專業叢書
作者 / Peter Lu‧呂旭明會計師、Max Lu‧呂嘉昕信託師
U.S. Trust and Estate Planning 美國信託規劃實務(英文部分)
Chapter 5 The Rise of the Global Family Office
Should Wealth Creators apply for Permanent Residency (PR) in the EU? As an example, would applying for a Bulgaria PR be appropriate for them?
Bulgaria offers a particularly attractive program for Cross-Border Wealth Creators. It’s investment requirement, ~€500,000 in an Alternative Investment Fund (AIF), is particularly low compared to other countries in the EU.
In addition, Wealth Creators typically receive their EU Permanent Residency (PR) card within 6 – 8 months and can apply for full Bulgarian Citizenship within 5 years from the initial PR application. Bulgarian citizens enjoy visa-free travel to 142 countries around the world.
Furthermore, Bulgaria’s flat 10% income tax rate only applies to income derived from within the country and the country does not tax its residents on any income derived from outside Bulgaria. 
In summary, Europe provides a comprehensive suite of benefits for Cross-Border Wealth Creators, from business and tax advantages to high quality of life and robust legal protections.
Acquiring EU citizenship or permanent residency can significantly enhance personal and family security, business opportunities, and overall wealth management strategies.

Advantages of Obtaining Bulgarian Citizenship

In the past, Asian wealth creators typically chose countries like Portugal, Spain, Greece, and Cyprus for investment immigration to Europe, seldom considering Bulgaria. However, since Bulgaria became a Schengen member state on March 31, 2024, Bulgarian citizens no longer need a passport to travel to most EU countries, Norway, and Switzerland. This enhanced mobility allows Bulgarian citizens to freely move, work, and invest across European countries, gradually making Bulgarian citizenship an option for wealth creators seeking investment immigration. The advantages of investment immigration to Bulgaria are summarized as follows:

1. Fast Track to Residency and Citizenship: Bulgaria offers a rapid pathway to residency and citizenship, particularly through investment immigration programs. This allows foreign nationals to obtain permanent residency in a short period and apply for citizenship within a relatively short time frame.
2. Low Cost of Living: Compared to living in the United States, the cost of living in Bulgaria is relatively low, including expenses for housing, food, transportation, and other daily necessities, making it an ideal choice for economic immigration to Europe.
3. Favorable Tax System: Bulgaria has one of the lowest tax rates in Europe, with the lowest personal and corporate income tax rates in the EU. This provides an attractive tax environment for entrepreneurs and high-income individuals. Bulgaria’s personal income tax rate is only 10%, the lowest in the EU. Additionally, those who reside in Bulgaria for less than 183 days are considered non-tax residents and are exempt from personal income tax. For dividend income, Bulgaria imposes a 5% tax, but for EU citizens, the dividend tax rate is 0%. Bulgaria has also signed numerous tax treaties with other countries (e.g., China-Bulgaria Double Taxation Avoidance Agreement) to prevent double taxation and promote foreign investment.

4. EU Member State Status: As an EU member state, Bulgarian citizens enjoy the right to freely travel, work, study, and receive local health insurance benefits (e.g., can apply for the European Health Insurance Card, EHIC) in other EU countries. This provides immigrants with the flexibility and opportunities to live across the EU in the future. Furthermore, Bulgarian nationality law supports the acquisition of Bulgarian nationality for family members of its citizens without age restrictions, allowing wealth creators to consider family-based immigration.
5. Visa-Free Access to Multiple Countries: Holding a Bulgarian passport allows visa-free travel not only within Schengen countries without passport checks but also to up to 142 countries, including the UK and Canada.
6. Pleasant Natural Environment and Climate: Bulgaria boasts beautiful natural scenery, such as magnificent mountains and the Black Sea coast, along with a pleasant climate, making it an ideal place to live and enjoy life.

These advantages make Bulgarian citizenship a compelling choice for those considering investment immigration, offering economic benefits, increased mobility, and a favorable living environment.

An Overview of Bulgaria
Bulgaria is located in southeastern Europe on the Balkan Peninsula, bordered by Romania, Serbia, North Macedonia, Greece, and Turkey, with the eastern coastline along the Black Sea. The capital city, Sofia, serves as the country's political, economic, and cultural hub. Known as the last piece of untouched land in Europe, Bulgaria boasts rich historical landmarks, natural landscapes, unique artistic treasures, and a warm, hospitable culture.

