Portugal offers spellbinding experiences for avid travelers, foreign investors, and international families alike. Thanks to its Golden Visa program, it’s possible for expats to acquire residency by investment and even Portuguese citizenship in this charming nation. One of the best ways to get a Portuguese Golden Visa is via the Portugal Golden Visa investment fund pathway.

In this guide to Portugal’s investment funds for the Golden Visa, we cover the following:

Important note: The Portugal Golden Visa rules are changing soon. If you would like to apply for the program, we would urge you to consult a specialist before starting the process. To keep up to date with the latest information on the Portugal Golden, you can consult our article here: Golden Visa Ending: Everything We Know So Far.

Golden Visa Investment Fund Portugal: An Overview

About The Golden Visa Program

The Portugal Golden Visa Program is a five-year residency by investment scheme. Qualifying applicants must invest a significant amount into the Portuguese economy to obtain a Portuguese residence permit. Portuguese citizenship is attainable after five years of holding your investment, provided you meet all the requirements under Portuguese nationality law.

For more information about the Golden Visa benefits, investment options, and requirements, consult our Golden Visa Portugal Guide here.

What Is The Golden Visa Investment Fund?

An investment fund is a financial services company that collects investors’ money and invests it in real estate, the stock market, business, etc., to increase capital. This process is operated by the fund managers.

According to an amendment in Portuguese Law 23/2007 on July 4th, people can make contributions to Portugal investment funds to get the Portugal Golden Visa.

Therefore, the Golden Visa investment fund route is one of the many qualifying investment options for the Golden Visa Program.

For the investment fund option, a capital transfer into Portuguese investment funds or venture capital funds to the amount of or greater than €500,000 is needed to procure legal residency in Portugal.

The funds themselves must be focused on the capitalization of companies registered under Portuguese law, with a minimum maturity of five years at the time of the investment and at least 60 percent of the value of the investments made in commercial companies on national territory.

Interestingly, Portugal Golden Visa statistics point to an influx of investors rushing to invest in the Golden Visa, with enhanced interest in the fund investment Golden Visa option – particularly amongst American citizens.

Why is the Portugal Golden Visa fund option so popular?

Real estate was statistically the preferred route for investment in Portugal when it came to applying for the Golden Visa. However, more and more investors are turning to the Golden Visa investment fund option, seeing it as a new way to acquire legal residency.

Having ownership of a property can be attractive to some, especially when it can result in rental income or even a holiday home. In practice, this method may not suit everyone, as finding and purchasing the right property can be difficult and time-consuming.

For extra clarity, consult our fund investment Portugal guide, where we compare the traditional residential real estate investment route with funds. Whether you opt to invest in commercial real estate, residential real estate, or Portuguese Golden Visa funds largely depends on your personal situation. 

Venture capital funds (or FCR – Fundo de Capital de Risco) are considered a qualifying investment for those wishing to apply for Portugal’s Golden Visa. With a minimum investment amount of €500,000 in a fund that qualifies for the Golden Visa, investors can successfully apply for the Portugal residency-by-investment program and have immediate access to the program’s benefits.

The term ‘venture capital’ may sound daunting and complicated, but it is simply a designation of investment funds that are managed by corporate experts in the field who seek to invest in start-ups or medium-sized projects with strong growth potential. Some of the eligible funds are managed as Private Equity funds, which usually invest in more established and revenue-generating companies (later stage than VC). 

Each fund has a specific, well-defined investment mandate and may focus on sectors such as energy, industry, technology, healthcare, or real estate. Funds are regulated by Portugal’s regulator, the CMVM.


How are the Portuguese Golden Visa investment funds regulated?

Portugal Golden Visa funds are regulated by CMVM (The Portuguese Securities Market Commission), which requires funds to comply with the following requirements, including but not limited to:

  1. Report the valuation of their net assets on a semi-annual basis. That means investors may have their participation unit price revised every six months
  2. Employ independent accredited accounting firms such as PwC, KPMG, or EY for annual audits.
  3. Disclose their fees in the PPM/management regulation document. That means investors should have clarity on the management entities’ fees and custodian bank charges.

Who can participate in the Golden Visa fund?

