The Golden Visa, a scheme established, probably for the first time in 1984, by Saint Kitts and Nevis in the Caribbean, is today a powerful wealth management instrument allowing nationals of third-party states to obtain a residence permit — or, depending on the jurisdiction, citizenship — in exchange for a qualifying financial contribution to the host country.
However, the growing regulatory complexity surrounding these "citizenship by investment" programs, combined with pressure from supranational bodies to tighten their oversight, increasingly requires applicants to demonstrate genuine ties to their chosen country — a far cry from what was previously expected.
Indeed, the instability of European migration policies — illustrated by the closure of Spain's program in April 2025 and Malta's condemnation by the Court of Justice of the European Union that same month — underscores the critical importance of having a coherent strategy.
This article provides a current overview of the main active Golden Visa programs around the world, based on available information and subject, sometimes, to quick changes and evolutions, as we speak.
Origins and reasons: from crisis response to long-term planning
The concept of residence by investment, while historically rooted in the 1980’s, found its true European momentum in the aftermath of the 2008 financial crisis.
Countries such as Portugal, Spain, and Greece used these mechanisms to attract massive foreign direct investment aimed at recapitalizing their shattered economies.
The results were unambiguous: between October 2012 and the end of 2024, Portugal's program alone mobilized approximately €7 billion and granted legal residency to nearly 15,000 investors and their families.
The fundamental distinction between RBI and CBI
Before going further, a clarification of terminology is essential, as confusion between these two concepts leads to costly strategic mistakes:
- The Golden Visa (RBI – Residence by Investment) offers a renewable residence permit and, for EU member states, freedom of movement within the Schengen Area. It does not automatically confer citizenship. Naturalization remains subject to strict criteria of effective residence and, often, language and civic integration tests.
- The Golden Passport (CBI – Citizenship by Investment) allowed, in certain states, direct acquisition of nationality without any prior effective residence requirement. It is precisely this model that has been condemned by the most recent European case law.
Regarding CBI, the CJEU ruling of April 29, 2025 (Case C-181/23, Commission v. Republic of Malta) represents a landmark turning point in European jurisprudence. The Court held that a member state cannot grant its nationality — and thus European citizenship — in exchange for predetermined payments or investments.
The Schengen area: an analysis of key jurisdictions
The European landscape has been profoundly reshaped between 2023 and 2026.
Spain, after years of a popular program, officially closed its doors on April 3rd, 2025, citing the need to combat the housing crisis in Madrid and Barcelona.
Ireland and Cyprus had already suspended their schemes under the dual pressure of the European Commission and the Financial Action Task Force (FATF).
The map of available options has therefore narrowed, making careful selectivity and rigorous analysis even more essential.
Portugal
Portugal remains, in 2026, the leading destination in Europe for residence-by-investment candidates. Its singularity lies in a rare combination: among the world's lowest physical presence requirements, a pathway to European citizenship within five years, and institutional stability.
Since the reform came into force, the direct real estate route has been closed. Investors must now channel their capital into venture capital funds (FCRs), supervised by the CMVM (Portuguese Securities Market Commission), with at least 60% of the capital invested in companies headquartered on national territory.
The minimum investment threshold is €500,000, with a minimum holding period of five years — aligned with the cycle required to initiate a naturalization application. An alternative remains: a cultural donation of €250,000 (reduced to €200,000 in low-density areas) to public entities or recognized public-interest foundations. This amount is non-refundable, which fundamentally distinguishes it from the fund investment route.
One important caveat must be noted. In June 2025, the Portuguese government proposed an amendment to the nationality law that, if enacted in its current form, would extend the residency period required to apply for naturalization from five to ten years for most non-EU nationals.
The Constitutional Court rejected four of the seven proposed amendments in December 2025.
At the time of writing, the legislative situation remains in limbo, with the text awaiting presidential promulgation. Applicants must closely monitor developments in this area and consult their legal counsel regarding the rules in force at the time of their eligibility.
Greece
Greece has established itself, since the closure of Spain's program in 2025, as the last major active real estate investment residency program in Europe.
Greek immigration law now distinguishes two main investment zones:
- "Premium" zones, encompassing Athens, Thessaloniki, Mykonos, Santorini, and islands with more than 3,100 inhabitants, require a minimum investment of €800,000.
- All other regions require a threshold of €400,000. An exception remains at €250,000 for commercial-to-residential conversion projects and for the restoration of listed historic buildings. These thresholds are accompanied by a minimum floor area requirement of 120 square meters for the acquired unit.
A fundamental operating constraint has also been introduced: properties acquired under the Greek Golden Visa may not under any circumstances be listed for short-term rental on platforms such as Airbnb. Violation of this prohibition exposes the holder to an administrative fine of €50,000 and immediate revocation of the residence permit. Long-term rentals, however, remain permitted.
Also worth mentioning is the new startup investment route, introduced by Law 5162/2024: an investment of €250,000 in a company registered under the government's Elevate Greece program grants a five-year residence permit, provided the investor holds less than 33% of voting rights and the company creates at least two jobs within the first year.
Hungary
Launched in July 2024, Hungary's Guest Investor Program has quickly established itself as the fastest and most stable option in Central Europe. Its primary appeal lies in the simplicity of its mechanism: an investment of €250,000 in real estate funds approved by the Hungarian National Bank grants a ten-year residence permit with no minimum physical presence requirement. This long-term, renewable visa offers unmatched stability within the Schengen Area for investors whose mobility strategy does not require immediate physical anchorage.
