Portugal is a charming destination with a mild climate, rich cuisine, and hospitable people. With its Golden Visa program, it has also become a gateway to Europe for 12,497 families from around the world as of 2024. An investment method is gaining more and more popularity recently to get residency by investment in Portugal: Portugal Golden Visa Investment Funds.
Important 2025 Update: On June 23, 2025, the Portuguese government proposed changes to the Nationality Law that may impact Golden Visa holders. It includes extending the minimum residency period required to apply for citizenship. On October 28, it was approved by the parliament. On November 13, the Socialist Party bypassed the President and announced it would request a preventive review of the law by the Constitutional Court. You can learn more about the proposed changes to Portugal’s citizenship law by clicking here.
Key Aspects of Portugal Golden Visa Funds
- Minimum Fund Investment: €500,000
- Fund Eligibility: All funds must be regulated by CMVM.
- Fund Investment Options: Closed-ended funds and open-ended funds (Venture Capital and Private Equity Funds, in sectors like renewable energy, tourism, healthcare, and agriculture). You can no longer invest in real estate-related funds as of late 2023.
- Diversification: You can diversify your investments across several funds to reduce your risk. However, ensure that you invest a total of €500,000.
- Exit Strategy: To choose the right Portugal Golden Visa investment fund, you need to consider the exit strategy. You may want to exit the fund after you get your permanent residency or citizenship. Open-ended investments allow you to enter or exit the investment whenever you want, while closed-ended investments lock you in for a specific period.
What to Discover in This Guide?
- Overview of the Portugal Golden Visa Program
- What Is the Portugal Golden Visa Investment Fund?
- Who Can Invest in Golden Visa Portugal Investment Fund?
- How are The Portugal Golden Visa Funds Regulated?
- Advantages of Portuguese Golden Visa Investment Fund
- Portugal Golden Visa: Fees and Costs
- Portugal Golden Visa Investment Fund List
- Things to Consider Before Investing in a Fund
Overview of the Portugal Golden Visa Program
The Portugal Golden Visa is a residency visa issued in exchange for a qualifying investment made in Portugal. The applicant needs to be a non-EU-EEA or Swiss citizen with a clean criminal record. The Portuguese government initiated the program in October 2012. As of 2023, the program has helped attract more than €7.2 billion of foreign direct investment into the country.
In 2025, we published a Funds Outlook Report, gathering insights from many industry experts at Get Golden Visa. As a leading and most trusted Golden Visa advisory firm, we have collaborated with fund experts in the Portugal Golden Visa landscape, and they shared their insights on the future challenges and opportunities in the market.
What Is the Portugal Golden Visa Investment Fund?
The investment fund route for the Portugal Golden Visa was introduced through an amendment in Portuguese Law no. 102/2017, of August 28th, 2017. The corresponding part of the law reads:
“Capital transfer of the amount of €500,000* or higher, for the acquisition of units of investment funds or venture capital Portugal fund of funds dedicated to the capitalization of companies, capital injected under the Portuguese legislation, whose maturity, at the moment of the investment, is, at least, of five years and, at least, 60% of the investments are realized in commercial companies with head office in the national territory (1)”.
Below, you will find the data from 2012 to 2023:
| Category | Value |
|---|---|
| Fund-Based Golden Visa Approvals | 556 approvals |
| Total Investment Through Funds | €594,462,194.84 |
| Share of All Golden Visa Approvals | 4.37% |
| Share Within All Capital Transfer Approvals | 42.4% |
| Investment Type | Capital Transfer → Investment Fund Subscription |
Who Can Invest in Golden Visa Portugal Investment Fund?
For the Portugal Golden Visa application through the investment fund Portugal, you primarily need to qualify for a Golden Visa. The first criterion is:
- Being a non-EU-EEA citizen and a non-Swiss citizen
- Having a clean criminal record
Depending on the Portugal investment funds and the fund management company, the investment funds may bring additional requirements to the applicants. These typically include the investor to:
- Be a savvy investor, meaning the investor needs to have experience with some kind of financial instrument, such as company stock, government bond, company bond, fund, etc.
- Provide proof of sufficient funds
- Provide the source of funds.