The following applicants are eligible to qualify for the Golden Visa fund option:

  • Be a non-EU/EEA citizen or a non-Swiss citizen
  • Have a clean criminal record
  • Be over 18 years old
  • Have sufficient legal funds to invest in

Depending on the fund and the fund management company, the investment funds may have extra requirements.

In some cases, the investor must:

  • Have some experience with a financial instrument like company stock, government bond, company bond, fund, etc.
  • Submit proof of having enough funds
  • Show where the source of funds comes from

Can a US citizen invest in a Portuguese Investment Fund for Golden Visa?

Absolutely yes, an American citizen can certainly qualify for the investment fund pathway under the Golden Visa scheme. However, do note that the IRS requires foreign financial institutions and certain non-financial foreign entities to report on the foreign assets held by their US account holders. So, any bank, fund, and fund manager in Portugal who has an American client or investor must abide by the US government’s legislation.

While some banks and funds shy away from working with American investors, there are banks and funds in Portugal that are open to accepting Americans. For more information, consult our Portugal Golden Visa Qualified Investment Fund Rules and Regulations guide.

Benefits of the Portugal Golden Visa Investment Fund

There are a number of benefits to picking the investment fund option for the Golden Visa that the other investment routes lack. Here you can find an in-depth overview of the key benefits.

Lower investment

Compared to other investment routes, such as capital transfer, for which you need an investment of €1.5 million, the investment fund option allows you to obtain Portuguese residency from a €500,000 investment.

Low fees and taxes

Investment fund investments do not lead to large fees and taxes, such as the real estate option. Purchasing a property in Portugal requires an IMI transfer tax (average 6%), stamp duty (0.8%), and annual municipal taxes (ranging from 0.3-0.5% annually). In contrast, the investment fund route has none of these taxes.

A safe and secure investment

The funds are regulated and must comply with the rules stipulated by the Portuguese Securities Market Commission (CMVM), which means that fund managers are regularly audited by third parties. Alongside being registered by the CMVM, the Bank of Portugal, and the external Fund Management company also regulate the fund. In addition, the Portuguese Tax Authorities audit the fund. The thorough and high levels of regulation mean that the fund must comply with the Portuguese legislation and tax laws.


While all real estate rental income is subject to a fixed 28% taxation, venture capital funds are a tax-efficient vehicle — dividends and capital gains returned to investors may be tax-exempt. Some cases allow for exemptions to withhold tax on income generated through the fund, especially if the investors are not tax residents in the country.


It is possible to invest €500,000 in several funds, depending on their minimum “tickets.” Also, Portuguese legislation governs the funds to obtain a certain level of diversification. There are quotas on what percentage a particular asset or investment in the fund may constitute of the total fund portfolio. This allows for the diversification of investments within the fund and alleviation of risk for the participating investors.

Potential earnings

The annual yields and eventual capital gains may be significantly higher than other investment funds related to the Golden Visa program, depending on the focus of the investment fund.

Management delegation

The investment fund Golden Visa is professionally managed by experts in each specific sector. While being a real estate landlord can be a hassle, owning a participation unit in an investment fund is much more straightforward. The management burden is delegated to the fund managers. This may also be a disadvantage for control-loving investors, making it both an advantage and disadvantage of investment funds.

Disadvantages of the Portugal Golden Visa Investment Fund

Investment funds also have some disadvantages to them, which are outlined below.

Lack of control

While also an advantage, in that the fund manager does all the work, the investment fund route requires the investor to trust his or her funds with an external fund manager that will determine the investment decisions and steer the strategy. Some investors may not like this lack of control.

Exit issues

Most investment funds will contractually ensure the participants that the fund will not be dissolved before a minimum number of years to make sure that the participant can achieve the time period when he or she is able to apply for permanent residency in Portugal. There can be some issues with this: (1) the resale of the participation unit before the fund dissolves is difficult in most cases; (2) funds normally have extension periods, but sometimes these are unilaterally decided by the fund managers (and not subject to the investors’ vote); (3) if the ultimate objective of the investment fund is to sell the portfolio at a target appreciation, then there will be no guarantee of what the corresponding market will be when the fund decides to sell.

