Golden Visas in Europe: Top 3 EU Residence Programs
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Contents
- What Exactly is a Golden Visa Program?
- What Makes a Golden Visa Better Than Other Residencies?
- Drawbacks of a Golden Visa?
- The Golden Visa Process
- How to Qualify for a Golden Visa Program
- Who Would Do Best with a European Golden Visa?
- The Trend in Golden Visa Programs
- Alternatives to Golden Visa Programs
- Top 3 European Golden Visa Programs
- #1: Greece
- #2: Portugal
- #3: Spain
- Other Golden Visa'ish Option
- Latvia
- Cyprus
- Italy
- FAQ
- Need Help?
When many of our clients think about residency in Europe, they often think about “Golden Visa” programs. That’s especially true of programs in Greece, Spain, and the most famous of all, Portugal.
But the truth is, a “Golden Visa” is nothing more than a residency by investment program. In that, many European countries offer such a path. They just don’t all call it a Golden Visa; that’s more of a marketing term.
In this article, I’ll explain the key benefits and drawbacks to such programs. We’ll also dive into the main Golden Visas in Europe, and the best alternatives to them, too.
What Exactly is a Golden Visa Program?
As mentioned earlier, a Golden Visa is simply a marketing term for getting residency in exchange for an investment and/or donation of some sort. They’re specifically built to attract foreign investors.
Although many countries in Europe have such programs, only a few—including Spain, Portugal, and Greece—actually use the term. The ones that do tend to share a couple of features in common including:
Minimal on the ground requirements.
A potential path to citizenship.
Tax opportunities.
Once you qualify for the visa, you’re awarded either temporary or permanent residency. Some programs allow you to rollover your residency over and over again. Others put you on the path to citizenship if you want that.
What Makes a Golden Visa Better Than Other Residencies?
The attraction of European Golden Visas to foreign investors is really the flexibility. The most successful programs will let you purchase an asset like real estate with a good chance of earning you a solid return.
Here’s a summary of the key advantages that differentiate these programs from other residency options:
Investment Opportunities
The best Golden Visas aren’t cheap. However, they do offer the possibility to enjoy a solid asset. Often, this isn’t because of the underlying fundamentals but rather because the program itself brings in so much new investment that fuels the rise in prices.
We’ve seen this “virtuous cycle” play out in countries that offered real estate as one of the options.
This cycle is also the reason a growing number of European countries no longer allow a real estate investment to qualify for a Golden Visa—more expensive property means higher prices for locals who are priced out of the market.
Fast-Track Residency
Golden Visa programs typically promise to bypass the regular “slow” path to residency common under other paths. This is usually true—at least in the early days.
But we’ve found that as a program takes off, backlogs are inevitable. For example, Portugal’s application process will take years to clear at this point.
Recently, I came across a brilliant workaround for people who get caught up in a long line. The technique basically moves you to the front of the line if you’re in a rush.
Minimal Physical Presence
Most programs allow for minimal physical presence requirements, meaning that you can keep your residency in good order with no need to spend much (or any) time on the ground.
Path to Citizenship
Most Golden Visa programs provide a pathway to citizenship after a certain period, which includes the right to a passport.
Tax Benefits
Most European countries have higher income tax rates than the US. But some Golden Visa programs offer attractive tax options.
However, it can take some work to make these tax benefits fit into American planning.
How Much Time Should You Spend in a Country if You Want a Passport?
As mentioned, some European Golden Visa programs will put you on a path to citizenship with little or no need to spend time in the country. But should you?
Unlike many of my peers in the business, I usually say no. So much talk in this space tends to treat citizenship like a commodity. They encourage you to get two, three, 10 citizenships if you can.
And I understand where they’re coming from—it’s an insurance policy.
But I personally disagree with this approach. A citizenship is usually a lifetime commitment. Shouldn’t you know what you’re getting into?
There’s also a practical element to this. There’s a certain lifecycle to these programs. At a certain point, the programs get stricter. The more popular it is, the stronger the local backlash and the faster the program changes.
