The End of the One-Country Mindset: Building a Cross-Border Mobility Strategy Across Iberia 

For years, investment migration has been framed as a choice. Spain or Portugal. Lifestyle or citizenship. Residence or flexibility.  

That is increasingly the wrong way to think about Iberia.  

In our experience, one of the most interesting shifts emerging in 2026 is that internationally mobile families are no longer trying to make a single residency program solve every objective.  

Instead, they are separating those objectives and matching each one to the country best positioned to deliver it.  

The result is a strategy we are seeing more frequently: living in Spain under a Non-Lucrative Visa while simultaneously maintaining a Portuguese Golden Visa as a long-term residency and citizenship pathway. 
 
It is not a loophole. It is simply a recognition that residency planning has become more sophisticated.  

The regulatory landscape has changed considerably over the past two years.  

Spain closed its Golden Visa program to new applicants in April 2025, pushing affluent retirees and financially independent families towards alternative residence routes such as the Non-Lucrative Visa.  

Meanwhile, Portugal’s Golden Visa remains available through qualifying investment funds with a minimum investment of €500,000. Portugal continues to require only a very limited physical presence to maintain Golden Visa status and qualify for permanent residency and citizenship - approximately seven days per year on average.  

These changes have had unexpected consequences.  

Instead of choosing between Spain and Portugal, many clients are asking a different question:  

“Why can’t we use both?”  

From a mobility perspective, it is a logical evolution.  

Spain offers the day-to-day lifestyle many families are seeking, including international schools, healthcare, established expat communities, and the ability to genuinely build a life there.  

Portugal, by contrast, offers something different: a passive investment-based residency framework that can sit quietly in the background while preserving long-term optionality.  

Those are different objectives. There is no reason they must be achieved through the same residence permit.  

This is the conversation we find ourselves having more frequently with globally mobile families.  

The Portuguese investment is treated exactly as that—an investment. A €500,000 allocation into an eligible regulated investment fund can remain professionally managed while the investor satisfies Portugal’s relatively modest residency obligations.  

There is no expectation that they relocate permanently or build their primary life there. Instead, the investment preserves a long-term pathway toward Portuguese citizenship while requiring only the program’s limited physical presence obligations. Applicants are also not required to renounce their existing citizenship, subject to the laws of their home country. 

Meanwhile, Spain becomes home.  

The Spain Non-Lucrative Visa provides the legal basis to reside in Spain for those supported by independent wealth or passive income, allowing families to enjoy the lifestyle they originally wanted without relying on an investment migration program that no longer exists.  

The key insight is that these two programs are solving different problems.  

One establishes a legal residence where the family actually wants to live.  

The other preserves a long-term strategic position within Portugal and a pathway to EU citizenship without demanding a permanent move.  

Too often, advisers present residency programs as mutually exclusive products. In reality, sophisticated international planning rarely works that way.  

The most resilient mobility strategies are increasingly being built across jurisdictions rather than inside them.  

The broader trend extends well beyond Spain and Portugal.  

Global families are becoming less interested in finding a single “perfect” visa and more interested in building flexibility into their lives. They recognize that immigration policy changes, tax regimes evolve, and personal priorities shift over time.  

That has changed the questions they ask.  

Instead of “Which program is best?”, they increasingly ask:  

• Which residence permit supports where we want to live today?  
• Which program preserves future options?  
• How can we avoid restructuring our lives every time immigration policy changes?  

Those are fundamentally different conversations.  

They move residency planning away from products and towards portfolio thinking.  

One of the biggest misconceptions in investment migration is that every objective should be achieved through a single residency program.  

Increasingly, the opposite is true.  

For the right client, Spain’s Non-Lucrative Visa and Portugal’s Golden Visa are not competing solutions—they are complementary ones.  

One supports everyday life. The other quietly preserves long-term European optionality through a passive investment and limited physical presence requirements.  

As Jelena Sivcev, Product Strategy Manager at Global Citizen Solutions, observes: 

“As global mobility becomes more strategic, the winners will not necessarily be those who choose the ‘best’ program. They will be those who stop thinking in terms of individual visas altogether and start building residency strategies that are designed to work across borders.”