Developer Bartra has asked TÃ¡naiste Leo Varadkar for a temporary reduction in the investment needed for the State Residence Silver Program. He also warned that charitable donations through the program were consumed in fees and commissions.
The company wrote to Mr Varadkar in January telling him that the controversial Immigrant Investment Program (IIP) could be better exploited to help Ireland recover from the Covid-19 pandemic.
He said the state residency cash program was “underperforming” compared to other EU states and Ireland was lacking substantial investment. Bartra said Spain, Greece and Portugal have all generated between 300% and 600% more investment through their immigrant investor programs in recent years.
The company said Ireland needs to capitalize on its intrinsic advantages in terms of quality of life, higher education system and English-speaking population.
Bartra proposed a reduction of the investment threshold from 1 million euros to 500,000 euros for a fixed period of three years for the priority sectors of social housing and rest homes.
He said this would bring the state “through Covid-19 and have greater clarity on the implications of Brexit.”
Bartra’s letter stated that the current investment thresholds for similar programs in Spain, Greece and Portugal are between â¬ 200,000 and â¬ 500,000.
Bartra said the reduction could generate â¬ 2 billion in annual investment and that the investment threshold could then be subject to a full review after three years.
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The developer also warned of the complications of a second cash residency option allowing individuals to donate â¬ 500,000 “that is of public benefit to the arts, sports, health, culture or education â.
Bartra said he did not charge any fees on any donations he facilitated, but that the amount of money that ultimately goes to the association is affected by “fees, commissions or discounts.”
Bartra proposed that a mandatory endowment of â¬ 50,000 be made on each investment through the IIP with a prohibition on the payment of fees, commissions or discounts.
The email was forwarded by the TÃ¡naiste to the Justice Ministry which manages the program and has now been released under Freedom of Information.
Separately, notes from meetings between Bartra and the department detail discussions between the company and managers about the program.
In March 2019, Bartra founder Richard Barrett and two colleagues met with two heads of the department where they discussed how IIP works in different markets.
In Hong Kong, residents had âhistorically favoredâ countries like the US and UK, but expats were âlooking at optionsâ. The memo said people there were “very mobile” and Bartra responded by switching to online marketing.
There was also talk of the need for “greater transparency” regarding the program with a move to the publication of all projects to stop the perception that some seemed favored over others.
Bartra also asked if there was a dedicated investor meeting system with the department. A note from the meeting read, âWe cannot provide an appointment. The registration desk is aware of the limitations of its systems.
Ministry officials also reported a designated investment fund through which Chinese nationals allegedly placed money “as a means of withdrawing money from China.”
Notes from the meeting stated: â[Official] advised if this was the case for us it could be considered a fund to fund transfer and that of KYC [know your customer] perspective that would be made.
A spokesperson for the department said they regularly receive suggestions to improve the functioning of IIP. He said that all of them have been studied.
âThat said, there are no planned changes to the program at this time. However, the position is constantly being reviewed.
The spokesperson said that controls over the program had also been tightened and that the IIP was currently being routinely audited by the department’s internal audit unit.