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Portugal Golden Visa Investment Funds

Mark Damsgaard

Mark Damsgaard

Founder of Global Residence Index

Last updated: December 13, 2023

Portugal’s Golden Visa faced uncertain times during 2023, but the investment options are clear as of 7 October 2023 after being signed into law by the President. 

The option of direct investment into real estate is no longer an option. The Golden Visa Fund or Investment Fund option is arguably the most sought-after route to obtain temporary residence and, ultimately, citizenship in Portugal. 

In this article, I’ll outline the Golden Visa Fund option and its availability for applicants. Through my experience of working with many clients in the investment migration industry (and specifically the Portuguese program), I will share some pros and cons of the Golden Visa fund option and describe how Global Residence Index can assist in your end-to-end case management process.

What is the Portuguese Golden Visa Fund and what are the criteria that a fund needs to go through to be eligible for accepting client funds? The answers are part and parcel of my guide below. 

Please enjoy.


The Golden Visa Fund Investment Option

The law under Portugal’s Article 90A Residence for Investment purposes defines the investment funds route to the Portugal Golden Visa as follows:

  • The Golden Visa Fund is the capital transfer of €500,000 or higher to acquire units of investment funds or venture capital funds dedicated to capitalizing companies, capital injected under the Portuguese legislation. The maturity of the investment cannot be shorter than five years, and at least 60% of the investments are realized in commercial companies with head offices in the national territory.


There are four essential conditions that an Investment Fund needs to show to qualify for the capital transfer path for a Portuguese Golden Visa:

  1. The fund needs to be approved and regulated by CMVM (Portuguese Securities Market Commission);
  2. For an added level of security, the Central Bank regulates the activities of the fund as well as the management company; 
  3. 60% of the fund’s capital must be invested in companies with headquarters in Portugal;
  4. The investor has to buy fund units for a minimum of €500,000; and
  5. The investment must be kept during the Golden Visa process until permanent residency or citizenship is acquired, which takes at least five years but can extend to six or seven years.


How Does a Golden Visa Fund Investment Work?

The Portugal Golden Visa Investments funds are defined as investing capital alongside other investors. This ensures that the fund is not a fly-by-night investment fund, but rather a fully focused investment business. 

There are advantages to investing in the Golden Visa Fund Investment:

  1. Using professional investment managers;
  2. Benefiting from economies of scale, i.e., lower costs; and
  3. Increased asset diversification.

The Portuguese Securities Market Commission (CMVM) must supervise and regulate the financial instruments market and the agents that operate in them and promote investor protection. These apply to the Golden Visa Funds, increasing investor protection

There are roughly two hundred funds in Portugal. However, only around fifty are eligible for the Golden Visa fund option based on the fundamentals set by the CMVM. 


Risk Appetite for Golden Visa Fund Investors 

The Golden Visa Fund investments are classified as fundo de capital de risco (FCR). The applicant demand is growing even with the higher cost criteria at €500,000. 

Why is this the case? Should investors not want to limit their investment size for the Golden Visa through alternative options?

There are several answers to these questions. A priority reason is that the Golden Visa investment funds can provide significant returns for clients.

  • There are low, medium, and high-risk investment funds depending on the risk appetite of the applicant; 
  • The Golden Visa fund allows investors to have exposure in Portugal, across Europe, and even exposure outside of Europe; 
  • Early seed rounds can provide for investments with multiple-digit returns for investors if companies succeed in future funding rounds.

The Golden Visa fund presents a solid case for clients for the security of their investments. To be eligible and approved as a fund, there are tight regulations the funds must adhere to when taking on investor funds. 

The investment fund is tax efficient, something the real estate industry suffered from. There are no IMI transfer taxes, stamp duty, notary fees, exit taxes, or estate agent commissions. These taxes, or lack thereof, in the investment fund option can significantly impact the end ROI for investors.


Types of Golden Visa Funds in Portugal

The Golden Visa fund investment is excellent for having diverse asset exposure in multiple risk classes in Portugal and abroad. Earlier, we mentioned that asset risk is an item to consider.

That being said, the funds can have a blend of each type of investment to get further diversification across asset classes. These details will be discussed when consulting with the fund manager. 

Although often investors focus on obtaining Portuguese citizenship as a primary incentive to invest in the Golden Visa funds, getting a decent return on investment is equally important. 

Let’s consider a few more details of the Golden Visa funds that will help clients understand their options and make a better-informed decision when the time comes. As per the laws, the funds can use 40% of investment outside Portugal.


Private Equity Funds 

Private equity funds actively invest in privately held companies, bypassing the stock market. They predominantly target sectors such as healthcare, industrial, and IT. Their primary strategy involves taking a controlling stake in operational businesses and increasing their value through active involvement in company management.

The PE Golden Visa funds have a medium to high-risk profile alongside an expected yield of similar magnitude. An investor should look at anywhere from 7 to 15% p.a.

The Golden Visa, through investing in a Venture Capital fund, is a subset of the private equity. They actively focus on early-stage startups with global growth potential before these businesses achieve profitability. 


Venture Capital Funds

Consequently, venture capital investments entail more risk but promise a higher anticipated return. The Portuguese VC funds concentrate on sectors like technology, life sciences, and clean energy. 

The VC fund’s primary emphasis is on maximizing returns upon exit. Only a small percentage is placed into these more speculative investments if the investment is within a mutual fund. However, the potential upside can be considerable and have a significant positive impact on the overall ROI. 


