EU residency by investment gives non-EU investors several ways to establish a European base, but there is no single European programme and no standard investment structure.
Italy, Portugal and Greece all offer routes for international investors, yet they work in very different ways. Italy links residency to investment in the Italian economy. Portugal has moved away from real estate and now focuses on funds, companies, research and other qualifying activities. Greece remains the clearest property-led option.
For families comparing EU residency by investment, the minimum investment is only the starting point. The more important questions are what happens to the capital, how much time you need to spend in the country, how the programme treats family members and whether the structure fits your tax and long-term residency plans.
What Does EU Residency by Investment Mean?
EU residency by investment is a broad term used to describe national programmes that allow qualifying non-EU nationals to obtain residence rights after making an eligible investment or economic contribution.
There is no single EU Golden Visa issued by the European Union.
Each country governs its own programme. Italy has the Investor Visa for Italy. Portugal operates the Autorização de Residência para Investimento, commonly known as the ARI. Greece has its own investor residence framework.
This distinction matters because residency, permanent residence, tax residence and citizenship are not the same thing.
A residence permit issued by an EU or Schengen country can provide important mobility benefits, but it does not automatically make the investor a tax resident or citizen of that country.
Before comparing programmes, investors should consider:
- the qualifying investment
- capital risk and liquidity
- minimum physical presence
- family eligibility
- renewal requirements
- tax implications
- permanent residence objectives
- citizenship objectives
- exit options for the investment
The best route is not necessarily the one with the lowest threshold. It is the one where the immigration structure and the investment still make sense when considered together.
EU Residency by Investment Compared: Italy, Portugal and Greece
The main EU residency by investment options available to international investors differ substantially in structure.
| Italy | Portugal | Greece | |
|---|---|---|---|
| Starting qualifying amount | €250,000 | €250,000 for certain routes, €500,000 for the commonly used fund route | €250,000 for specific property categories, otherwise €400,000 or €800,000 |
| Direct property purchase qualifies? | No | No | Yes |
| Company investment available? | Yes | Yes | Other investment routes exist, but property is the best-known route |
| Fund-oriented route | Depends on the legal structure of the qualifying investment | Yes | Not the core property route |
| Physical presence | Depends on the wider residence strategy | Limited minimum presence under ARI rules | Generally suitable for investors not seeking immediate full-time relocation |
| Tax residence automatic? | No | No | No |
| Typical investor profile | Investment plus Italian residency | Low-presence, fund-based strategy | Property-led residency strategy |
This table should be treated as an initial comparison, not as legal or investment advice. The right jurisdiction depends on the investor’s capital, family structure, tax position and long-term objectives.
Italy: Residency Linked to Investment in the Italian Economy
Italy’s Investor Visa provides four statutory investment routes:
- €250,000 in an Italian innovative startup
- €500,000 in an Italian limited company
- €1 million in a philanthropic initiative
- €2 million in Italian government bonds
Direct residential property does not qualify.
For a broader overview of the programme, investment options and application requirements, read our Italy Golden Visa 2026 guide.
One of the more distinctive features of the Italian system is the sequence of the application.
According to the official Investor Visa for Italy programme, the investor applies for the Nulla Osta before completing the qualifying investment.
The Investor Visa Committee assesses the application and supporting documentation. The official procedure states that, where the application is complete, the outcome of the Nulla Osta assessment is communicated within 30 days.
The investor therefore does not need to deploy the qualifying capital simply to submit the initial application.
After entering Italy with the Investor Visa, the investor must apply for the investor residence permit within the prescribed post-entry period and complete the declared investment within three months of arrival.
The initial investor residence permit is valid for two years and may subsequently be renewed if the qualifying investment is maintained.
This structure is important for investors who want legal eligibility to be assessed before capital is committed.
It also makes Italy different from a model in which the investor first buys an asset and only then relies on that asset to support a residence application.
Portugal: A Golden Visa Without the Old Property Route
Portugal still operates its Golden Visa programme, formally known as the ARI.
What has changed is the investment.
