For a decade, families weighing Italy vs Portugal for a Golden Visa ended up in Portugal. A €500,000 property in Lisbon or the Algarve, a residence card, five years, then a European passport and ten years of near-zero tax on foreign income through the NHR regime.
Three things changed that picture.
Portugal closed the real estate route in October 2023. It closed the NHR to new applicants at the end of the same year. And on 19 May 2026, its amended Nationality Law came into force, doubling the residence period for citizenship from five to ten years for most non-EU nationals, Americans included.
Italy, meanwhile, kept its programme stable. For families planning their next decade in Europe, the comparison deserves a fresh look.
The capital you commit
Portugal’s main route today is a €500,000 subscription to a regulated investment fund, with at least 60% of the fund invested in Portuguese companies and a minimum maturity of five years. A cultural donation route starts at €250,000.
Italy offers four routes, each tied to the Italian economy rather than to a fund manager:
- €250,000 in an innovative Italian startup
- €500,000 in an Italian limited company
- €1,000,000 as a philanthropic donation to a project of public interest
- €2,000,000 in Italian government bonds, held for at least two years
One practical difference matters to many investors. In Italy the capital moves only after the visa is granted, within three months of arrival. Your funds stay where they are while the application is assessed.
Time to a passport
Both countries now sit at ten years of legal residence for naturalisation of non-EU citizens. Portugal’s advantage on speed, the argument that sold thousands of applications, has disappeared.
Portugal still offers permanent residence after five years. Italy grants a two-year investor permit, renewable for three more years as long as the investment is maintained, and long-term EU residence becomes available after five years of legal stay.
For families whose real objective is a second passport, the decision now rests on where they actually want to spend those ten years.
Tax: where the gap is widest
This is where the two countries part ways.
Portugal replaced the NHR with IFICI, a regime reserved for specific professions: researchers, qualified roles in certified startups, executives in companies that meet investment or export criteria. Passive investors and family wealth holders rarely qualify. Pensions are excluded.
Italy’s regime for new residents works the other way round. It is designed for people with significant foreign income and assets:
- €300,000 per year covers all foreign-source income, whatever the amount
- €50,000 per year for each family member who joins the regime
- Up to 15 years of validity
- No Italian wealth tax on assets held abroad and no inheritance or gift tax on foreign assets
The €300,000 figure applies to those who move their residence from 1 January 2026. For a family with €3 million of annual foreign income, the effective rate drops to around 10%, and it falls further as income grows.
The Italian Golden Visa and the flat tax are separate instruments. Many of the families we work with combine them: the visa provides the right to live in Italy, the flat tax defines how their global income is treated once they do.
Presence and lifestyle
Portugal asks Golden Visa holders for seven days a year on average. Italy’s investor permit carries no minimum stay requirement during its first five years, which makes it equally light for families who split their time between New York, Dubai and Milan.
The real question is lifestyle. Lisbon and the Algarve offer an established English-speaking community. Italy offers Milan’s financial district, Lake Como, Tuscany and Rome, with private banking, international schools and some of Europe’s strongest healthcare within reach of each.
Italy vs Portugal Golden Visa: how the two compare
| Italy | Portugal | |
|---|---|---|
| Minimum route | €250,000 (startup) | €250,000 (cultural donation) |
| Most common route | €500,000 Italian company | €500,000 investment fund |
| Real estate route | None | Closed since 2023 |
| Citizenship | 10 years | 10 years (since May 2026) |
| Tax regime for wealthy newcomers | €300,000 flat tax on foreign income | No equivalent since NHR closed |
| Minimum stay | None in the first five years | About 7 days per year |
Our view
For entrepreneurs who want a passive fund allocation and a light presence, Portugal remains a reasonable choice. For families with substantial foreign income, cross-border assets and an interest in succession planning, Italy now offers the stronger combination.
The flat tax alone can change the economics of the decision by hundreds of thousands of euros a year.
Frequently asked questions
Is the Portugal Golden Visa still available in 2026?
Yes. The main route is a €500,000 investment in a qualifying Portuguese fund. Real estate no longer qualifies, and citizenship now requires ten years of legal residence for most non-EU nationals.
Can I buy property for the Italian Golden Visa?
Property purchases do not count towards the investment threshold. Many investors buy a home in Italy alongside their qualifying investment.
Can I combine the Italian Golden Visa with the flat tax?
Yes. The two are independent, and a Golden Visa holder who becomes an Italian tax resident can opt for the flat tax if they meet its conditions, including no Italian tax residence in at least nine of the previous ten years.
Italy vs Portugal Golden Visa: which is faster for citizenship?
Both now require ten years of legal residence for most non-EU citizens.
Plan your next step
Every family’s income mix and asset structure changes the answer. Book a private consultation with Brera 1901 to model both options against your own numbers.
This article is for general information only and does not constitute legal, tax or investment advice. Rules and thresholds may change. Consult qualified professionals before making any decision.
