains, with the current system continuing at least through 2029. A Dutch adviser's Prinsjesdag summary says the decision has instead been pushed to the Spring Memorandum of 2027, with the bill stalled.
Why it matters: the 36% figure is no longer a safe planning assumption, in either direction. Nothing here is enacted. This has not yet been confirmed by a Dutch government document that I could open.
🇪🇺 Brussels' legal basis is on record; what the five states have done since is not confirmed
Official report; political statements
The Commission's Eighth Report under the Visa Suspension Mechanism, COM(2025) 792 final, states that "the operation of such programmes constitutes, in itself, a ground for suspending the visa-free status" (page 6) and elsewhere calls it a "potential ground" (pages 7 and 15). It estimates about 107,000 passports issued by Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and Saint Lucia, and asks for adequate vetting "pending the discontinuation" of the schemes.
Why it matters: reports say EU letters of 25 June 2026 set a 1 June 2028 phase-out date and asked for interim measures by September. The letters have not been published; the reports come via Antigua's Prime Minister and specialist press. Whether the interim measures have been introduced is not confirmed by any source I found.