Sharing the earnings

The potential yield and ultimate capital appreciation are shared between the investors and the managers of the fund. The management and performance fees will vary from fund to fund.

KYC burden

Participants will need to share some documents and critical information with the managers of the fund, including proof of income and source of income. Such Know-Your-Client (KYC) burden does not exist in real estate acquisitions.

Golden Visa Investment Options

Residential Real Estate

Commercial Real Estate

Buy Real Estate on Madeira or Azores

Fund Subscription

Capital Transfer

Scientific Research

Job Creation

Cultural Investment

Residential Real Estate: Buy residential real estate in designated interior areas of Portugal worth at least €500,000, or €350,000 if investing in a rehabilitation project. If the residential property is located in a designated low-density area, then a 20 percent discount applies.

Commercial Real Estate: Buy commercial real estate anywhere in the country worth at least €500,000 or €350,000 if investing in a rehabilitation project. If the commercial property is located in a designated low-density area, then a 20 percent discount applies.

Buy Real Estate on Madeira or Azores: Buy residential and commercial real estate anywhere in Portugal’s autonomous islands of Madeira and Azores, worth at least €500,000, or €350,000 if investing in a rehabilitation project.

Fund Subscription: Make a contribution to an investment Fund worth at least €500,000.

Capital Transfer: Make a capital transfer of at least €1.5 million.

Scientific Research: Science or Technology research contribution of at least €500,000 or €400,000 if located in a designated low-density area.

Job Creation: Company incorporation and creation of ten jobs amounting to a minimum value of €500,000.

Cultural Investment: Support the arts or reconstruction of national heritage with an investment of at least €250,000 (or €200,000 if located in a designated low-density area.


Portugal Golden Visa Program: Fees and Costs

Real estate (rehabilitation project)

Real estate

Capital transfer

Investment fund

Minimum investment

€1.5 million


IMT Transfer Tax





Stamp Duty





Notary Cost





Exit fees










Performance Fee




35% of the profit*

Management Fees




1.5% annually**

Legal Fees***





Total amount (approximate without Exit Fees, Management Fee, or Legal Fees taken into consideration)



€1.5 million


*This will vary depending on the investment fund. It is typical for the performance fee to range between 20-50 percent above the hurdle of the profit.

**This will vary depending on the investment fund. It is typical for the annual management fee to range between 1-2 percent of the amount invested.

***Legal fees will vary considerably, depending on the law firm, the number of your family members, alongside other variables. Legal fees will not differ greatly between different investment routes.

Fund Investment Profile and Diversification

The overall level of security of risk of a Portuguese VC fund or ‘Golden Visa Portugal investment fund’ will depend on many factors, including investment mandate, managers’ credentials, leverage and liquidity, and legal documents.

Some funds may offer limited potential for capital appreciation with a safer investment profile while others may have a more leveraged approach with an aim to provide Golden Visa investors multiples of the capital invested. For example, high-growth companies focused on technology have a different profile to property development projects that tend to have a more predictable cash-flow curve.

Funds may offer the opportunity of an early exit, but as a rule of thumb, usually, the investor should expect to realize all gains after five to ten years.

The risk-return profile of these funds will vary according to the sector exposure and portfolio diversification (i.e., how many companies comprise the fund portfolio).

Examples of risk-return levels based on sector exposure and investment portfolio diversification

Examples of risk-return levels based on sector exposure and portfolio diversification

List of funds that qualify for Portuguese Golden Visa

Portugal has long been recognized for its rich investment landscape, characterized by steady economic growth and a welcoming environment for foreign investors. While the country’s real estate sector has historically been a magnet for international capital, Portugal’s investment horizon extends far beyond.

However, it’s important to note that recent regulatory changes have excluded real estate-related funds from eligibility for the Portuguese Golden Visa program. While this adjustment may affect some investors, the program still extends its welcome to a variety of other investment fund categories, such as Growth/Buy-out funds, Venture Capital funds (VC), and Finance Real Estate.

Below, we’ll explore some of the attractive fund options that qualify for the Portuguese Golden Visa.