When it leads to qualification for citizenship, local judges and magistrates will start to deny applicants that don’t show enough “commitment” to a country after the residency period, even if the letter of the law says they should qualify.
I’ve seen this personally happen to clients in three countries now.
Drawbacks of a Golden Visa?
They Aren’t cheap
Residency by investment programs, including Golden Visas, are among the priciest ways to gain the right to live, work, study, or retire in another country.
Complex Application Process
They’re hard to do on your own and, in some cases, you aren’t even allowed. Not only that, but language barriers add a whole new level of complexity.
Ongoing Obligations
Some programs have ongoing requirements. You’ll likely have to keep your investment in place for some time. You may also need to spend some time in the country on a regular basis.
Market Risks
In many cases, you’re making an investment (some programs allow a donation instead). Any investment is subject to a drop in value or even loss, i.e. market risk.
Changing Regulations
Immigration policies and Golden Visa programs can change suddenly, which can affect existing visa holders or the attractiveness of the program in the future.
In practice, I’ve rarely seen them change the rules on someone mid-application. They will usually grandfather those people in and apply the revised rules to new applications.
Estate Planning Challenges
Most European Golden Visa programs come from countries that use civil law, a very different legal system than our common law. This makes estate planning that much harder because:
- Civil law doesn’t recognize common law structures like living trusts.
- Many civil law systems have the concept of “forced heirship”, which limits the way you’re allowed to pass assets under their jurisdiction to your chosen heirs.
Investments caught up in these other systems need careful planning for everything to work together properly.
Additional Reporting Requirements and Taxes for Americans
Depending on which investment you make, you’ll be doing more filing to Uncle Sam; forms we’ve found most accountants don’t know how to deal with.
If done right, you shouldn’t owe any extra tax on income from your investment after you pay tax to the country where you made it. But that’s true only if you do your accounting properly.
The Golden Visa Process
Unsurprisingly, the process varies from one European country to another. However, most follow the same basic path.
Step One: Choose a Country That Best Fits Your Needs and Be Clear About the Requirements
When we work with clients, we always start here. If the program doesn’t match what our client wants, what’s the point?
Step Two: Make the Investment
Some countries will allow you to make the investment (or donation in some cases) after the application process starts. Others want you to do it before and include proof in your application.
Step Three: Submit the Golden Visa Application
Your representative in the country will submit your application. Depending on the country, you’ll need to make one or more personal appearances in the country itself or one of its consulates.
Step Four: Wait
Your application will be reviewed by the authorities. If approved, you’ll be given your visa.
Step Five: Apply for Residency
After you get your visa, you’ll likely want to convert it into a residency permit, if necessary. Most programs have a dedicated residency tier that Golden Visa holders automatically qualify for. These special tiers offer the benefits listed above—in particular the minimum presence requirement.
In some cases, you’ll get a temporary residency that you need to convert to permanent residency later. In others, you’ll get permanent residency right away.
What's the Difference Between Temporary and Permanent Residency?
In a Golden Visa program:
- Temporary residency is usually your first step. It allows you to live in the country for a limited time and require you to renew every 1–2 years. You’ll need to maintain your investment (like real estate) and meet whatever physical presence requirements are in place. (Usually none.)
- After some time, you can apply for permanent residency. This brings more stability, fewer renewals, and greater rights. Permanent residency also places you on a path to full citizenship.
Step Six: Apply for Citizenship
Once you fulfill the requirements, you’ll be able to apply for citizenship. Every country does it slightly differently but for the most part, the authorities will expect you to:
- Speak the local language with intermediate proficiency or better.
- Know the basics of the country’s culture and history.
- Show that you’ve spent the required minimum amount of time living in the country.
- Maintain a clean criminal record during your time there.
How to Qualify for a Golden Visa Program
Different countries have different requirements. But here are some of the options:
Invest in Real Estate
Purchase property meeting a minimum value (example: €250,000 in Greece). Some programs will let you get away with less if you invest in certain low-density or rehabilitation areas.
On the flip side, some countries will ask you to pay more if you want to invest in the most popular places, including the locations that most expats target.