Italy
Italy does not offer a traditional real estate Golden Visa, but rather an "Investor Visa for Italy" — also known as the "Dolce Visa" — conditioned on investments in innovative startups, Italian companies, government bonds, or donations to cultural or scientific philanthropic projects.
Its true competitive advantage lies in its combination with the so-called "High Net Worth Individual" (HNWI) tax regime, which allows foreign tax residents to pay a flat annual lump sum of €300,000 (since 2026) on all their foreign-source income, regardless of its actual amount.
For an investor with significant worldwide income, the tax savings can be substantial and may alone justify choosing Italy as a primary jurisdiction of residence.
United Arab Emirates (UAE)
The required investment is approximately AED 2 million (roughly USD 545,000), achievable through real estate acquisition or a qualifying bank deposit.
The advantages of this jurisdiction are considerable: complete absence of personal income tax, dividend tax, and capital gains tax on worldwide income; no minimum stay required to maintain an active visa; and a stable regulatory framework that compares favorably with European legislative volatility.
Singapore and Hong Kong
Singapore stands out for the strength of its passport, which is regularly ranked among the two or three strongest in the world in terms of visa-free access. Its Global Investor Programm(GIP) requires a substantial investment of SGD 2.5 million (approximately USD 1.85 million), but in return offers direct access to permanent residency — the first step toward one of the world's most sought-after nationalities.
Hong Kong, for its part, relaunched its CIES (Capital Investment Entrant Scheme) in 2024, which had been suspended in 2015. Since its relaunch, the program has attracted approximately HKD 95 million (around USD 12 million) across roughly 3,200 applications.
Tax engineering and regulation
One fundamental point that every investor must have fully internalized: obtaining a residence permit in a foreign country does not automatically change one's tax residency. The line between legal optimization and tax fraud lies precisely there, and it is closely monitored.
The 183-days rule and the CRS standard
Virtually all European states apply the 183-day physical presence rule to determine liability for worldwide income tax.
An investor who obtains a Portuguese or Greek Golden Visa but continues to spend most of his time in his home country remains tax-domiciled in that country. The OECD closely monitors such situations through the Common Reporting Standard (CRS), which requires financial institutions in member countries to automatically report to foreign tax authorities’ information relating to accounts held by their resident nationals. This growing transparency renders obsolete so-called "appearance" residency strategies — whereby an individual obtains a residence permit without genuinely changing their economic and social ties.
Portugal's NHR 2.0 tax regime
For investors who become effective tax residents in Portugal, the country has offered since 2024 the so-called NHR 2.0 regime (New Non-Habitual Resident Regime).
This regime provides a flat rate of 20% on certain Portuguese-source income and partial exemptions on foreign-source income for a period of ten years.
For Golden Visa holders who do not become Portuguese tax residents — meaning those who spend fewer than 183 days per year in Portugal — no Portuguese tax is owed on foreign-source income.
Tightening due diligence requirements (AML/KYC)
Compliance requirements have tightened considerably under the impetus of the FATF, whose anti-money laundering and counter-terrorism financing recommendations have been transposed into national legislation with increasing rigor.
For any Golden Visa applicant, preparing a robust due diligence file is no longer a formality: it is a sine qua non condition for a successful application.
Requirements focus notably on three areas: full traceability of wealth over the past ten to twenty years (Source of Wealth); demonstration that the invested funds originate from legitimate and declared sources (Source of Funds); and verification of the absence of any links to sanctioned persons or entities, states on the FATF grey or black list, or non-cooperative jurisdictions. Any direct or indirect connection with such actors leads to automatic rejection.
Legal and operational risks in 2026
Investing in a Golden Visa without the benefit of specialized legal and tax counsel constitutes a significant risk. The types of risk are multiple and often poorly anticipated.
- Program instability: sudden closures, such as those of Spain in 2025, Ireland, or Cyprus, serve as a reminder that responsiveness is paramount.
- Capital lock-up: whether real estate or fund-based, investments impose lasting illiquidity that must be anticipated in your wealth management planning.
- Barriers to citizenship: obtaining residency does not guarantee a passport; language requirements and civic knowledge tests are concrete hurdles that are often underestimated.
- Mid-course rule changes: the legislative framework may tighten during your process; for example, a naturalization timeline may shift from five to ten years, as it is the law in force at the time of the final application that governs.
- Threats to Caribbean passports: the European Union is considering withdrawing visa-free access for countries that sell their nationality without residency requirements, which would significantly diminish the appeal of destinations such as Saint Kitts and Nevis.
Conclusion
In 2026, gaining citizenship or residency through investment is no longer a simple financial product, but a genuine act of long-term wealth strategy.
The CJEU ruling of April 2025 clarified the rules of the game: European citizenship cannot be sold, imposing absolute legal and fiscal rigor on applicants. Far beyond the investor themselves, the Golden Visa is now conceived as a family sovereignty asset, protecting future generations against geopolitical upheaval.
Vanbelle Law Boutique has more than three decades of relevant experience and has been an award-winning law firm in international tax for over ten years (Best International Tax Law Firm in Belgium). Don’t hesitate to contact us if you are considering a move abroad.
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