Note: As of late 2023, the Portuguese Government passed the “Mais Habitaçao” legislation. The Portuguese government eliminated the following investment options from being eligible for a Golden Visa: All real estate acquisitions (€500,000, €400,000, €350,000, €280,000), real estate-related funds of €500,000, capital transfer of €1,500,000. There’ll also be a restriction of location in the real estate investment option pertaining to the Golden Visa program.

You can also keep up to speed with any changes to the program in our article: Portugal Golden Visa Changes, Updates, and New Rules.

Portuguese Golden Visa funds with real estate exposure

With the new law coming into force, several funds that involve real estate will no longer be eligible, namely those that invest or pursue the residential segment. It is expected that other funds that require certain investments in real estate will continue to be eligible if the respective business operations are the main purpose and objective of the fund (e.g., farmland, hospitality, industrial & logistics).

The expected return across such funds varies to some degree depending on the business, sector, location, etc.

Funds that invest in yielding generating assets such as retail parks, warehouses, and hotels may offer expected annual dividends once all the capital is deployed. 

The expected dividend yield usually varies from 2 percent to 5 percent, depending on the rental proceeds and net management fees. In addition, the net value of the assets may increase over the long term, and thus the value of the shares too. 

Growth/buy-out funds (Private Equity funds)

Typically, these funds invest in privately held companies, usually established SMEs or mid-caps. The goal is to acquire, restructure, and eventually sell these companies at a profit. 

Venture Capital funds (VC)

Venture Capital funds invest in early-stage startups with high growth potential. VC investments are inherently risky, as many startups fail, but successful investments can yield substantial returns. 

Finance real estate

Some funds have an alternative strategy where they focus on preferential cash flows at the expense of lower returns. Usually, such a strategy involves the fund lending a great portion of its capital to the companies (SPVs) that hold real estate assets while taking a smaller equity position in them.

In other words, the fund would acquire a percentage of the company shares (whose valuation is done independently), and then it would lend money to the company with a fixed interest rate. The real estate asset, project, or licensing may sometimes work as collateral in the absence of senior debt.

Therefore, the rate of return of such funds predominantly reflects the fixed income from such debt instruments.

Note about fund investment strategy: Investors should understand the areas of focus and sectors the fund intends to invest in. Some funds structure themselves as sector-agnostic, while others are more sector-specific or niche-oriented. Naturally, each sector will entail different risk levels, considering the economic circumstances and trends at the time of investment. For example, funds with a growth/buy-out policy invest in established companies with proven market products and positive EBITDA, typically involve larger investments compared to VC funds that invest smaller amounts in several startups and early-stage companies, where growth is less certain (but potential can be high). 

The Exit

When investing in an investment fund, it is crucial to put some thought into the exit of the investment fund.

Minimum lock-up period

Most investment funds that qualify for the Golden Visa will ensure that they do not dissolve within a minimum of six years. This ensures that your investment will remain valid for the required time period to apply for permanent residency and Portuguese citizenship.

Resale or transfer of participation fund units

For most Portuguese investment funds, participation fund units can be transferred or sold between participants. With this said, it is usually difficult to find a demand for a participation unit in a fund that is suited to Golden Visa timescales unless specified at the formation of the fund.

This makes Portuguese investment funds rather illiquid until the fund is dissolved by the fund manager. Some funds circumvent the issue by offering a buy-back of their participation funds units at a specific discount, but this is uncommon.

Extension periods

Most investment funds will have a specific exit target in terms of timing, and many of the Portuguese Golden Visa investment funds are set for a six-year period.

With this in mind, the majority of investment funds have the option to extend, and this option to extend can be triggered at the six-year mark. In some cases, the fund manager will make the decision on this, not the investors, meaning that you may be locked in further than the time required to apply for Portuguese citizenship. We recommend checking with the fund as this can be a crucial detail.

Extension period options can actually be favorable sometimes, as the expected exit year might not be ideal due to an economic downturn, for example.  

Exit market

The primary objective of most Portuguese Golden Visa investment funds is to exit the portfolio by eventually selling it at a profit.

Fund managers are generally highly incentivized with a performance fee based on a percentage of the appreciation in value. This is beneficial to Golden Visa investors, meaning that their incentives between investors and fund managers are aligned.

