When investigating the potential options to obtain residence in Europe, two investment programs should be considered. The Greek and Portuguese Golden Visa Residence programs, as they are commonly known, offer an array of benefits and may be regarded as similar in many aspects. Firstly, neither country offer a Citizenship by Investment program.
There are several differences between the programs, but following the most fundamentals possible, a non-EU citizen can obtain EU residency after making a qualifying investment.
Greece vs Portugal Golden Visa Comparison
A Golden Visa program is designed for non-EU citizens, but each program’s finer details show they will have its unique investment criteria. The applicant and family members can obtain residence on one application.
The below table gives a Golden Visa comparison between the two European Union countries, excluding the qualifying investment requirements.
| Golden Visa Criteria | Portugal | Greece |
|---|---|---|
| Application Processing Time | Two to three months | Six to nine months |
| Length of Residence | Five years renewable | One year, two years, two years |
| Physical Presence | Not required | Thirty-five days split over the five years |
| Time to Citizenship | Seven years – minimum 183 days per year | Five years – thirty-five days |
| Language Requirement for Citizenship | Yes | Yes |
| Income Tax Rates | Between 9% to 44% | Between 14.5% to 45% |
| Expat Tax Regime | Yes, 7% flat tax on foreign pensions for 10 years | Yes, Non-habitual residence for 10 years. 0% to 20% |
| Inferitance and Gift Tax | 10% to 40%, depending on the value and relationship | Zero |
| Abilityto Work on Golden Visa | No | Yes |
| Family Members Eligibility | Spouse, dependent children under 24, parents | Spouse, dependent children under 26, parents and parents-in-law |
The above comparison sheet does show that the Golden Visa programs are quite different. Both programs have a good expat tax regime and allow applicants to reduce their income tax liabilities.
There are pros and cons to using both programs. The applicant must consider as many indicators as possible to make a decision on the best Golden Visa scheme for them. Subjectively speaking, both countries an incredibly high standard quality of life.
What are the Investment Options for the Golden Visa Programs
The type of investment is something the applicant (as the investor) could ponder over for some time. Portugal and Greece have several options available to meet the qualifying criteria for obtaining EU residency under the Golden Visa Program.
| Investment Typ. | Portugal | Greece |
|---|---|---|
| Real Estate | €500,000 | €250,000 |
| Capital Transfer | €1,000,000 | €400,000 – €800,000 |
| Fund investment | €500,000 | €400,000 |
| Real Estate Low-Density Areas | *€280,000-€400,000 | |
| Real Estate Rehabilitation (older than 30 years) | €350,000 | |
| National Heritage, Arts, and Culture Investment | *€200,000-€250,000 | |
| Research and Development Investment | €350,000 | |
| Creation of Employment | 8- 10 permanent employment opportunities |
Debrief of Portugal’s Golden Visa Program
When investing in Portugal’s Golden Visa, the most popular route is also through real estate, although this is declining year on year.
2022 saw several changes to the Portugal program. The investment fund minimum investment increased from €350,000 to €500,000. The increase has not deterred applicants, and the number of investors using the investment fund route has quadrupled in the last two years.
To get Golden Visa, there are restrictions on the place and type of real estate that investors could purchase.
Debrief of Greece’s Golden Visa Investment Options
While several investment options are available, the most popular for the Greece Golden Visa program is the €250,000 real estate. Greece’s property market has seen substantial growth over the past decade. Investors have made significant annual yields from short and long-term rentals and the capital appreciation on their investment.
The capital transfer investment option has multiple options depending on the investor’s risk appetite.
- €400,000 into a company that’s registered in Greece;
- €400,000 in Greek government bonds;
- €400,000 in shares of real estate investment companies or bonds;
- €400,000 into a Greek bank; and
- €800,000 into corporate bonds.
The investment criteria are set to change soon over concerns about the price of real estate in Greece. The Prime Minister of Greece, Kyriakos Mitsotakis, is planning to double the real estate investment requirement from €250,000 to €500,000. Mitsotakis believes that “to increase the affordability of real estate for Greeks, we are now increasing the minimum amount of investment required for issuing a Golden Visa….”
The exact date of the increase is likely to begin in January 2023. It is unlikely that Greece’s Golden Visa program will see much of a negative impact on the number of applicants and permanent residency.
Advantages of European residence
After completing the qualifying investment requirement for the respective programs, the applicant will obtain residence in Europe. This will afford the applicant and their family members several benefits and advantages.
The Greece Golden Visa property acquisition amount is currently €250,000 and one of the lowest among Europe’s popular residency by-investment programs.
The Government implemented digital applications that are speeding up processing by months. Applicants can obtain their residence permits within a few months. A stark contrast to other Golden Visa programs that can take between six to nine months.
The Greek Golden Visa is a five-year permit and gives the applicants the right to live in Greece. Unfortunately, the Greek Golden Visa does not allow its residents to work. Applicants do not have a physical presence requirement to maintain residence. Of course, this does not fulfil the criteria for Greek citizenship.
