Developer urged lower investment in cash-for-residence scheme

Bartra also warned donations to charities via scheme are hit by fees and commissions

Developer Bartra asked Tánaiste Leo Varadkar for a temporary reduction in the investment needed for the State's cash-for-residency scheme. It also warned that charitable donations through the scheme were being eaten up in fees and commissions.

The company wrote to Mr Varadkar in January saying the controversial Immigrant Investor Programme (IIP) could be better leveraged to help Ireland recover from the Covid-19 pandemic.

It said the State's cash-for-residency scheme was "underperforming" compared to other EU states and Ireland was missing out on substantial investment. Bartra said Spain, Greece, and Portugal had all generated between 300 and 600 per cent more investment through their immigrant investor programmes in recent years.

The company said Ireland needed to leverage its inbuilt advantages in terms of qualify of life, superior education system, and English-speaking population.

Bartra proposed a reduction in the investment threshold from €1 million to €500,000 for a fixed period of three years for priority sectors of social housing and nursing homes.

It said this would bring the State “through Covid-19 and have greater clarity on Brexit implications”.

Bartra’s letter said current investment thresholds for similar schemes in Spain, Greece, and Portugal were between €200,000 and €500,000.

Bartra said the reduction could deliver €2 billion in annual investment and that the investment threshold could then be subject to a full review after three years.


The developer also warned about complications from a second cash-for-residency option allowing individuals to make a €500,000 donation “which is of public benefit to the arts, sport, health, culture, or education”.

Bartra said it had charged zero fees on any donations it had facilitated but that the amount of money that eventually goes to the charity is impacted by “fees, commissions, or rebates”.

Bartra proposed that a mandatory €50,000 endowment be made on every single investment through the IIP with a prohibition on payment of fees, commissions, or rebates.

The email was forwarded by the Tánaiste to the Department of Justice which administrates the scheme and it has now been released under Freedom of Information.

Separately, notes of meetings between Bartra and the department detail discussions between the company and officials about the scheme.

In March 2019, Bartra founder Richard Barrett and two colleagues met two department officials where they discussed how the IIP was working in different markets.

In Hong Kong, residents had "historically favoured" countries like the United States and the United Kingdom but ex-pats were "looking at options". The note said people there were "highly mobile" and Bartra had responded by moving to online marketing.

Also discussed was the need for “greater transparency” about the scheme with a move to publication of all projects to stop perception that some appeared favoured over others.

Bartra also asked about having a dedicated appointment system for investors with the department. A note of the meeting said: “We cannot provide appointments. The registrations office are aware of the limitations of their systems.”

Department officials also flagged a designated investor fund through which Chinese nationals were believed to be placing money “as a way of getting money out of China”.

Notes of the meeting said: “[Official] advised if this was the case for us, it could be seen as a fund-to-fund transfer and that from the KYC [know your customer] perspective that would be done.”

A department spokesman said they regularly received suggestions on improving the operation of the IIP. He said all were studied.

“That said, there are no planned changes to the scheme at this time. However, the position remains under constant review.”

The spokesman said controls on the scheme had also been strengthened and that the IIP was currently the subject of a routine audit by the department’s internal audit unit.