With this said, they are splitting your profit but not your potential loss. Therefore, the downside risk will fall on your shoulders.

Documents and Requirements For The Portugal Golden Visa

When applying for the Portuguese Golden Visa, there are numerous documents you must submit to the Portuguese authorities. Note that if any document is missing or incomplete, your application for the Portugal Golden Visa can be significantly delayed. That’s why it’s important to stay informed about all the necessary paperwork you must prepare beforehand.

Note that the documents listed below are not exhaustive, and additional documentation requirements may be requested by the authorities.

List Of Required Documents

  • Passport or another valid travel document
  • Proof of entry and legal stay in the national territory
  • Proof that you are covered by health protection, namely:
    • A document certifying that you are covered by the National Health Service or;
    • A document showing that you are an internationally recognized health insurance holder for the period of legal residence requested
  • Criminal record certificate from the country of origin or the country (or countries) where you have resided for more than one year (certified by diplomatic representation or Portuguese consular office). The certificate cannot be older than three months and must be translated into Portuguese;
  • Proof of your tax identification number, or equivalent, of the country of origin, of residence, or fiscal residence;
  • Completion of Application (using the approved model) containing the authorization for consultation of the Portuguese Criminal Registry;
  • Declaration on Commitment to Honor, by which the applicant declares that he will fulfill the minimum quantitative and time requirements (five years) for the investment activity in the National territory;
  • Present a negative statement debt issued, with a maximum advance of 45 days, by the Tax Authority and Customs and Social Security or, if not possible, declaration of the non-existence of registration with these entities;
  • Receipt of payment of the ARI application analysis fee.

Why choose Global Citizen Solutions for your Portugal Golden Visa?

  • Global approach by local experts: A team of experienced local case executives, immigration lawyers, and investment specialists based in Portugal.
  • Independent service: We are not a marketing agency for any projects. You will access all eligible routes for the Golden Visa so you can decide on the best option, and your investment will benefit from the legal, due diligence services of a reputable Portuguese Law Firm.
  • 100% approval rate: We have the unique distinction of never having had a Golden Visa case rejected and have helped hundreds of clients from more than 35 countries.
  • All-encompassing solution: Our dedicated onboarding and immigration teams will assist you throughout the Golden visa process and beyond with a single channel of communication.
  • Transparency: Our fees are clear and detailed, covering the entire process with no hidden costs.
  • Privacy: Your personal data is stored within a GDPR-compliant database on a secure SSL-encrypted server.

To see the full list of reasons to work with Global Citizen Solutions for your Portugal Golden Visa, you can find out more here: Why Work with Global Citizen Solutions for Your Golden Visa Portugal Application?


Golden Visa Portugal Investment Fund: Documents & Application Process

Portugal Golden Visa fund requirements

If you are interested in applying for the Portuguese Golden Visa through a Venture Capital Fund (FCR), you must carefully make your decision based on two important criteria:

  • Fund eligibility for the Portuguese Golden Visa
  • Fund credentials, including fund strategy, management pedigree, and legal obligations

Not every private equity fund in Portugal qualifies for the Golden Visa program. You need to make sure the chosen fund fulfills all the necessary technical requirements as listed by the Portuguese border service “Serviço de Estrangeiros e Fronteiras” (SEF) and that the investment fund is regulated by the Portuguese CMVM.

Required documents

To apply for the fund investments, you must demonstrate that you’ve made the investment with the minimum required amount and must submit the following documents:

  • Declaration by the credit institution authorized or registered in the national territory with the Banco de Portugal, attesting to the effective transfer of an amount equal to or greater than what is required;
  • Certificate proving ownership of the participation investment fund units, free of charge and charges (issued by the entity responsible for maintaining a registered updated version of the holders of participation units, under the terms of Portuguese legislation, of the respective management regulation or contractual instrument);
  • Declaration issued by the management company of the respective investment fund, attesting the viability of the capitalization plan, the maturity of at least five years, and application of at least 60 percent of the investment in commercial companies based in the national territory;
  • Certificate of commercial registration, if the investment is made through a company single shareholder, demonstrating that the applicant is the partner, cf. Article 65a (13) of Regulatory Dec. 84/07, of 11/05, in its current wording.