Americans: Can a US Citizen Invest in Portuguese Investment Funds?
Yes, a US citizen can invest in an investment fund in order to obtain a Golden Visa in Portugal.
However, the IRS requires foreign financial institutions and certain non-financial foreign entities to report on the foreign assets held by their US account holders. This means any bank, fund, or fund manager in Portugal that has an American client or investor is required to abide by heavy compliance implemented by the US government.
This leads some banks and Portugal investment funds to shy away from working with investors who are US citizens. Regardless, there are banks and Portugal Golden Visa funds that accept Americans. Besides, you can use IRA funds (Individual Retirement Account) to make a qualifying investment in the Portugal Golden Visa. However, this process should be carefully conducted and comply with Golden Visa requirements and IRS.
Feel free to contact us to learn more about these funds and for the Portugal Golden Visa investment fund list.
How are The Portugal Golden Visa Funds Regulated?
The Portugal Golden Visa funds are regulated by the Portuguese Securities Market Commission (CMVM). It is the primary authority responsible for supervising and overseeing financial markets and investment funds in Portugal.
So, the funds should meet the following criteria:
- It must be authorized and regulated by CMVM.
- Investors must commit at least €500,000 into the fund.
- It must update the value of its assets twice a year. This helps investors know how much their investment is worth every six months.
- Assets must be held by an independent custodian, and the fund must be audited regularly by an external accounting firm.
- It must clearly state all its fees (like management and custodian bank charges) in an official document. This ensures that investors know what they are paying for.
Note that Portugal Golden Visa funds must follow specific investment guidelines, including clear policies on what types of assets they can invest in. These rules are to manage risk and protect investors.
Advantages of Portuguese Golden Visa Investment Fund
The investment fund Portugal route of the Portuguese Golden Visa program has certain advantages that other investment routes lack. Below, you may find a comprehensive table of these benefits.
| Benefits of Getting a Portugal Golden Visa Through Investing in an Investment Fund | |
|---|---|
| Benefit | Description |
| Reasonable Investment | Compared to other investment routes for the Portuguese Golden Visa program, such as the capital transfer (€1.5 million), the investment fund option requires a lower investment amount of €500,000. |
| Low Fees and Taxes | Investing in investment funds does not lead to hefty fees and taxes like those of real estate investments. Acquiring a property in Portugal comes with an IMI transfer tax (average 6%), stamp duty (0.8%), and annual municipal taxes (0.3–0.5% annually); an investment in a fund has none of these taxes. |
| Secure Investment | A registered Portugal fund is regulated by (1) the Portuguese Securities Market Commission (CMVM), (2) the Bank of Portugal, and (3) the external Fund Management company. Additionally, (4) the Portuguese Tax Authorities audit the fund. These layers of regulation ensure compliance with Portuguese legislation, tax laws, and the investment plan approved by the fund. |
| Tax-Efficiency | Depending on the tax structure of the fund and the investor, a fund investment may yield significant tax benefits. Certain cases allow withholding tax exemption on income generated by the fund, particularly if investors are not tax residents in Portugal. |
| Diversification | Portuguese law requires funds to maintain diversification. There are quotas for how much a specific asset or investment may represent in the overall portfolio. This spreads risk and provides investors with a diversified structure. |
| Potential Earnings | Depending on the fund’s focus, annual yields and capital appreciation may be significantly higher than other investment options linked to the Golden Visa program. |
| Management Delegation | Owning a participation unit in a fund is a hassle-free investment. Management responsibilities are delegated to professional fund managers—an advantage for most investors, though control-oriented investors may see this as a disadvantage. |
Disadvantages of Portugal Golden Visa Fund
Every rose has its thorn. Portuguese Golden Visa investment fund also comes with its downsides, which you can find listed below:
| Downsides of Getting a Portugal Golden Visa Through Investing in an Investment Fund | |
|---|---|
| Downside | Description |
| Lack of Control | The investment fund requires the investor to trust their capital to an external fund manager who oversees investment decisions and strategy. This level of delegated control may not be suitable for some investors. |