Invest in a Business
You can start a business or invest in an existing one. Often, your company must create jobs. This can be a real nuisance in countries with inflexible labour markets where firing employees is very difficult and expensive.
Make a Capital Investment
Some programs let you deposit funds into local banks, purchase government bonds, or invest in approved funds. The amount needed is often higher than other options. But it’s also the most hands-off option.
Make a Donation
Sometimes you can contribute to a national fund, research institution, or cultural project. This is the most hands-off method of all. Of course, you don’t get your money back. (And, for American readers, you generally can’t take a tax deduction for this donation either.)
Mix of Options
Some programs allow a combination of real estate, fund investment, and donations.
Who Would Do Best with a European Golden Visa?
US Citizens Building Their Plan B
We’ve long maintained that a second residency is an essential part of any Plan B. If things start to unravel in your home country, you can relocate more or less permanently to the country in which you have second residency.
And with respect to Europe, residents of many of its constituent countries have a nicer lifestyle and decent public healthcare (with private options if you prefer) than you can find in the US. And with minimal presence requirements, it’s easy to keep your residency in good order without worrying about formally living there unless you want to.
Business Owners and Investors
A Golden Visa allows you to either start or expand your operations in Europe. Although not the most economically vibrant place overall, Europe still offers good opportunities if you know where to look. Having access to that market can be an advantage.
For Those Looking to Live in Europe Without Committing to One Place (Yet)
Because of minimal residency requirements, a Golden Visa can be a great way to dip your toe into Europe without having to commit to a country with stricter immigration processes.
The Trend in Golden Visa Programs
Unfortunately, Golden Visa programs are becoming stricter, with higher investment requirements and more focus on long-term benefits like business creation or donations.
- Some countries, like Ireland, have ended their programs entirely, citing concerns about fairness and local impact.
- Others, like Portugal and Greece, are tightening / have tightened rules by raising investment thresholds or limiting real estate options.
Sometimes these changes happen with little warning
But for clients who act early, they are usually grandfathered in at the old rules. For ones who apply later, they are lumped in with the new rules.
Alternatives to Golden Visa Programs
Golden Visas come with a high upfront commitment, so it’s not for everyone. But there are other options. That includes:
Skilled Migration Visas
If you meet the qualifications, these visas can offer a lower-cost route to residency with work rights. However, they can be hard to get and may come with a lot of bureaucratic hurdles compared to other options.
Entrepreneur Visas
Entrepreneur visas allow you to start or expand a business in the target country. They often require less upfront investment than Golden Visas but demand proof of your business’s viability. You will also need to be there a lot to actively manage the business and be prepared to hire locals.
Digital Nomad Visas
Digital nomad visas really picked up during the COVID years. They let you live and work in a country while earning income from abroad. This option offers flexibility without requiring a significant investment. However, these visas are usually temporary and rarely provide a direct path to residency or citizenship.
Top 3 European Golden Visa Programs
#1: Greece
Investment Options
Greece overhauled their program in 2024 in the face of pressure from the local population to rein in growing housing prices. They now offer four tiers of investment at generally higher minimums than previously:
- Tier One (€800,000 Minimum): Applies to properties in high-demand areas, including the entire Administrative Region of Attica (e.g., Athens), Thessaloniki, Mykonos, Santorini, and the larger Greek islands with populations exceeding 3,100.
- Tier Two (€400,000 Minimum): Covers properties in all other regions of Greece, offering a more accessible entry point for investors targeting less populated areas.
- Tier Three (€250,000 Minimum): Available for commercial properties converted to residential use, regardless of location or size. The conversion must be completed before applying for the visa.
- Tier Four (€250,000 Minimum): Pertains to the restoration of listed buildings, with renovations required to be finalized within five years of residency to renew the visa.
Additionally, the government banned the lease of purchased properties through the Golden Visa scheme as short-term rentals (e.g., Airbnb).
There are also other ways to meet the investment requirements, including:
- Financial Assets (€500,000 Minimum): Investing in Greek government bonds, shares, or units in Alternative Investment Funds (AIFs)* that invest exclusively in Greece.