Step-by-Step Process & Timeline

The length of time the Golden Visa process takes depends on many different factors, including how long your decision-making process takes, how quickly you are able to provide the correct documents, the experience of the law firm, and the schedule of the SEF office, amongst other things.

Here is a step-by-step process of the Portugal Golden Visa Investment Fund process:

Step 1: Choose an appropriate Golden Visa Investment fund or Golden Visa funds

Step 2: Appoint a law firm

Step 3: Get a NIF number (tax identification number (NIF) in Portugal) and open a Portuguese bank account

Step 4: Sign and complete the necessary fund subscription documents

Step 5: Fund managers evaluate and approve you as an investor

Step 6: Transfer the funds from your bank account to the fund account

Step 7: The fund manager issues the fund subscription declaration

Step 8: Provide all the Golden Visa documents to the law firm and pay the SEF application fee

Step 9: SEF Biometrics appointment scheduled, and you visit SEF in person

Step 10: SEF issues a residence permit that is valid for an initial two years

Step 11: Golden Visa residence permits are renewed every two years, and you are well on your way to Portuguese citizenship

Step 12: Portuguese citizenship and passport can be granted after five years

Questions To Consider Before Investing in Portuguese Golden Visa Funds

  • Are the Portugal Golden Visa funds regulated by the Portuguese authorities?
  • Is the fund fully eligible for the Portuguese Golden Visa, according to SEF?
  • Does the fund have the right attributes to safeguard the investor’s Golden Visa status? As a Golden Visa investor, you will need to maintain your investment in the Golden Visa fund for a minimum of five years, after which you will be able to apply for permanent residency and citizenship in Portugal.

Questions to ask the fund managers

  • How will the fund assure diversification? If so, how often and based on what?
  • What will the fund specialize in?
  • What is the expected target return?
  • Does the fund distribute dividends (how often and how much)?
  • What fees (subscription fee, management fee, performance fee) will the fund investment involve?

Take a look at our Portugal Golden Visa Ultimate Guide by local experts

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Portuguese Golden Visa Investment Fund Credentials

Once we’ve established that the fund is appropriately regulated and is an eligible Golden Visa instrument, the second phase of due diligence is required on the fund credentials.

The three main aspects of analyzing a Portuguese Golden Visa qualified investment fund include:

Fund investment strategy: Does the fund investment strategy make sense? What is the term of the fund? How does the fund plan on paying back investors?

Fund manager credentials: Do the fund managers have the right experience and credentials?

Fund legal: Are the legal documents appropriately drafted to safeguard the investor’s investment?

Useful Industry Acronyms for the Portugal Golden Visa Investment Fund

Regarding the terms, it would be useful to understand some Portuguese-specific acronyms used in this industry, such as:

UP (Unidade de Participação)

PU (Participation Unit), in English, is the equivalent of stocks or shares.

FCR (Fundo de Capital de Risco) – Private Equity Fund or Venture Capital Fund

SCR (Sociedade de Capital de Risco) – Venture Capital Fund

RG (Regulamento de Gestão) – Management Regulation, also known as PPM (Private Placement Memorandum)

Also, an important entity to have in mind is CMVM. It is the Portuguese equivalent of the SEC (Securities and Exchange Commission).

CMVM is a legal entity governed by public law and is part of the European System of Financial Supervisors  (ESFS) and the National Council of Financial Supervisors. (Chapter 1, articles 1 – 3).

The Importance of an Informed Decision

It is important that investors exercise careful consideration when selecting the correct fund investment. Legal documents, as well as the caliber of the fund managers, must be thoroughly scrutinized. Check out additional information on investing in Portugal for citizenship.

If you are interested in applying for the Golden Visa in Portugal, be it through buying a property or investing in a fund, we can help.

Portuguese Investment Funds and PFICs

This section of the article is aimed at providing American citizens with some further information regarding certain tax details that they should be aware of.

What is a PFIC?

The Passive Foreign Investment Company (PFIC) rules are designed to prevent United States Persons from deferring tax on passive income earned through non- US corporations. Also, PFIC rules are in place to prevent converting this income into capital gains that will then be taxed at preferential rates.

