This is actually a brilliant move by the club to get him a work permit, and the reasons are that a lot of the points in the appeals system are based on your importance to the club you join.
The biggest difference maker will be his wages. Here are the possible points a player can get -
3pts - Fee is in the top 25% of all PL transfers this summer.
2pts - Fee is in the top 50% of all PL transfers this summer.
3pts - The wages are in the top 25% at the club.
2pts - The wages are in the top 50% at the club.
1pt - The players current club is in a top league and he played 30% or more games.
1pt - the players current club is in European competition and played 30% of games.
At Villa, Luiz will probably be in the top 25% of earners, so that gets him 3pts straight away. You only need 4 points to get through so it's a game changer.
He should get at least 1 for playing in a top league last year, and probably £15m will be in the top 50% of transfers, so that'll be 2.
Which would give him 6 points. At City he'd only get 1 - for playing fir Girona.
But the great thing is that once he gets his work permit at Villa, they can't take it away easily, so if we have a cheap buyback clause we can get him back next season and he'll be able to play for us.