- Business Ventures (€500,000 Minimum): Direct capital contributions into Greek enterprises to create economic growth and jobs.
*American taxpayers will generally want to avoid AIFs as they are considered PFICs under the US tax regime. That means extra filings and more paperwork to Uncle Sam every year and, unless done properly (which is fairly rare for offshore funds), lousy tax treatment.
Presence Requirements
Greece’s Golden Visa has no minimum stay requirement, allowing you to keep residency without living in country.
Tax Benefits
Greece offers a Non-Domicile Tax Regime, which includes a flat €100,000 annual tax on worldwide income if you transfer your tax residence to Greece. This benefit lasts for up to 15 years and can extend to your family members for an additional €20,000 per person a year.
Because US citizens are taxed on worldwide income, planning is important if you want to benefit from this tax program.
Path to Citizenship
While the Golden Visa provides immediate permanent residency, obtaining citizenship requires seven years of continuous residency. During this period, applicants must also maintain tax residency and pass a Greek language test, making it a relatively challenging path to securing an EU passport.
#2: Portugal
In October 2023, Portugal removed real estate as a qualifying investment for its Golden Visa program—the thing that made it so popular in the first place. Still, other options include:
- Fund Subscription: Invest at least €500,000 in qualified Portuguese investment funds, such as private equity or venture capital funds.*
- Cultural or Artistic Donation: Contribute a minimum of €250,000 to support the arts or the reconstruction of national cultural heritage.
- Scientific Research: Invest at least €500,000 in scientific or technological research conducted by public or private institutions within Portugal’s national scientific and technological system. The threshold drops to €400,000 for research activity in a low-density or low GDP region.
- Business and Job Creation: Create at least 10 jobs by setting up or investing in a Portuguese business.
*Again, US clients will want to avoid investing in foreign funds unless absolutely necessary. They’re a compliance headache.
Presence Requirements
The program officially requires you to spend an average of seven days per year in Portugal to maintain your residency status.
Tax Benefits
For years, Portugal offered a very attractive tax regime for Golden Visa holders that decided to formally move to Portugal and become a tax resident there—the Non-Habitual Residents program. However, in 2023, under pressure from the government opposition, the tax break was ended.
Path to Citizenship
After five years of maintaining your investment and meeting the residency requirements, you may apply for Portuguese citizenship. You’ll need to speak basic Portuguese (level A2 under the Common European Framework of Reference for Languages system).
#3: Spain
Investment Options
Spain’s Golden Visa program offers several investment options:
- Real Estate: Purchase Spanish real estate with a minimum value of €500,000.
- Capital Investment: Deposit at least €1 million in a Spanish bank account or invest the same amount in Spanish companies or investment funds.
- Government Bonds: Invest €2 million in Spanish government bonds.
- Business Projects: Invest in a business project in Spain that creates jobs, contributes to innovation, or has significant socio-economic impact.
Presence Requirements
The program has no minimum stay requirement, allowing you to maintain residency without living full-time in Spain. You only need to visit Spain once during the visa’s validity to renew your status.
Tax Benefits
You won’t become tax resident unless you spend more than 183 days per year in Spain. If you do become a tax resident, your worldwide income becomes subject to Spanish taxation and you’ll have to avoid double taxation using the US-Spain tax treaty and foreign tax credits. Spain doesn’t offer any reduced tax program specifically for Golden Visa holders.
Path to Citizenship
After five years of legal residence, you can apply for permanent residency. Citizenship is available after ten years, provided you meet the residency requirement of living in Spain for at least six months per year and fulfill other conditions, such as Spanish language proficiency. If a second passport if your goal, there are better options out there.
Government Announces Program Cancellation
Earlier this year, the Spanish government announced it wanted to end the Golden Visa program. But Spain’s Senate vetoed the government’s attempt to terminate it, so applications continue to be processed. But there’s a huge backlog of applications in process that may or may not be grandfathered in if the program ends. Still, if your application is approved before the program ends, the conditions applicable to it should be honored.