A foreign corporation is a PFIC if it meets either:

  1. Passive Income Test – a foreign corporation is a PFIC if greater than or equal to 75 percent of its gross income is passive income, for example, dividends, payment in lieu of dividends, interest, rents, royalties, and annuities.
  2. Passive Asset Test – a foreign corporation is a PFIC if the average annual percentage of the fair market value of all passive income-producing assets is greater than or equal to 50 percent of the value of the entity’s assets. This is determined on a quarterly basis, And it is considered passive if it generates passive income or is reasonably expected to generate passive income in the foreseeable future.

Almost all foreign mutual funds are PFICs. In other cases, possible examples of PFICs include:

  • Passive investments in offshore Hedge Funds, including VC Funds, Stocks, Annuities, or Income Producing Property
  • Foreign Brokerage Accounts with Bond Funds, and Equity Funds
  • Foreign Retirement Accounts
  • Foreign Cash Value Life Insurance Policies.

Important note on mutual funds

Previously, mutual funds were an eligible investment option for the Portugal Golden Visa. Note that new regulations for Portugal’s Golden Visa program now exclude certain mutual funds as eligible investments, including:

  • BPI Portugal
  • IMGA Ações Portugal
  • Sixty Degrees Ações Portugal
  • Optimize Portugal Golden Opportunities.

This change impacts potential investors who must now explore other investment options under the program.

What is Form 8621?

Form 8621 is the form that a US person must file if they are a direct or indirect shareholder of a passive foreign investment company (PFIC) under some specific criteria.

Who must file Form 8621?

According to the IRS, any US person that is a direct or indirect shareholder of a “PFIC” must file Form 8621 for each tax year if they:

  1. Receive certain direct/ indirect distributions from a Passive Foreign Investment Company or Qualifying Electing Fund (PFIC).
  2. Recognize a gain on a direct/indirect disposition of PFIC stock.
  3. Are reporting information with regards to section 1296 mark-to-market election or a QEF
  4. In Part II of the form are making an election reportable
  5. Will need to file an annual report pursuant to section 1298(f)

Each PFIC must have a separate Form 8621 in which stock is held. All interests in PFIC’s must be reported annually.

When must Form 8621 be filed?

The investor must annually calculate their pro rata share of the earnings of their investment, regardless of having received or not any distribution, as it will be considered taxable income for that year.

By doing this, you will maintain the beneficial capital gain rate. Otherwise, you would be subject to a considerably higher capital gain tax rate.

Nonetheless, one must be aware that you can only make this selection in the first year of holding. It is highly complex to retroactively make a QEF election.

Portuguese Investment Funds and PFIC

Most Portuguese funds have until the end of April to report accounts, whilst US tax filing is due on 15 April.

This means that, due to the schedule difference between the date by which investment funds in Portugal issue their reporting and the US’ date of submission of tax return, US investors may consider filing for a tax extension deadline of 15 October to secure enough time to be able to appropriately file their taxes.

Any information contained in this communication is not intended as or to be construed as tax advice. We advise our clients and readers to seek professional tax consultancy from a trusted partner in their jurisdiction.

Why Work With Us

The Portugal Golden Visa program is ending soon, and this is your final chance to apply. If you have decided to seize this final opportunity here’s what we can do for you. 

  1. Firstly our onboarding team can help you obtain your personal Portuguese tax number (known as a NIF) in two days. We can then open a bank account or an escrow, which takes between two to four weeks.
  2. Alongside this, your will meet your immigration and legal team to discuss your personal and family circumstances and help you gather all the documents required for your application. 
  3. Our investment teams will help you familiarize yourself with the market and assist you in understanding all the eligible options for the program, which includes real estate, investment funds, and cultural projects. 

You’ll have three teams working in parallel to help you streamline your application while coordinating with each other. To provide you with an example, we will ensure that you won’t make the investment until all your documents and preparations are ready for your application to be viable and ready to be submitted. 

In times like these, time is of the essence. Global Citizen Solutions can ensure that your Golden Visa application process is a smooth one. 

Start your application today and secure your Portugal Golden Visa. 

Frequently Asked Questions about the Portuguese Investment Fund for the Golden Visa

Can I get residency in Portugal through investment funds?