  • Offers a higher potential upside compared to other fund types; and
  • Objective track records may be publicly accessible.

More Risk:

  • Generally carries more downside risk than other fund types; 
  • The investment is typically locked in for a more extended period compared to other fund types (might be a ten-year hold); and
  • Assessing these funds without industry expertise can be challenging.


Mutual Managed Funds 

In the case of a mutual managed fund, it is under the active supervision of a professional portfolio manager or a team of experienced managers who are responsible for making informed decisions about the selection of underlying investments for the fund’s portfolio.

Some mutual managed funds are designed for conservative investors who prioritize capital preservation and may aim for modest returns of 2 to 5%. Others, with a more aggressive growth-oriented approach, may aim for higher return, but typically with a higher level of risk at 7 to 10% or even more.

It’s important to note that past performance is not indicative of future results, and there are no guarantees in investment markets.


Portuguese Golden Visa Fund Fees

In the Golden Visa fund scenario, fees can be payable in the investment cycle’s setup, management, and investment exit. it’s always important to consider the combination of all three.

Fees reduce your overall return on investment, but they are already baked into the fund’s forecasted returns. Investment funds won’t necessitate additional fees by the investors or that investors experience an unexpected loss of capital when executing a sale in the case of real estate. I.e. clients trying to sell their €350,000 purchased property that can only sell for €250,000 where agent fees and other fees were built into the purchase cost.

An applicant can expect to pay the following fees through the Golden Visa Investment funds:

  • Setup Fees: Investors pay a one-time setup fee when investing in funds. This fee can be a percentage of the invested capital, typically ranging from 0.5% to 2%, or a fixed amount; 
  • Management Fees: This ongoing fee is usually calculated on a monthly or quarterly basis using the fund’s resources and typically falls within the range of 1 to 2.5% and
  • Performance Fees: The performance fee represents the portion of investment returns the fund does not distribute to investors. The magnitude of performance fees can vary significantly based on strategy, asset type, and whether the fund disburses annual dividends.

Investors will further pay fees that are directly related to the Golden Visa. Advisory, legal and administrative fees are front loaded based on the investment amount and could be between 5 to 8%. 


Possible Shortfalls for the Golden Visa Fund Investment

Early exit can be a financially negative aspect that a client might consider undergoing. Depending on the investment fund, liquidity to exit might be near impossible, especially if the fund has a long lock-in period. Other possibilities include having to take a severe penalty for early exit. 

The investor will lose the ability to hold the Golden Visa in Portugal if they exit from the investment within the five-year investment threshold to be eligible for permanent residence and citizenship. 


The Golden Visa Fund Investment Process 

Suppose the Portuguese Golden Visa is the investment migration program for you, using an investment fund as the qualifying investment for the Golden Visa is a great choice. 

The high-level step-by-step process for obtaining temporary residency through the Golden Visa investment fund. 

  1. Complete the initial KYC process and identify the fund for investment;
  2. Register and obtain a tax number in Portugal;
  3. Open a bank account with a Portuguese bank;
  4. Complete the application document collection process;
  5. Invest in the correct Golden Visa fund;
  6. Submit the application and complete biometrics at the SEF office when available and
  7. Obtain a two-year temporary residence ID card. 

You can start your renewal process for your second temporary residence about ninety days before expiry. After completing five years of temporary residence and being physically present in Portugal for thirty-five days, investors can obtain Permanent Residence and apply for citizenship at the same time. 

The Portugal Golden Visa law changes will impact the understanding of the program, and there can be areas that are misunderstood. Global Residence Index does not provide financial advice, but we can introduce you to golden visa eligible investment funds and take care of your Golden Visa process until citizenship via our partner team of local lawyers in Portugal. 

If your are interested in the Portuguese golden visa, want to speak with our team about how we can assist you, or if you are seeking introductions to regulated fund managers with golden visa eligible investments, please contact us by clicking here.


Frequently Asked Questions about Portugal’s Golden Visa Funds

What is the minimum investment for the Golden Visa fund option?

€500,000 into an approved Golden Visa fund makes you eligible for temporary residence.

What is the length of investment into the Golden Visa fund?

Although the Golden Visa requires investors to hold their investment for at least five years, the funds might be longer from six to ten years, depending on the investment.

Can I make a return on my investment?

Yes, the purpose of the Portuguese Golden Visa fund option is to use the capital to grow the economy and give an excellent return to the investors. 

Are the fees payable even if I do not make a return?

Fees will vary from fund to fund. There might be an initial setup fee and an ongoing management fee. However, the fund should emphasize a performance percentage for their fees.


Need help?

Navigating through golden visa & citizenship by investment programs can be complex and overwhelming, regardless of the country or program you’re interested in. If you’re struggling to find clear, accurate information, you’re not alone. Our team is here to offer you clarity and reliable advice across a wide range of immigration programs.

By scheduling a consultation, you’ll receive personalized guidance tailored to your unique situation. We’re dedicated to helping you understand the details of various immigration programs, making them more straightforward so you can proceed with confidence.


During our call, we will:

Here is what to expect from a call with our advisory team:


We’ll answer your questions about the program and the application process, providing you with the clarity you need.


We’ll break down each stage of the immigration process, ensuring you know exactly what to expect.


We’ll help you determine if the chosen program is the right fit for you or suggest alternatives that may better align with your goals.


Gain access to our network of recommended local lawyers, as well as providers of eligible investment options.