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Playing field not level when it comes to emigration



In 2023, South Africans are among many worldwide considering their emigration options.

Gallup International’s 2022 study posed a hypothetical question, “If you were given all the necessary paperwork, would you like to live in another country, or would you prefer to remain where you are?”

The answer was revealing, with 36% of global respondents expressing a desire to migrate. Notably, this inclination was more pronounced among the youth and individuals from lower-income nations, especially in sub-Saharan Africa and Latin America. However, for many, migration remains a distant dream due to the multifaceted barriers they face.

The American online remittance service, Remitly, highlighted Canada, Australia, the United States (US), and the United Kingdom as top international relocation preferences. What factors make these destinations so attractive in 2023? Or rather, what do these countries look for in prospective immigrants, and how do their immigration systems and policies differ?

In the North American context, the US is more conservative in its immigrant acceptance compared to Canada. Projections suggest that by 2025, the US will welcome only three immigrants per 1 000 residents, a stark contrast to Canada’s ambitious 12.5. This is underscored by Canada’s declaration last year to admit a staggering 1.45 million new permanent residents by 2025.

For perspective, Canada’s entire population is about 40 million. A fundamental difference between the two is their immigration focus: Canada leans heavily towards economic immigrants, whereas the US prioritises family reunification.

Breaking down the statistics: Canada recently reported that 60% of its new immigrants were economic immigrants, with family class immigrants making up 25% to 30%.

In the US, the scales tip differently. Almost two-thirds of the immigrants are family-based, while only 13% to 15% arrive under employment-related provisions. US immigration attorney David Garson provides a nuanced perspective. “An ideal immigrant would have at least a bachelor’s degree and experience in a STEM [science, technology, engineering, and mathematics] field. However, as with other countries, there’s a shortage of qualified individuals for skilled labour. The government hasn’t done much to open immigration avenues for these types of people.”

Garson further cautions about changes to the US immigration system, “I don’t foresee immigration becoming more lenient, as most are aware it’s a politically charged topic. Making it more lenient can create a perception of ‘weakness’ that’s exploited in the media.”

Canada’s immigration strategy emphasises economic factors. It pioneered a points-based system in 1967. This system allows individuals to attain permanent residency without previous Canadian visits or job commitments. Those with strong English and French language skills, in their 20s or early 30s, and with higher educational qualifications and professional skills are favoured. Every two weeks, an Express Entry draw is held. Those assigned the announced minimum score receive an Invitation to Apply for permanent residency.

Daniel Mandelbaum, a Toronto-based Canadian immigration attorney, categorises prospective economic immigrants as either “fortunate” or “economically enabled risk-takers”. Mandelbaum elaborates, “By ‘fortunate’, I mean circumstances align such that a prospective immigrant meets the criteria of an immigration programme. For example, finding a life partner who’s Canadian; securing a job offer from an employer willing to support immigration; or qualifying as a skilled immigrant with in-demand skills.

Those with significant savings and a risk appetite might “take a significant risk to move to Canada as a temporary resident, spending a lot to make permanent immigration a reality, such as an international student or entrepreneur who hopes their investment in education or business will lead to permanent immigration in the future”, he says.

The OECD’s (Organisation for Economic Co-operation and Development’s) March 2023 report named Canada the most desirable country for start-up founders within the OECD. The US also ranks highly, with a robust start-up ecosystem. However, spouses of start-up founders in the US don’t have full access to the labour market, and there’s no direct route from a start-up visa to permanent residency.

Though New Zealand is a sought-after country for immigration, it’s not particularly friendly to those wanting to start a business. “A common misconception is that if you plan to start a business in New Zealand, there’s a clear immigration pathway,” says Christchurch-based immigration attorney Nicola Tiffen. “For most, this isn’t the case. New Zealand does have a visa category for business setup, but it’s challenging to secure, with many applications being declined.”

New Zealand’s immigration system favours highly skilled foreigners with local job offers, preferably in occupations on its green list. Alternatively, it’s highly beneficial to receive a job offer with a salary at least twice the median wage. Tiffen notes the advantage of New Zealand’s immigration system is its faster processing times due to the country’s smaller size.

Sydney-based immigration attorney Phillip Yip says, “Australia’s immigration system is designed for an annual intake of about 190 000 migrants. The numbers break down to about 70% skilled migrants and 30% family-related migrants.” He describes the ideal immigrant to Australia in 2023 as someone with recognised post-high school qualifications, under 45, with at least two years of relevant full-time work experience, acceptable English proficiency, and no health or character issues.

This year, there was a comprehensive review of Australia’s migration system, recommending significant reforms. “The government has recognised the failings and promises structural change to attract and retain the best talent. I predict more lenient immigration processes in the future,” says Yip.

Michel Soler, the director of private clients for Latin America at Henley & Partners, a firm specialising in residence and citizenship by investment (RCBI), says, “Investment migration is now more attractive than ever for wealthy individuals, successful entrepreneurs, and business owners aiming to expand their personal rights, mitigate risk, and maximise optionality.”

He outlines some advantages of RCBI: flexibility, with minimal physical presence requirements to maintain status, inclusion of qualifying dependants beyond core family members, and attractive tax regimes. “For residency by investment, contrary to popular belief, options may start at about €50 000 [R1.014 million]. For citizenship by investment, options start at $100 000 [R1.9 million] minimum. Investment for a single applicant and can rise to more than $1 million [R19 million].” However, such programmes are frequently changing, so getting in while they are open is critical, as they may not be in the future.

“While some programmes have closed this year, such as Ireland, others are raising investment thresholds, such as Greece, or restricting investment routes, like Portugal.”

As someone who assists individuals worldwide wanting to migrate but uncertain about their options, I offer three primary pieces of advice: first, set aside savings – immigration and start-up expenses can easily run into tens of thousands of dollars; second, acquire a high-demand skill that isn’t tightly bound by regional regulations; and third, pursue any citizenships you may qualify for because of ancestry. Such ancestral citizenships can sometimes simplify migration to a third country, leveraging free-trade agreements associated with your citizenship by descent.

  • Dan Brotman is the founder of Rootless Mobility, a migration consultancy that assists clients uncertain about their emigration options. Dan holds citizenship of South Africa, the US, Israel, and will soon add Canada to the list.

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