Regional Advisory Hub
Australia and New Zealand
Oceania Research Hub: Tax Residency, ATO Reporting and Outbound Diversification
An advisory reference for Australian and New Zealand citizens and residents examining São Tomé & Príncipe citizenship, with attention to residency-based taxation and outbound reporting.
Last updated · Source: Citizenship by Investment Unit (CIU), Decree Law No. 07/2025
01 — Executive Summary
Investment migration in Australia and New Zealand
Australia and New Zealand are mature outbound markets with a distinctive profile. Both tax on residence rather than nationality, both recognise dual citizenship, and both maintain highly documented financial systems that make source-of-funds verification straightforward. Demand is driven by mobility, family planning and geographic diversification rather than by tax.
Geography recurs in every conversation. Both passports are strong, but distance from Europe, Africa and the Americas means families with international interests hold assets, children in education and business relationships on the other side of the world. A citizenship in the Atlantic sphere is framed as a hedge against that concentration.
Succession is the second driver. Both countries have large migrant-origin populations whose second and third generations hold no status outside Oceania. Investment migration restores an inheritable status that can pass to descendants — a point that weighs heavily with family businesses.
The practical appeal of the São Tomé & Príncipe Citizenship by Investment Programme here is that nothing requires attendance. From Sydney, Melbourne or Auckland, an interview or residency visit is a real cost. There is no interview, no language test and no travel requirement, and the published review window is approximately 8 weeks.
02 — Applicant Profiles
Who typically applies
- Business owners and SME principals
- Owners of established Australian and New Zealand businesses with export, supply-chain or client relationships across Asia, Europe and Africa.
- Family offices and SMSF-adjacent structures
- Families managing intergenerational wealth who treat legal jurisdiction as one more diversification axis alongside asset class and currency.
- Mining, resources and agribusiness principals
- Operators with African and Latin American project exposure, where a second document has direct operational relevance.
- Retirees and pre-retirees
- Planning extended overseas periods and preferring permanent status to a sequence of renewable visas.
- Migrant-origin families
- Second and third-generation households re-establishing a status outside Oceania for their children.
- Global executives
- Senior professionals on rotation through Asia, the Gulf and Africa.
- Digital entrepreneurs
- Remote-first owners for whom a fully remote application is decisive.
03 — Rationale
Why applicants choose São Tomé & Príncipe
- Geographic diversification
- An Atlantic and Lusophone anchor reduces the Oceania concentration in a family's legal and travel arrangements.
- No travel requirement
- No travel to São Tomé & Príncipe is required at any stage. At this distance from any programme jurisdiction, that is a substantive saving.
- Family inclusion
- Spouse or de facto partner, financially dependent children under 30, and financially dependent parents and grandparents aged 55 and over.
- Tax considerations (high level)
- Both countries tax on residence. A further citizenship does not alter residency, which turns on the resides test, domicile and the 183-day rule in Australia, and permanent place of abode and day-count tests in New Zealand.
- Speed and predictability
- A published fee schedule and a defined review window of approximately 8 weeks, against multi-year residence-then-naturalisation routes.
- Inheritable status
- Citizenship is granted for life and passes to descendants — the central attraction for family-business applicants.
- De facto partner recognition
- The dependant definition expressly contemplates a de facto partner, matching how relationships are recognised under Australian and New Zealand law.
Note: this hub is a research resource. It does not constitute legal, tax or immigration advice, and readers should obtain qualified professional advice in their country of nationality and residence.
04 — Fact Box
Key programme facts
All figures are published government amounts, held in a single canonical data layer and reconciled against Decree Law No. 07/2025.
- Qualifying route
- National Development Contribution (NDC)
- Minimum contribution
- US$90,000
- Indicative all-in cost
- US$100,750 single · US$108,000 family of four
- Submission fee
- US$5,000 per application
- Processing fee
- US$5,000 per application
- Document issuance
- US$750 per applicant
- Processing time
- 8 Weeks
- Minimum age
- 18 years
- Dependants
- Spouse, children under 30, parents and grandparents 55+
- Residency requirement
- None
- Dual citizenship
- Recognised
- Administering authority
- Citizenship by Investment Unit (CIU)
A single contribution route to the National Transformation Fund.
