Three years after the 2023 reform, we now have a clear picture of the future of the Portuguese Golden Visa programme. The major change in 2026 does not concern the investment routes, but rather access to Portuguese nationality, which now requires a longer period of residence.
Obtaining a Golden Visa through real estate investment ceased to be possible in October 2023. However, several other highly attractive options remain available.
Ultimately, the more apocalyptic predictions that anticipated the end of the Golden Visa in Portugal have not materialised.
Investors may continue to apply for a Golden Visa with the possibility of:
Regarding this final point, it should be emphasised that the minimum stay requirements for maintaining the Golden Visa do not, in themselves, imply tax residence in Portugal. Access to IFICI requires effective tax residence under the general rules of the Portuguese PIT Code and that the individual has not been resident in Portugal during the previous five years.
For expatriates intending to relocate to Portugal, we would also note that several other residence permits are available, including the D2, D3, D7 and D8 (remote work/digital nomad visa).
The main difference between these permits and the Golden Visa is that there is no mandatory minimum investment requirement to apply for them, although applicants must demonstrate income or an activity in Portugal. They do, however, require effective presence in the country: a residence permit may be cancelled if its holder is absent from Portugal, without valid justification, for 6 consecutive months or 8 non-consecutive months during the validity period of the permit.
ACQUISITION OF UNITS IN NON-REAL-ESTATE INVESTMENT FUNDS
Capital transfers of € 500,000 or more intended for the acquisition of units in non-real-estate collective investment undertakings incorporated under Portuguese law. At the time of the investment, these funds must have a maturity of at least five years, and at least 60% of the value of the investment must be invested in commercial companies with registered offices in Portuguese territory;
INVESTMENT IN COMMERCIAL COMPANIES WITH REGISTERED OFFICES IN PORTUGUESE TERRITORY
Capital transfers of € 500,000 or more intended to incorporate a commercial company with its registered office in Portuguese territory (i.e., mainland Portugal, Madeira or the Azores), together with the creation of five permanent jobs; or to increase the share capital of an existing commercial company with its registered office in Portuguese territory, together with the creation or maintenance of jobs, with a minimum of five permanent positions for a minimum period of three years;
JOB CREATION
Creation of at least 10 full-time jobs;
INVESTMENT IN SCIENCE AND TECHNOLOGY
Capital transfers intended for research activities carried out by public or private scientific institutions that are part of the national scientific and technological system. The minimum transfer amount is €500,000. The minimum investment amount is reduced by 20% for investments made in low-density areas;
ARTISTIC PRODUCTION AND NATIONAL CULTURAL HERITAGE
Capital transfers of € 250,000 or more may be made to support investment in or artistic production, as well as the recovery and maintenance of national cultural heritage, through certain entities carrying out projects relating to artistic production or to the recovery and maintenance of national cultural heritage. The minimum investment amount is reduced by 20% for investments made in low-density areas.
Since 7 October 2023, the date on which Law No. 56/2023 of 6 October (the Mais Habitação programme) entered into force, it has no longer been possible to submit Golden Visa applications through the following investments:
It should be noted that foreign nationals and non-residents in Portugal may continue to acquire Portuguese real estate. The only change concerns the possibility of using such transactions as a route to the Golden Visa. Residence permits already granted on the basis of these investments were not affected and may continue to be renewed.
The period of legal residence required for naturalisation has been extended from 5 to 7 years for nationals of Portuguese-speaking countries and Member States of the European Union, and to 10 years for all others. The relevant period now also begins from the date the residence permit is issued, rather than from the date of application, and integration requirements, such as knowledge of the Portuguese language and culture, have been strengthened.
For those primarily seeking a second residence in the European Union, the Golden Visa remains an attractive solution. Those whose main objective is Portuguese nationality should, however, take this timeframe into account, although Portugal continues to have one of the European Union’s more open regimes for acquiring nationality, both in terms of the applicable timeframes and the possibility of holding dual nationality.
Since the 2023 amendments, eligible investments have ceased to include the real estate sector and demand has shifted towards the alternatives that remain available, with the acquisition of units in non-real-estate investment funds standing out in particular.
In addition to its track record in residence permit procedures, NEWCO has extensive expertise in incorporating Portuguese companies, both in Madeira and mainland Portugal, as well as a broad network of trusted partners in the investment fund and private equity sectors and experience in the tax structuring of individuals relocating to Portugal, including under IFICI.
We’ll analyse your situation, identify the most suitable investment option and guide you through the entire process, from the application to tax compliance.
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