| Exit | Most funds guarantee that the fund will not be dissolved before a minimum number of years to allow participants to reach eligibility for permanent residency or citizenship. However, issues may arise: resale of participation units is often difficult before dissolution; fund extensions can be decided solely by fund management; and the final exit depends on market conditions at the time of portfolio sale, which may not be favorable. |
| Sharing the Earnings | Both potential yield and capital appreciation are shared with fund managers. Management and performance fees vary between funds and reduce the investor’s net return. |
| KYC Burden | Participating in a fund requires comprehensive documentation, including proof and source of income. This Know-Your-Client (KYC) requirement is significantly more demanding than typical real estate purchases. |
Portugal Golden Visa: Fees and Costs
During the process, you will encounter many fees and costs related to the Portugal Golden Visa funds. Here is how:
| Investment Fund | |
|---|---|
| Minimum Investment | €500,000 |
| Government Fees | |
| Processing Fee | €605.10 per person |
| Initial Application Fee | €6,045.20 per person |
| Renewal Application Fee | €3,022.60 per person |
| Exit Fees | 0% |
| Commission | 0% |
| Performance Fee | 35% of the profit* |
| Management Fees | 1.5% annually** |
| Legal Fees*** | varies |
|
Total
(approximate without Exit Fees, Management Fee, or Legal Fee) |
€500,000 |
* Varies on the fund, it is typical for the performance fee to be between 20%-50% above a hurdle on the profit.
** Varies on the fund, it is typical for the annual management fee to be between 1%-2% of the invested amount.
*** Legal fees vary widely between law firms, the number of family members, and other variables; they would not greatly differ between different investment routes.
Minimum Investment Amount
To get legal residency in Portugal through the investment fund option, you need to invest at least €500,000 in a Portuguese investment or venture capital fund.
Here are the basic rules for choosing a Golden Visa fund:
- The fund must invest in companies based in Portugal
- The investment must stay in the fund for at least five years
- At least 60% of the money must go to businesses operating in Portugal
We’ve also prepared the chart below to show you a comparison of Portuguese investment funds to other investment options.
| Investment Options | Minimum Investment Amount |
|---|---|
| Portuguese Golden Visa Funds | €500,000 |
| Donate to Portuguese Cultural Heritage | €250,000 |
| Set up a Company and Create 10 Job Positions | Project dependent |
| Scientific Research | €500,000 |
The Basics of Fund Investment Profile and Diversification
Portugal Golden Visa Fund investment profile refers to what kind of assets or businesses a fund invests in. It gives you an idea of the fund’s strategy, risk level, and goals. For example:
- Some funds tend to be stable.
- Others invest in startups or tech companies, risky, but they also offer high growth potential.
- Some might target green energy, healthcare, or tourism. These sectors can have both growth opportunities and risks, depending on global trends, government policies, and economic conditions.
On the other hand, diversification means sharing your investment across different sectors or companies to reduce risk. Therefore, it helps you to protect your money by sharing your risks.
Type of Portugal Golden Visa Funds
We can divide funds into two categories: open-ended funds and closed-end funds. In the market, 90% of the available funds are closed-end funds, and 10% are open-ended funds.
1. Open-Ended Funds
Open-ended funds let you enter or exit the investment whenever you want, compared to closed-end funds. Therefore, they are great for investors who want more flexibility and liquidity. In the meantime, they still meet the 5-year minimum holding rule for the Golden Visa.
These include:
- Public equities,
- Corporate bonds,
- Digital assets like Bitcoin, Ethereum, and Solana
2. Closed-Ended Funds
Closed-ended funds are less liquid because the money is normally invested for a specific time, which gives you less flexibility. You cannot exit the fund anytime you want, as your capital is locked in for the duration of the fund’s life.
They are often structured like private equity or venture capital funds.
Portugal Golden Visa Investment Fund List
Located in the southwestern part of Europe, Portugal is quite attractive for foreign investors with its stable and prospect opportunities. Before the “Mais Habitação Law” was released on October 6th, 2023, the country had been a strategic point for real estate investors. Since then, Portugal’s Golden Visa program has ceased the real estate option.