1. Religion: Bulgaria is predominantly Eastern Orthodox (82.6%), with a significant Muslim minority (12.2%). The country upholds religious freedom, allowing its citizens to practice their faith freely.
2. Language: The official language is Bulgarian, with English widely spoken as a common second language.
3. Climate: Bulgaria experiences a temperate continental climate. The eastern regions are influenced by the Black Sea, and the southern regions by the Mediterranean, resulting in a Mediterranean-type climate. The average annual temperature is about 10.5°C, with January being the coldest month (average temperatures between -1°C and 2°C) and July the warmest (average temperatures between 20°C and 25°C). The annual average precipitation is around 450 millimeters.
4. Population and Ethnicity: Bulgaria has a total population of approximately 6.9 million people. The ethnic composition is primarily Bulgarian (84%), with a significant Turkish minority (8.8%), and the remaining population consisting of various other ethnic groups.
5. Economy: Bulgaria's economy is primarily based on agriculture, with roses, yogurt, and wine being internationally renowned products. The national currency is the Lev (BGN), which has maintained a stable exchange rate, currently pegged at approximately 1 Euro = 1.95583 Lev. Following the pandemic, Bulgaria has sustained a stable economic growth rate, with a 3.4% growth in 2022 and an impressive 7.6% growth in 2021, indicating recovery from the impact of COVID-19. Additionally, Bulgaria's stable political and investment environment continues to attract numerous foreign investors and entrepreneurs.

How to Obtain Bulgarian Citizenship & Investment Planning After Obtaining Bulgarian Citizenship
Obtaining a Bulgarian residence permit is the first step towards acquiring EU citizenship. With a Bulgarian residence permit, you can immediately open a personal bank account in Bulgaria, establish a local company, and open corporate bank and investment accounts, laying a solid foundation for future family wealth transfer, tax planning, and legal risk management.

Typically, acquiring Bulgarian residency through investment immigration involves the following steps:

1. Invest in the Bulgarian Immigration Fund: Invest 500,000 euros to obtain a permanent residence permit in Bulgaria.
2. Get a Local Mobile Phone: Apply for a Bulgarian mobile phone, which serves as a basic tool for opening personal or company bank accounts and activating banking apps.
3. Establish a Local Company: Set up a local Bulgarian company, whether it be an investment company, operational company, or holding company.
4. Open a Local Personal Bank Account: Open a personal bank account in Bulgaria.
5. Acquire Real Estate: As a permanent resident, you can hold local land ownership or real estate in Bulgaria.
6. Hold Offshore Holding Company: Hold overseas holding companies under Bulgarian investment company name.
7. Open Investment Accounts in the US: Open investment accounts in the US investment banks in the name of the offshore holding company.
8. Internationalize Asian Equity Holdings: Transfer personal equity holdings in Asia to the offshore holding company.
9. Transfer Bulgarian Holding Company Equity to a US Family Trust: Transfer the equity of the Bulgarian holding company to a US family trust to achieve cross-border inheritance, asset protection, and tax planning purposes.

After obtaining Bulgarian citizenship, wealth creators can consider transferring the equity of a Bulgarian holding company into a U.S. irrevocable dynasty trust to further enhance the potential for multigenerational family asset transfer. By combining a U.S. dynasty trust with a Bulgarian holding company, wealth creators can achieve EU citizenship while ensuring that their wealth is protected under U.S. law.

Bulgaria Investment Immigration Program & AIF Investment Immigration Fund
To assist wealth-creating families with investment immigration, Ginkgo Investment Company directly engages local Bulgarian immigration lawyers and introduces the innovative AIF (Alternative Investment Fund) investment immigration service. This service aids clients interested in immigrating to Bulgaria by investing in AIF, facilitating the acquisition of permanent residency and subsequent Bulgarian citizenship.

The operation and investments of AIF must strictly comply with Bulgarian laws. The Bulgarian AIF project primarily invests in Bulgarian company stocks and bonds, aligning with the immigration criteria under Bulgarian citizenship law. Investors participating in the AIF program are required to invest 500,000 euros (approximately 1 million levs). After investing for 6-8 months, they can obtain permanent residency. After 60 months of holding permanent residency, they qualify for Bulgarian citizenship, thereby gaining full EU citizenship rights. 



The process of immigration and obtaining Permanent Residency (PR)

Step 1 : Apply for Immigration to Bulgaria in person

Step 2 : Visit the Bulgarian Embassy in Beijing / Shanghai in person

Step 3 : Visit Bulgaria again to appy for PR

Step 4 : Obtain PR (Permanent Residence Permit)

Step 5: Pass the Bulgarian language exam and obtain Bulgarian citizenship and passport