If they do not sell their real estate or withdraw funds from their capital transfer, they will be eligible to hold and renew their Golden Visa.
Golden Visa holders can open a Greek (European) bank account and, if they desire, become tax residents in Greece. Additionally, holders can use their Greek IDs or EU residency to travel anywhere within the Schengen area. When it comes to family members, the program allows families to stay together. The spouses, dependent children under the age of twenty-four, parents, and parents-in-law can all join the main applicant.
Portugal’s Golden Visa program has been active for over a decade and has seen thousands of applicants obtain residence and some citizenship in Europe. The program has its critics, which is typical of political grandstanding. That being said, the Portugal Golden Visa has survived attempts to be cancelled as the economic and social benefits continue to thrive from foreign investment.
The Portuguese allow non-EU citizens to use the non-habitual tax allowance if the applicant is a tax resident. The ten-year non habitual residency NHR can reduce income taxes in Portugal to zero with a cap set at 20%.
The Portugal Golden Visa allows its applicants to live and work in the country, a bonus to quickly get into the workforce without needing another type of visa. All holders can travel within the Schengen zone without obtaining a visa. There are physical presence requirements to maintain for the duration of the Portugal Golden Visa.
Dependents allowed to apply on the applicant are similar to Greece. A spouse, parents of either may apply and dependent children under twenty-six years of age.
We have prepared a complete guide of Portugal Golden Visa. You will find all the benefits of Portugal Residency, interesting facts about the country and all investment options.
Requirements for Obtaining Citizenship While on the Golden Visas
Portugal: A Clear and Straightforward Pathway to EU Citizenship
As mentioned above, Portugal Golden Visa program requires a physical presence to maintain residence. The good news is that the same physical presence can fulfil the requirements for Portuguese citizenship. In order to apply for citizenship after five years the applicant must fulfil the following:
- A one-year temporary residence visa is issued, and the applicant needs to spend seven days in the first year;
- A two-year temporary residence permit is issued, and the applicant needs to spend fourteen days in Portugal between years two and three;
- A final two-year temporary residence permit is issued, and the applicant needs to spend fourteen days in Portugal between years four and five; and
- The applicant is eligible to obtain a five-year permanent residence visa but is also eligible to apply for citizenship.
The physical presence component is one part of the European citizenship process within the Portugal Golden Visa requirements. An applicant must pass a Portuguese language test. The CIPLE Portuguese proficiency test is a mandatory Portuguese language exam at the A2 level, considered basic Portuguese. The language test may be taken at any time during the five-year temporary residency as the certificate is valid for life.
The applicant needs to show real connections and close ties to Portuguese society. This can be shown in multiple ways. Participating in club sporting activities, going to local arts and cultural events, and giving time by volunteering at NGOs in Portugal can all be ways to show close ties.
If the applicant completes the above steps, they are very likely to be awarded citizenship and obtain a Portuguese passport and the ability to live, work and study anywhere in the European Union visa-free.
Greek EU Citizenship, a Tougher Pathway to Follow
Obtaining citizenship in Greece is more complex than the Portuguese route. In order to fulfil the physical presence for citizenship on the Greece Golden Visa, holders would need to fully commit to living in Greece for most of their Golden Visas period, and even after renewing it after five years.
The applicant need to become a tax resident in Greece; This requires a minimum physical presence of 183 days per annum for at least seven years.
Another requirement is to pass a Greek citizenship exam set by the Greek Government. Additionally, the applicant must collect documentation to show that they have fully integrated into Greek society. Following Greek Orthodox, Christianity can assist in building a solid case for citizenship.
After submitting all documents, the Government will contact the applicant for a formal interview. The interview will test the submitted submission file (language, knowledge of Greek geography, history, culture and integration into society.
The Greek naturalisation committee will make an assessment and approve or reject the application. Once citizenship is approved, the applicants do not need to hold the investment requirement of the Greece Golden Visa.
Yes, after the Greece investment program transfer of funds is completed, the main applicant and family members submit their Golden Visa application. On approval, they will receive a five-year renewable permanent residence. Holders can open a bank account, live permanently in Greece, and travel anywhere in the Schengen area without a visa.
Yes, after completing the investment requirement and paying the processing fee, a temporary residence is issued. The residence permit is renewable twice before permanent residency, and European citizenship can be granted. Holders can live and work in Portugal and travel visa-free to European countries.
Both programs have their pros and cons. They are similar in many ways. The Greece program is straightforward and faster to obtain residence. Portugal’s program has a clear route to citizenship, with an average of seven days of physical presence over five years.
Most people will be eligible if they are eighteen or older, do not have a criminal record, and not be on a banned country list. Currently, the program suspends citizens from Russia and Belarus from applying. EU and EEA citizens cannot apply for Golden Visa programs.
The Greek Golden Visa has no restrictions on third-country nationalities other than Russian citizens at the time of writing. Anyone satisfying the investment criteria and over eighteen may obtain permanent residence in Greece. EU and EEA citizens cannot apply for Golden Visa programs.