Single applicant. Family schedules are published in full on the programme page.
Contribution plus government submission, processing and document issuance fees.
Government Due Diligence is included within the Submission Fee — it is not charged as an additional fee.
Covers passport, national identification card, citizenship certificate.
From formal submission of a complete application to government decision.
Clean criminal record and verifiable lawful source of funds.
Financial dependency applies to children, parents and grandparents.
No travel to São Tomé & Príncipe is required at any stage.
Citizenship is granted for life and is inheritable by descendants.
Established under Decree Law No. 07/2025.
05 — Timeline
Typical applicant journey
Stage 1
Weeks 1–2
Engagement and preparation
An authorised agent is appointed, preliminary compliance screening is completed and the documentary file is assembled: identity and civil status records, police clearances and lawful source-of-funds evidence. Delay in investment migration originates here far more often than in government review. File quality at this stage largely determines the overall timeline.
Stage 2
Weeks 2–8
Submission and government review
The completed application is lodged with the Citizenship by Investment Unit (CIU). Review and Government Due Diligence run concurrently, not in sequence. Government Due Diligence is included within the Submission Fee — it is not charged as an additional fee.
Stage 3
Weeks 8–10
Approval in Principle and contribution
On a favourable decision, Approval in Principle is issued and the National Development Contribution (NDC) is remitted to the National Transformation Fund with any outstanding government fees. Dependants may be added after this point under a published post-approval schedule.
Stage 4
Weeks 10+
Registration and document issuance
Citizenship is registered and the passport, national identification card, citizenship certificate are produced and delivered. The entire process is conducted remotely — no travel to São Tomé is ever required.
The full stage-by-stage account is set out on the government process page.
06 — Regional Considerations
Matters specific to Australia and New Zealand
Tax residency
Australian tax residency rests on the ordinary concepts test and the statutory tests, including domicile and the 183-day rule. New Zealand applies a permanent place of abode test with a 183-day rule. None refers to citizenship, so a second nationality does not change residency in either country.
Changing tax residency requires a genuine change in the underlying facts — where a person lives, where the family and home are, where economic interests are centred — and can trigger capital gains consequences on ceasing residency. Take qualified advice before acting.
ATO and IRD reporting
Both countries participate in the OECD Common Reporting Standard, and institutions collect self-certifications of tax residency. Because reporting follows residency, an additional citizenship does not change what is reported. Self-certifications should still be updated where terms require disclosure of all nationalities.
Australian residents with foreign income, foreign companies or foreign trusts have existing disclosure obligations, including under the controlled foreign company and foreign trust rules. A second passport leaves these untouched.
Outbound investment and transfers
Neither country operates exchange controls, but reporting applies. In Australia, international funds transfer instructions are reportable to AUSTRAC by the sending or receiving institution regardless of amount; New Zealand applies its own reporting rules. Expect the bank to ask the purpose of the transfer, and be able to document it plainly.
Dual citizenship and public office
Australia has permitted dual citizenship since 2002 and New Zealand permits it generally. Australians should note the disqualification of dual nationals from the federal Parliament under section 44 of the Constitution — narrow, but relevant to anyone in or contemplating public life.
Professional advice
This hub is a research resource, not legal or tax advice. Consult a registered Australian tax agent or a New Zealand chartered accountant on residency and reporting before applying.