However, it still offers diverse investment fund options as an eligible route to citizenship. Here, we listed some of them:
1. Private Equity Funds
A private equity (PE) fund is a type of investment where a group of investors pools their money together. This money is then managed by Portuguese-based fund managers. Then, they use that money to buy shares in private businesses or to help those businesses grow. Here, “the private businesses” refer to the companies that are not listed on the market.
Private equity funds are closed-end funds, so you cannot use them in stock exchanges. Besides, there are two types of partners. One of them is the limited partners who are responsible for the entire amount they invest. It tells the parties the amount of risk and the life of the fund. The other one is the general partners, who are vulnerable to market volatility.
Here are some examples of private equity funds:
- Healthcare
- Education
- Tourism
- Agriculture
- Renewable Energy
- Small and medium enterprises
- Entertainment.
2. Venture Capital Funds
Venture capital funds invest in startups or growing businesses. Think of these young companies in need of funding to grow and expand into new markets. Although they carry more risks, they offer higher rewards if the company does well.
Here’s how they work:
- Fund managers collect money from investors.
- They invest that money in multiple startups or fast-growing small businesses.
- If those businesses grow, the fund can make a good return.
- If they fail, the risk is higher, and you could lose money.
Here are some examples of venture capital funds
- Start-Ups
- R&D
- AI
- Space-Tech
- Deep-Tech
The Exit
As stated in the above advantages and disadvantages of the Portugal Golden Visa fund list, the exit of an investment fund is an issue worth delving deeper into.
Minimum Lock-up Period
Most Golden Visa qualifying investment funds will contractually make sure that they do not dissolve within a minimum of six years. This practically ensures that your investment will be valid for the necessary period to apply for Portuguese citizenship.
This is a collaborative approach, and it is something to look for in the investment fund for the Golden Visa path. Though it does not end there. It is also important to assess and question the following aspects.
Resale or Transfer of Participation Units
Most Portuguese investment funds allow for the participation units to be transferred or sold between participants. However, it is typically difficult to find a demand for a participation unit in a fund, which is timed particularly for Golden Visa timelines, unless it is at the very formation of the fund.
This makes these fund investments rather illiquid until the fund manager dissolves the fund. Some funds get around this issue by offering a buy-back of their participation units at a certain discount.
Extension Periods
It is common for funds to have a particular exit target in terms of timing.
Many of the Portugal Golden Visa investment funds set it at six, eight, or ten years.
Having said that, the majority of the funds have optional extension periods, which may be triggered at the maturity mark. The optionality is decided by the fund managers, not the investors. This means that you may be locked in further than the time required to apply for citizenship in Portugal. It is best to check with the fund.
Exit Market
The ultimate objective of most Portuguese Golden Visa funds is to exit the portfolio by selling it at a profit eventually. Most fund managers are highly incentivized with a performance fee based on a percentage of the appreciation in value. This is a good thing as it means their incentive is aligned with that of the investors.
However, mind you, they are splitting your profit, but not your potential loss. So, the downside risk is all on you.
Golden Visa Investment Fund Portugal: Documents and Requirements
The documentation required to apply for the Portugal Golden Visa through an investment in a fund is pretty much the same as the documentation needed for any Golden Visa application in Portugal.
Documents and General Requirements for Portugal Investment Funds
- Passport or other government-issued identification
- Evidence of the healthcare coverage
- Document proving coverage by the Portuguese National Health Service, or
- Document proving coverage by an internationally recognized health insurance,
- Criminal Record, obtained from the country of origin or residence;
- Issued up to three months before the application submission, and
- Translated into Portuguese
- Tax identification number from the country of origin or tax residence
- Filled out Application Form stating authorization for consultation of the Criminal Record in Portugal,
- A Letter of Statement by which you declare to comply with the minimum time requirements for the corresponding investment activity in Portugal,
- Payment receipt for the ARI application fee.