Real estate is no longer a qualifying route.
Current options include investments in qualifying funds, scientific research, cultural activities, job creation and certain company capitalisation structures.
The official Portuguese immigration authority, AIMA, lists the current qualifying routes under the ARI programme.
One of the most commonly discussed routes requires €500,000 in qualifying non-real-estate collective investment vehicles.
Those vehicles must satisfy specific legal conditions. These include requirements relating to the fund’s maturity and the proportion of the portfolio invested in companies headquartered in Portugal.
Portugal is particularly relevant for investors who prioritise limited physical-presence requirements.
Under current ARI rules, investors are generally required to spend at least seven days in Portugal during the first year and fourteen days during each subsequent two-year period.
That can be attractive for internationally mobile families that want European residence rights without immediately moving their main home to Portugal.
The investment itself still requires proper financial due diligence.
A fund being eligible for residency does not automatically make it suitable from an investment perspective.
Investors deciding between the two jurisdictions can also read our detailed Italy vs Portugal Golden Visa comparison.
Greece: The Property-Led Alternative
Greece takes a different approach.
Its Golden Visa remains strongly connected to real estate, making it especially relevant for investors who already intend to purchase property.
The minimum investment depends on the location and type of property.
In high-demand areas including Attica, Thessaloniki, Mykonos, Santorini and certain Greek islands, the standard qualifying threshold can reach €800,000.
In other areas, the standard threshold is generally €400,000.
A €250,000 route remains available for specific categories of property, including certain conversions from commercial to residential use and qualifying listed or historic buildings.
This creates a clear distinction between Greece, Italy and Portugal.
In Greece, property can itself form the basis of the residency application.
In Italy, purchasing real estate does not by itself qualify for the Italian Golden Visa.
In Portugal, real estate has been removed from the qualifying ARI routes.
For an investor who already wants to own property in Greece, the alignment can be efficient.
For someone primarily concerned with liquidity, diversification or portfolio construction, the same property-based structure may be less attractive.
What Happened to Spain’s Golden Visa?
Spain still appears in many online comparisons of EU residency by investment, but it should no longer be presented as an active Golden Visa jurisdiction.
Spain ended its investor visa regime with effect from 3 April 2025.
This is useful context for investors because it demonstrates that residence-by-investment programmes are regulatory frameworks, not permanent products.
Governments can change them.
Portugal removed property from its qualifying routes.
Greece increased property thresholds in several important locations.
Spain closed its investor visa.
That means programme stability and regulatory direction should form part of the analysis alongside investment amount, lifestyle and potential returns.
Which EU Residency by Investment Programme Fits Which Investor?
There is no universal winner in EU residency by investment.
Different structures suit different investors.
If You Want Capital Allocation Rather Than a Property Purchase
Italy deserves closer analysis.
The €250,000 innovative startup route and the €500,000 Italian company route connect immigration directly to investment in the Italian economy.
That can be relevant for investors who already think in terms of portfolio allocation, equity exposure and capital deployment rather than purchasing a property primarily to satisfy an immigration requirement.
The investment itself still has to be evaluated independently.
Immigration eligibility and investment quality are two different tests.
A good residency strategy should satisfy both.
If Low Physical Presence Is a Priority
Portugal remains particularly relevant.
Its relatively limited minimum-stay requirements can fit investors who want to retain an international lifestyle while establishing European residence rights.
This can be attractive for entrepreneurs, investors and families whose economic life remains distributed across several countries.
For investors using the fund route, the analysis should still include:
fund strategy, governance, fees, liquidity, concentration, duration and exit terms.
The residence permit should never replace investment due diligence.
If You Already Intend to Buy Property
Greece has the clearest logic.
If purchasing Greek property already forms part of the family’s investment or lifestyle plan, using a qualifying acquisition for residency can align two objectives.
The reverse should also be considered.
Buying a property that you would not otherwise want simply because it creates residence rights can introduce unnecessary concentration and liquidity risk.
Why Italy Stands Out in an EU Residency by Investment Comparison
Italy becomes particularly interesting when the immigration decision forms part of a broader relocation and wealth-planning strategy.