07 — Comparison
São Tomé & Príncipe in context
Investment migration programmes differ in legal effect, cost and timeline. The table below states published positions only; entry figures exclude government fees and professional costs unless indicated, and every programme is subject to change.
| Programme | Type | Entry level | Indicative timeline | Notes |
|---|---|---|---|---|
| São Tomé & Príncipe — National Development Contribution (NDC) | CBI | US$90,000 | ~8 weeks | Single contribution route; remote application; CPLP member state; programme established 2025. |
| Vanuatu — Development Support Programme | CBI | From US$130,000 | ~1–3 months | Long-established Pacific programme; visa-free access to the EU/Schengen area was suspended for Vanuatu passport holders in 2024–2025. |
| St Kitts & Nevis — Sustainable Island State Contribution | CBI | From US$250,000 | ~4–6 months | Oldest CBI programme (1984); mandatory interview; higher entry threshold following the 2024 Caribbean price harmonisation. |
| Dominica / Antigua / Grenada | CBI | From US$200,000–US$235,000 | ~4–8 months | Caribbean contribution routes; Grenada holds a US E-2 treaty, the only Caribbean CBI to do so; all subject to EU visa-suspension review. |
| Malta — Citizenship by Naturalisation for Exceptional Services | Hybrid | From ~EUR 690,000 plus residence period | 12–36 months | EU citizenship; ruled unlawful by the Court of Justice of the EU in April 2025 and consequently discontinued in its previous form. |
| Portugal — Golden Residence Permit | RBI | From EUR 250,000 (cultural donation) or EUR 500,000 (regulated funds) | 18–36 months to residence | Residence, not citizenship; real-estate route closed in 2023; naturalisation requires a qualifying residence period and language attainment. |
Regional consideration — Australia and New Zealand
Distance is the practical variable for applicants in Oceania. Programmes requiring an interview or in-country attendance — St Kitts & Nevis among the entries above — carry a travel cost from Sydney or Auckland that the table's headline figures do not show. The São Tomé route is completed remotely, so the comparison for this region is best read as fees plus travel rather than fees alone.
Detailed one-to-one analyses are published on the programme comparison pages.
08 — Government Process
How the government administers an application
Submission
Applications may only be lodged through an agent designated by the Citizenship by Investment Unit (CIU); there is no direct-to-government filing channel for private applicants. The submission fee of US$5,000 is payable per application and is non-refundable.
Government review and due diligence
Review is conducted by the Citizenship by Investment Unit (CIU) under Decree Law No. 07/2025. Government review and Government Due Diligence are conducted concurrently by the Citizenship by Investment Unit. Government Due Diligence is included within the Submission Fee — it is not charged as an additional fee. Screening typically encompasses identity verification, criminal-record checks, sanctions and politically-exposed-person screening, adverse media review and verification of the declared source of funds.
Decision and Approval in Principle
A decision is communicated to the agent, who notifies the applicant. Approval in Principle confirms that the government intends to grant citizenship subject to completion of the contribution and remaining fees. The published guidance measures approximately 8 weeks from formal submission of a complete application to government decision.
Contribution
The National Development Contribution (NDC) is remitted after Approval in Principle. Contribution levels are published by household composition, beginning at US$90,000 for a single applicant and rising in defined steps for couples and larger families, with US$5,000 for each additional dependant.
Registration and passport issuance
On receipt of the contribution, citizenship is registered and the document issuance fee of US$750 per applicant covers the passport, national identification card, citizenship certificate. The fee applies equally to adults, spouses, children and infants.
09 — Questions
Frequently asked questions — Australia and New Zealand
Can Australians obtain São Tomé & Príncipe citizenship?+
Yes. Open to applicants of all nationalities except the Democratic People's Republic of Korea. Australian applicants are assessed on the same statutory criteria as everyone else.
Can New Zealand citizens apply?+
Yes, on the same basis. New Zealand law generally permits dual citizenship.
Does Australia allow dual citizenship?+
Since 2002, yes. Australians may acquire another citizenship without losing their own.
Will this change my Australian tax residency?+
No. Residency turns on the ordinary concepts test and the statutory tests, none of which refers to citizenship. Change requires a genuine change in the underlying facts.
Do I need to tell the ATO?+
There is no standalone notification for acquiring a foreign citizenship. Existing obligations on foreign income, companies and trusts continue; confirm your position with a registered tax agent.