Investment Related Documents
You’ll need to present supporting documents to show that an investment of the minimum amount has been made by you. The supporting documents include:
- A declaration from a registered Portuguese institution stating that a transfer of an amount fulfilling the minimum investment requirement has been made effectively
- Supporting documents stating the ownership of the participation units by yourself, free from any obligations or charges
- A declaration issued by the managing company of the investment fund, stating the business plan, maturity dates of at least five years, and deployment of at least 60 percent of the fund portfolio in Portugal
Timeline
How long the Golden Visa process takes really depends on a multitude of factors. These factors include how fast your decision-making process is, how quickly you get the required documents together, as well as the experience of your law firm, and the application load in the SEF office when you submit your application.
Below is a step-by-step process of the program through a Portuguese investment fund:
- Step 1: You choose an appropriate Portugal investment fund option
- Step 2: You appoint a law firm
- Step 3: You get a tax identity number (NIF) and open a bank account in Portugal
- Step 4: You sign and complete all necessary fund subscription documents
- Step 5: The Fund manager evaluates and approves you as an investor
- Step 6: You transfer the necessary funds from your bank account to the fund account
- Step 7: The Fund manager issues a fund subscription declaration
- Step 8: You provide all GV documentation to the law firm & pay the AIMA application fee
- Step 9: AIMA Biometrics Appointment is set, and you show up at AIMA in person
- Step 10: AIMA issues the residence permit, valid initially for two years
- Step 11: Golden Visa residence permits are renewed every two years, and you continue on the path to Portuguese citizenship.
Schedule an Online Advisory Call
We present investors from all around the world with more than 40 funds to choose from in Portugal. In a quest to serve you better, we’re presenting an online advisory call.
In this 45-minute, one-on-one call, you’ll:
- Learn how to assess the risk and return profile of a fund
- Get to know which aspects to consider when choosing funds
- Receive tips on fund investment strategies
- Communicate your questions and concerns
Once you book your request, our team will contact you to set up a day and a time.
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Things to Consider Before Investing in a Fund
Wondering about how to choose the right fund? Well, it depends on the investor’s profile. Before investing in a fund, there are several important factors to consider to secure your profit. Here are the key things to evaluate:
- Start by determining your risk profile. At this step, you should also consider the sectors you prefer or wish to avoid, and the level of risk you are comfortable with.
- Decide whether you want to invest in an open-ended fund, a closed-ended fund, or a combination of both. This will be based on your liquidity preferences and investment timeline.
- Evaluate the expected target return of the fund to ensure it aligns with your expectations.
- Check whether the fund is attracting only Golden Visa investors or also Portuguese and institutional investors, as broader participation may signal stronger credibility.
- Understand the fund’s fee structure to assess the overall cost of the investment.
- Review how diversified the fund’s portfolio is to reduce potential investment risk.
- Examine the fund’s exit strategy, especially for closed-ended funds, and understand who the expected buyers are at the time of liquidation.
- Ensure the fund’s life cycle is compatible with your Golden Visa timeline
- Research the track record of the fund manager and advisor. You can look into their experience, past performance, and reputation in the market.
- Assess the overall risk-return profile of the fund.
The process might seem complicated. At this stage, Get Golden Visa, as an independent fund advisory firm, is here to help you find a solution that aligns with your interests. Below, you can watch our partner, Werner Gruner, and learn how we streamline your process.
Portugal Golden Visa Fund Investment For American Citizens
If you are looking to invest in the Portugal Golden Visa Fund as an American citizen, there are important rules you need to know. Now, let’s look at these:
Opening a Bank Account
To get a Portugal Golden Visa, you need to open a bank account in Portugal. Make sure to choose a bank that follows FATCA, the Foreign Account Tax Compliance Act. These rules are meant to prevent US citizens from hiding money abroad to avoid taxes.
If your bank follows FATCA regulations, it will help you avoid tax problems in the US.
PFIC
Many foreign investments, including mutual funds, are classified as PFICs by the US government. This rule is in place to prevent US citizens from avoiding taxes on income from foreign investments. If you invest in a PFIC, you might need to file an extra tax form (Form 8621) and report your share of any income or gains.
A foreign corporation is a PFIC if:
- At least half of its assets generate passive income. This passive income test is determined by the average fair market value of the company’s assets over the year and is checked every quarter.
- At least 75% of its total revenue comes from passive sources, such as dividends, interest, rents, royalties, or annuities.