Yes, it is possible to get a residency permit in Portugal through funds. You must make a minimum investment of €500,000 and ensure the investment fund is accepted for the Portugal Golden Visa.

Does Portugal have citizenship by investment?

The Portugal Golden Visa program doesn’t automatically lead to citizenship. However, Portuguese citizenship is possible if you hold your respective investment for five years and pass on the eligibility criteria, which would ensure Portuguese citizenship by naturalization.

How will Portugal Golden Visa changes in 2022 affect the investment fund option?

On 1 January 2022, the Portugal Golden Visa underwent an extensive makeover. Regarding the investment fund option, the investment amount increased. Specifically, a capital transfer in Portuguese investment funds to the amount of or greater than €500,000 will be needed to apply for legal residency in Portugal. The funds themselves must invest at least 60 percent of their capital in Portuguese companies (registered under Portuguese law.) The funds should be over a five years term in order to accommodate the requirements of the Golden Visa program. The investment fund option has become more popular in recent years, particularly among American investors.

What are the benefits of the Portugal investment fund Golden Visa?

Funds are specifically managed by experts in each sector, you can obtain residency with a Portuguese fund investment, and many investors are exempt from paying tax in Portugal. Funds are also regulated by the Portuguese Securities Market Commission.

Are all Portuguese investment funds eligible for the Portuguese Golden Visa?

Not all Golden Visa Portugal investment funds are eligible for the Golden Visa. It is crucial to consult an expert before investing in Golden Visa eligible funds.

Can I invest in more than one fund for the Golden Visa application?

Yes, you may invest in more than one fund if the sum of your investment is €500,000 or more. For example, you can invest €200,000 in fund X and €300,000 in fund Y. Since the total sum is €500,000, you will be able to apply for the Golden Visa.

Theoretically, you could invest in three or more Golden Visa eligible funds (subject to their minimum ticket).

Would I lose my Golden Visa if my participation unit's total value depreciates?

No, if you invested the minimum required (€500,000), you should not lose your Golden Visa, regardless of the price fluctuations on shares during and at the end of the fund term. What matters is how much you invested initially.

Can I exit my investment prematurely for the Portugal Golden Visa?

It may be possible to exit, although investors should consider the following:

  1. You would not be able to renew your Golden Visa application or acquire permanent residency if you exit before the five-year minimum term required for the Golden Visa.
  2. Traditionally, venture capital funds are not liquid investments, and one should expect to sell their shares back to the fund or to another investor at a discount.

Is Portugal's Golden Visa worth it?

The Portugal Golden Visa is worth it if you’re looking to widen your opportunities, procure EU residency, and even Portuguese citizenship after five years.

Who is considered a US Person?

According to the Internal Revenue Service or IRS, the term “United States Person” means:

  • A citizen or resident of the United States 
  • A US-based partnership 
  • A US-based corporation 
  • Any US estate other than a foreign estate 
  • Any US-based trust if: 
    • A court in the USA is able to display primary supervision over the trust’s administration, and 
    • One or more US persons have the authority to control the substantial decision-making processes of the trust
  • Any other person that is not a foreign person.

What is the difference between venture capital in Portugal and Portugal private equity?

Venture capital and private equity funds are becoming increasingly popular for individuals seeking a Portugal Golden Visa. The regulatory differences between venture capital and private equity are few: 

  • They tend to use the same investment vehicles (private equity funds, private equity companies, or unregulated corporate structures)
  • The equivalent tax treatment and regulatory disclosure requirements
  • No real difference in fund governance between the two fund investment types 

There are more differences between the commercial terms of raising funds and the economics of investments that are made.

Venture capital investments are generally smaller, and the participation of public or state-owned investors is more prevalent, which can result in more investment restrictions. Venture capital investments are normally made via equity or quasi-equity convertible investments, meaning that these investors will typically acquire smaller stakes in investee companies with regard to buyout and growth investors and have less involvement in the management of the investment.

What is the minimum amount I can invest in Golden Visa investment fund Portugal?

The minimum investment requirement for the Golden Visa Fund investment option is €500,000. The fund investment route is gaining in popularity, particularly amongst US nationals.