The first reason is the Investor Visa process itself.
The investor can seek the Nulla Osta before completing the qualifying investment. Capital is then deployed within the prescribed period after entering Italy.
For families concerned about transferring significant capital before legal eligibility has been properly assessed, that sequencing is valuable.
The second reason is taxation.
Italy offers a substitute-tax regime for qualifying individuals transferring their tax residence to the country.
Under the rules applicable to qualifying new residents, the annual substitute tax on eligible foreign-source income is €300,000 for the principal taxpayer, with an additional €50,000 for each qualifying family member included in the election.
The tax regime and the Investor Visa are legally separate.
An Investor Visa does not automatically create Italian tax residence.
It also does not automatically make the investor eligible for the flat-tax regime.
Equally, qualifying for an Italian tax regime does not create immigration rights.
For families genuinely planning to establish Italy as a long-term base, however, immigration, tax and investment planning should be analysed together.
Treating them as three separate projects often creates additional complexity later.
Legal Structuring Matters Before Capital Moves
The financial structure and immigration application need to remain consistent from the beginning.
The investment referenced in the application must correspond to the qualifying structure ultimately used by the investor.
Timing also matters.
Documentation, source of funds, legal eligibility and investment execution need to remain aligned throughout the process.
This is where the legal and investment roles become distinct but interconnected.
An experienced Italian immigration attorney should assess the legal position alongside the investment process rather than only becoming involved after capital has already moved.
For internationally mobile families, the same coordination should extend to tax advisors and other professionals involved in the relocation.
What to Consider Before Choosing EU Residency by Investment
Before selecting an EU residency by investment programme, we would normally examine five questions.
1. Would You Make the Investment Without the Visa?
This is one of the most useful tests.
A €500,000 property, a €500,000 fund investment and a €500,000 equity position are not economically equivalent.
They have different risk profiles, expected returns, costs and exit options.
The residence benefit does not remove those differences.
If you would never make the underlying investment without the visa, understand exactly what you are accepting in exchange for the immigration benefit.
2. How Much Liquidity Do You Need?
Property can take time to sell and can involve significant transaction costs.
Private equity investments can have limited exit options.
Funds may have lock-up periods or restricted redemption windows.
Residency should not force a family to commit capital that may reasonably be needed elsewhere.
3. Are You Planning a Real Relocation?
A European Plan B and a permanent move are two different objectives.
Someone seeking an additional residence option may prioritise limited physical presence.
A family moving its children, home and economic life to Europe needs to think much more broadly.
Tax residence, schools, healthcare, banking, housing and family immigration should all form part of the initial analysis.
4. What Is the Long-Term Objective?
Residency is not citizenship.
Permanent residence is not citizenship either.
If obtaining European citizenship is part of the long-term objective, the analysis should begin with the country’s residence, physical-presence, language and naturalisation requirements.
It should not begin with the assumption that making an investment automatically creates a passport.
5. How Does the Programme Fit Your Wider Wealth Structure?
For high-net-worth families, immigration rarely exists in isolation.
A relocation can affect corporate ownership, taxation, succession planning, banking relationships, real estate holdings and investment structures across several jurisdictions.
The best time to analyse those effects is before the move.
Choosing the Right EU Residency by Investment Route
Choosing EU residency by investment should not start with a ranking of the cheapest Golden Visas.
It should start with the investor.
Greece can be compelling when acquiring qualifying property already fits the family’s plans.
Portugal can be attractive when limited physical presence and a fund-based structure are priorities.
Italy can make sense for investors who want to combine European residency with investment in the Italian economy and potentially a broader relocation and tax strategy.
None of these answers is universal.
The relevant question is not simply:
Which country requires the lowest investment?
It is:
Which country gives you the right combination of residency, capital structure, mobility and long-term optionality?
Brera 1901 works with international families to answer that question before a jurisdiction is selected and before capital is committed.
Book a Private Assessment to compare the European options against your investment profile, family situation and long-term residency objectives.