Some examples of PFICs include foreign mutual funds, hedge funds, foreign brokerage accounts, foreign retirement accounts, and foreign cash value life insurance.
Form 8621
If you’re a US citizen who invests in a PFIC, you will need to file Form 8621 with your taxes every year. This form is used to report:
- Distributions from the PFIC.
- Gains from the sale or exchange of PFIC shares.
- Any elections (like QEF or Mark-to-Market) you make for PFIC treatment.
- Specific information about the PFIC, including its name, address, and the type of income it generates.
When to File Form 8621
You must file Form 8621 if:
- You receive distributions from the PFIC.
- You sell or exchange PFIC shares for a gain.
- You wish to choose the QEF or Mark-to-Market election.
- You must disclose specific details as per Section 1298(f) of the Internal Revenue Code.
Taxation for US Citizens
When it comes to taxes in the US, many people think the system is complicated and frustrating. Therefore, applying for Portugal’s residency by investment program may seem complicated for them as US tax returns are due by April 15. On the other hand, investment funds in Portugal must submit their accounts by the end of April. This means US investors may not have enough time to file their taxes properly because of the timing difference.
If not managed properly, you may be taxed twice on the same income. To solve this, you can apply for an extension until October 15 to make sure they have enough time to file correctly.
Moreover, there is an agreement between Portugal and the US to avoid double taxation. However, in practice, it does not work as it seems. As an American, you will be taxed on your worldwide income by the US regardless of where you live.
Although Portugal’s special tax regime for non-residents has ended since March 31, 2025, it has been replaced by the IFICI 0.2 program. Therefore, you can go for it on condition that you are eligible to apply, as long as you are a new resident and have not resided in Portugal for the previous five years.
Note that you still need to contact your tax advisor to get clarification depending on your specific circumstances.
Get Golden Visa: Who We Are and How We Can Help You
Get Golden Visa is a trusted investment advisory firm. We help people get additional residency and citizenship by making a qualifying investment through a fund subscription in Portugal. With our team of legal professionals in Lisbon and Porto offices, we offer our clients a tailor-made and transparent journey in their quest for the Portuguese Golden Visa through funds.
Contact us and talk to one of our experienced team members to help you with any and all your questions.
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Frequently Asked Questions on Golden Visa Investment Fund Portugal
What is the difference between Venture Capital in Portugal and Portuguese Private Equity?
The fundamental distinction is that, whereas a private equity fund is based on solid businesses, venture capital funds are typically invested in startups.
What is the Golden Visa Portugal investment fund?
Golden Visa investment fund Portugal is an investment method that allows investors to invest in Portugal to qualify for Portugal Golden Visa. If you make an investment of €500,000 into the funds, you can qualify for the program.
Can I make an investment in different Portuguese investment funds?
Yes, you can do diversification with the Golden Visa Portugal investment fund and invest in different funds.
What is the minimum amount I can invest in the Golden visa investment fund in Portugal?
The minimum investment amount is €500,000 as of January 1st, 2022.
Do all funds in the ‘Fundo do Capital do Risco’ category qualify for a Golden Visa?
No. In late 2023, the Portuguese Government passed legislation called “Mais Habitaçao”, which states that any direct or indirect real estate investment of a fund will disqualify it for a Golden Visa application.
Is it possible to gain Portuguese residency by investing in a fund?
Yes, it allows investors to obtain residency by contributing to qualified Golden Visa funds that meet specific criteria.
Will a drop in the value of my fund units affect my Golden Visa status?
No, your Golden Visa won’t be affected if your investment loses value. What matters is that you invested the required amount when you applied, followed the rules, and keep your initial investment.
Can I withdraw my investment early while holding a Portugal Golden Visa?
No, if you take out your investment before five years, you could lose your residency. You need to keep the investment for the full period to keep your Golden Visa.
What should US investors know before applying for the Portugal Golden Visa through a fund?
US Golden Visa applicants need to choose funds that are compliant with regulations such as FATCA and SEC rules.
How secure are investment funds in Portugal?
Portuguese investment funds are supervised by the CMVM, the national regulator. This helps ensure some control, but like any investment, there are risks.