Is a de facto partner recognised as a dependant?+
Yes — the dependant definition expressly includes a spouse or de facto partner.
Can I include my parents?+
Yes, where they are 55 or over and financially dependent. Grandparents aged 55 and over qualify on the same basis.
Do I have to travel to São Tomé?+
No travel to São Tomé & Príncipe is required at any stage. 100% remote application.
Can Australian and New Zealand citizens obtain São Tomé & Príncipe citizenship by investment?+
Yes. Open to applicants of all nationalities except the Democratic People's Republic of Korea. Applicants from Australia and New Zealand are assessed against the same statutory criteria as anyone else: age 18 or over, a clean criminal record, and a verifiable lawful source of funds.
How much does the programme cost?+
Contributions begin at US$90,000 for a single applicant. With government fees added, the indicative all-in figure is US$100,750 for one applicant and US$108,000 for a family of four.
How long does approval take?+
Approximately 8 weeks from formal submission of a complete application to government decision. Review and due diligence run concurrently, which is why the window is shorter than in most comparable programmes.
Is there a residency or physical presence requirement?+
None. No travel to São Tomé & Príncipe is required at any stage.
Can the whole application be completed remotely?+
Yes — from engagement to document delivery. The entire process is conducted remotely — no travel to São Tomé is ever required.
Can a spouse be included?+
Yes, and the dependant definition covers a de facto partner as well as a married spouse — a point that matters given how common de facto relationships are in both countries. Evidence of the relationship is assessed as part of the file. A partner may also be added later under a published post-approval fee.
Can children be included?+
Children under 30 qualify where they are financially dependent on the main applicant. Newborns may be added up to one year of age after approval.
Can parents or grandparents be included?+
Yes, where they are aged 55 or over and financially dependent on the main applicant.
What documents are required?+
A complete file generally comprises: valid passport copy; birth certificate; police clearance certificate; proof of address; source of funds evidence; passport-style photographs; marriage certificate (where applicable). In practice the criminal record element is an AFP National Police Check in Australia and a Ministry of Justice criminal record check in New Zealand, and apostilles are issued by DFAT and by the New Zealand Department of Internal Affairs respectively. Both are Hague Convention parties, so consular legalisation is not required.
What documents does a successful applicant receive?+
Passport, National Identification Card, Citizenship Certificate. The issuance fee of US$750 per applicant covers all three, and applies equally to adults, spouses, children and infants.
Is there a separate due diligence fee?+
Government Due Diligence is included within the Submission Fee — it is not charged as an additional fee.
Is an interview required?+
No interview is held at any stage, and no language test is set.
Is a language test or education qualification required?+
Neither. No business experience requirement.
Does São Tomé & Príncipe permit dual citizenship?+
Dual citizenship is fully recognised. Whether an applicant may keep an existing nationality is settled by the law of that country, not by São Tomé & Príncipe.
Is the citizenship permanent and can it be passed to children?+
Citizenship is granted for life and is inheritable by descendants.
Which authority administers the programme?+
The Citizenship by Investment Unit (CIU), under Decree Law No. 07/2025. Contributions are made to the National Transformation Fund.
Can an application be filed directly with the government?+
No. Filing runs through agents designated by the CIU; there is no direct channel for private applicants.
What happens if an application is declined?+
The submission fee of US$5,000 per application is non-refundable and covers Government Due Diligence. The contribution falls due only after Approval in Principle.
Are there nationality restrictions?+
Open to applicants of all nationalities except the Democratic People's Republic of Korea.
Does São Tomé & Príncipe citizenship confer visa-free travel rights automatically?+
Visa policy is set unilaterally by each destination and changes over time. No passport should be acquired on a mobility figure alone; verify current entry requirements for the destinations that matter to you, at the time you travel.