Other Golden Visa'ish Option
Although Greece, Spain, and Portugal use the term Golden Visa for marketing, the proper term for such program is residency-by-investment. Many European countries offer such an option. Here are a few of the more popular ones:
Latvia
Latvia’s residency by investment program offers a low-cost entry to European residency. You can:
Invest €250,000 in real estate plus a government fee.
Contribute €50,000–€100,000 in a Latvian business (depending on its size) while employing at least 50% local workers.
Make a fixed deposit of €280,000 in a Latvian bank.
This program gives you access to permanent residency after 5 years. However, if citizenship is your goal, you’ll need to reside in Latvia for 10 years and learn the Latvian language.
Cyprus
You qualify by:
Purchasing property worth at least €300,000 (excluding VAT).
Investing €300,000 in a local company or fund.
Permanent residency is immediately granted without renewal requirements, and you can include your family in the application.
Italy
Italy’s investor visa allows you to gain residency by making a significant investment. Options include:
€2 million in Italian government bonds.
€500,000 in an Italian business.
€250,000 in an Italian “innovative startup”.
€1 million as a philanthropic donation to support cultural, educational, or public-interest projects.
If you’re retired or financially independent, the Dolce Vita Visa gives you residency by proving an annual income of €31,000 (higher for families).
Frequently Asked Questions
What is the cheapest European Golden Visa?
Greece was the most affordable Golden Visa program until recently starting at €250,000 with real estate. However, in September 2024, it changed things up substantially.
There are certain opportunities to qualify with property for €250,000 tier. However, that only applies to properties in less-demand regions, commercial properties converted to residential, and restoration projects. High-demand areas are up to €800,000.
Other tracks like business investment and paper assets can be had for €400,000.
What is the best Golden Visa in Europe?
There’s really no such thing as a “best” Golden Visa because it depends on your goals and what you’re hoping to achieve.
But Portugal’s Golden Visa is generally considered the most well rounded. You don’t have to spend much time in country, there’s a path to citizenship in as little as five years.
Which European Golden Visa is the easiest to get?
No matter how you slice it, you’re dealing with government bureaucracy so the answer is none. But Greece has a reputation for the being one of the most well run programs.
Which European countries offer Golden Visa programs?
“Golden Visa” is a marketing term that is often used to talk about the European residency by investment programs of Greece, Portugal, and Spain.
However, other European countries also have attractive residency by investment programs including Cyprus, Italy, and Latvia.
What are the different types of European Golden Visa programs?
Golden Visa programs typically offer several investment paths, such as:
- Real Estate Investment: Buying property.
- Capital Investment: Investing in funds, bonds, or businesses.
- Donations: Contributing to cultural or public-interest projects.
- Business Creation: Starting or expanding a business that creates jobs.
Did Spain get rid of their Golden Visa?
Spain has not eliminated its Golden Visa program but the government has announced it wants to phase it out. The program continues, but if you’re interested, you should act now. We expect it will end in early 2025.
Did Portugal get rid of their Golden Visa?
Portugal significantly changed its Golden Visa program in 2023 by removing real estate purchases as a qualifying option. Other pathways like fund investments and donations are still available.
Does France have a Golden Visa program?
France doesn’t have a traditional Golden Visa program. Instead, you can explore the “Talent Passport” (Passeport Talent), designed for non-EU nationals. If you’re an investor, you’ll need to make a direct investment of at least €300,000 in a French business and commit to creating a certain number of jobs within four years.
What happened to Ireland's Golden Visa?
Ireland officially ended its Golden Visa program, known as the Immigrant Investor Programme, in 2023. The decision was made in the face of EU pressure as well as a big question whether the program was bringing the economic benefits promises.
However, everyone already in the program was allowed to continue their application; new applications are no longer being accepted.
Need Help?
Golden Visa programs represent a great opportunity to get a second residency, potentially a path to a second passport, and even lower your tax bill. But they can be complicated and hard to figure out.
We’re here to help, of course. If you’re interested in one of these programs, please feel free to book in a call with one of our Associates to discuss further.
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We have 40+ years experience helping Americans move, live and invest internationally…
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