Before you brief aGolden Visa adviser: thedecisions that are yours
An adviser handles most of a Portugal Golden Visa application. Four decisions stay with the applicant: which investment to make, whether to become tax resident, who to include, and when to start the clock. This page sets them out so that the first meeting with a lawyer starts where it should.
Last reviewed . Rules cited to the sources numbered at the foot of the page.
Five questions to answer before the first meeting
Answer each question and the notes beside it narrow to the ones worth raising with an adviser. Nothing here decides eligibility, and no answer produces a verdict; the notes name an area to investigate and who answers it. Until a question is answered, every note for it is shown.
The four decisions an applicant makes
Which route to invest through
The Portugal Golden Visa accepts five kinds of investment, and since 7 October 2023 none of them may be directed, directly or indirectly, at real estate.3 They are: €500,000 in units of a Portuguese non-real-estate investment fund; €500,000 applied to scientific research, or €400,000 in a low-density territory; €250,000 to artistic production or the recovery of national cultural heritage, or €200,000 in a low-density territory; €500,000 into a Portuguese company that creates five permanent jobs; or the creation of ten jobs, with no capital minimum.1
The decision turns on what the applicant wants back, more than on which route is cheapest. A fund and a company return capital, with risk; a donation returns nothing, with certainty; a company and the jobs route need someone to run something in Portugal for years. Whatever is chosen is held for at least five years under a signed declaration.1 Investment routes sets out the trade-offs and what to read in a fund's documents.
Whether to become tax resident in Portugal
Holding a Portugal Golden Visa does not make the holder a Portuguese tax resident; tax residence follows from spending more than 183 days in Portugal in any 12-month period, or from keeping a home there in conditions that show an intention to occupy it habitually.6 The permit's own presence requirement is seven days in the first year and fourteen in each later period, so an applicant can hold it for years without ever crossing the tax line.1
That makes tax residence a decision rather than a consequence, and one that belongs to a tax adviser in the applicant's home country as much as in Portugal. The regime that once softened the move for new residents closed to new entrants at the end of 2023, and its replacement is limited to specified activities.7 Tax and residence draws the line between the two statuses and stops where advice begins.
Who to include
Family reunification may be requested at the same time as the main application and depends on it succeeding.1 The family the law recognises is the spouse or a partner of at least two years, children who are minors, adult children who are dependent and in education, and dependent parents.2 Each person holds their own permit and pays their own government fees under the tariff in Portaria 307/2023, at the first application and at each renewal.5
The decision is who to include now, who might follow later, and what evidence each person's dependency rests on, because dependency is examined again at renewal. Applying with family covers the evidence, the fee stack per person and the child who turns 18 in the middle of the five years.
When to start the clock
Under Lei Orgânica 1/2026, in force since 19 May 2026, naturalisation as a Portuguese citizen requires ten years of legal residence for most third-country nationals and seven for EU and CPLP nationals, counted from the grant of the residence permit rather than from the date of application.4 Permanent residence is unchanged: it follows five years of legal residence under article 80 of the immigration law.2
The 2026 law did not alter the Golden Visa itself.4 It altered the reason for starting early. If the aim is permanent residence and Schengen mobility, the timing question is only about the investment and the backlog; if the aim is a passport, the clock starts on the day the permit is granted, and every month between submission and grant is a month that does not count. Citizenship applications already pending on 19 May 2026 keep the previous five-year rule.4
What to ask the adviser
Fifteen questions, grouped by the stage at which they arise. The full checklist adds a sentence on why each answer matters.
Before choosing a route
- Which of the five qualifying investments matches what I want from Portugal: an asset I get back, a gift I do not, or a business I run?
- Is there anything in my nationality, my record or my current residence that rules me out before any money moves?
- Given the 2026 Nationality Law, what does my realistic timeline to permanent residence and to citizenship look like, and is citizenship even the point?
On the fund or the donation
- Is this fund constituted under Portuguese law, free of real estate, at least five years from maturity, and at least 60% invested in companies headquartered in Portugal, and will the manager state all four in writing?
- What happens to my units at year five: redemption at net asset value, an extension I cannot refuse, or a sale I have to find a buyer for?
- If I choose a donation, which body receives it, who signs the declaration AIMA requires, and what happens if the project is cancelled?
On the application
- Which documents will you prepare, which must I obtain personally, and in what order so that nothing expires before submission?
- What entry document will I use for the biometrics appointment, how many trips to Portugal should I plan, and who in my family must attend?
- How long have your own most recent files taken from submission to card, and what did the renewal involve?
On the family
- Who in my family qualifies today under article 98, and what evidence proves the relationship and the dependency?
- What are the government fees for each person across the first card and two renewals, and what are your fees per person?
- What happens if a child turns 18 or leaves education during the five years, or if my partner and I separate?
On the five-year horizon
- What must I show at each renewal, and what would cause a refusal?
- If I spend more time in Portugal than I plan to now, at what point do I become tax resident, and who advises me on that?
- At year five, what are my options: permanent residence, a further renewal, or exit from the investment, and in what order?
Sources cited on this page
- AIMA: Autorização de Residência para Investimento, Art. 90.º-A (read on 2026-09-03)
- Diário da República: Lei n.º 23/2007, de 4 de julho (legal regime of entry, stay, exit and removal of foreigners), consolidated (read on 2026-09-03)
- Diário da República: Lei n.º 56/2023, de 6 de outubro (Mais Habitação), amending the ARI regime (read on 2026-09-03)
- Diário da República n.º 95/2026, Série I: Lei Orgânica n.º 1/2026, de 18 de maio, amending and republishing the Nationality Law (Lei n.º 37/81) (read on 2026-09-03)
- Diário da República: Portaria n.º 307/2023, de 13 de outubro (fee table for visas and residence permits) (read on 2026-09-03)
- Autoridade Tributária e Aduaneira, Portal das Finanças: Código do IRS, artigo 16.º (Residência): the 183-day and habitual-dwelling tests for tax residence (read on 2026-09-03)
- International Bar Association: An overview of Portugal's new IFICI regime (the regime that replaced NHR for new residents from 2024) (read on 2026-09-03)