Is São Tomé & Príncipe a member of the CPLP?+
Yes. The Community of Portuguese Language Countries has nine member states: Portugal, Brazil, Angola, Mozambique, Cabo Verde, Guinea-Bissau, Equatorial Guinea, Timor-Leste and São Tomé & Príncipe. Guinea-Bissau's membership was suspended in December 2025. Membership frames cooperation between states; it confers no automatic residence rights on individuals.
Does acquiring citizenship change where a person pays tax?+
Not by itself. Australia and New Zealand both tax on residence, and neither residence test refers to nationality; a change requires a change in the underlying facts, such as where a person lives and keeps their home and family. Existing obligations on foreign income, controlled foreign companies and foreign trusts continue unaffected. Confirm your position with a registered tax agent or chartered accountant before applying.
The complete programme FAQ library is maintained on the FAQ page.
10 — Research Resources
Further reading on CBI.ST
- Programme Overview
Legislation, qualifying route and the full published investment schedule.
- Government Process
The four-stage application timeline from engagement to document issuance.
- Benefits and CPLP Access
Mobility, family inclusion and the Lusophone dimension of the programme.
- Frequently Asked Questions
The full programme FAQ library, maintained against the canonical data layer.
- Programme Comparisons
Side-by-side analysis against other CBI and RBI programmes.
- Research and Analysis
Long-form articles on programme developments and regulatory change.
- About the Agent
Designation, governance and the firm's standing with the CIU.
- Enquiries
Confidential assessment of eligibility and household composition.
11 — Glossary
Investment migration terminology
- Citizenship by Investment (CBI)
- A statutory pathway under which a sovereign state grants citizenship in return for a qualifying economic contribution, subject to due diligence and legislative conditions.
- Residence by Investment (RBI)
- A pathway granting residence rights — not citizenship — in return for investment. Naturalisation, where available, generally requires years of physical presence.
- National Development Contribution (NDC)
- The qualifying route of the São Tomé & Príncipe Citizenship by Investment Programme: a non-refundable contribution to the National Transformation Fund.
- Approval in Principle (AIP)
- A government decision confirming intent to grant citizenship, conditional on completing the contribution and outstanding fees.
- Government Due Diligence
- The state's independent vetting of an applicant. In this programme it is conducted concurrently with review and is included within the submission fee.
- Source of funds
- Documented evidence of how the applicant's wealth used for the application was lawfully generated — employment, business proceeds, investment gains, inheritance or sale of assets.
- Source of wealth
- The broader documented history of how an applicant's total net worth was accumulated, distinct from the specific funds used for an application.
- Politically Exposed Person (PEP)
- An individual entrusted with a prominent public function, or their close associate or family member, subject to enhanced scrutiny under international AML standards.
- Dependant
- A family member included in an application. Here: a spouse or de facto partner, financially dependent children under 30, and financially dependent parents and grandparents aged 55 and over.
- Dual citizenship
- The simultaneous holding of two or more nationalities. Whether a person may retain their existing nationality is determined by that country's law, not by São Tomé & Príncipe.
- CPLP
- The Community of Portuguese Language Countries — an intergovernmental organisation of Lusophone states including Portugal, Brazil, Angola, Mozambique and São Tomé & Príncipe.
- Visa-free access
- Entry to a destination without a pre-issued visa. Access is set unilaterally by each destination and can change; it is never guaranteed by a passport alone.
- Tax residency
- The jurisdiction entitled to tax a person's income, determined by domestic law tests such as presence, domicile or centre of vital interests. Citizenship and tax residency are distinct concepts.
- CRS
- The OECD Common Reporting Standard for the automatic exchange of financial account information between participating jurisdictions. Reporting follows tax residency, not passport-holding.
- Designated agent
- A firm authorised by the Citizenship by Investment Unit (CIU) to prepare and submit applications. Private applicants cannot file directly.
Enquiries
Assessment for applicants in Australia and New Zealand
Eligibility, household composition and documentation are assessed confidentially. Indicative costs run from US$100,750 for a single applicant, based on a US$90,000 contribution, with government review of approximately 8 weeks.
Request an assessment