Portugal (residency by investment) — The program remains open, but real estate and capital-transfer routes are gone. Qualifying options now center on approved funds, R&D, arts/cultural patronage, and company/job creation. Typical naturalization timeline is 5+ years of legal residency (language A2 and integration requirements apply). (Global Citizen Solutions)
Greece (residency by investment) — Still highly competitive. Minimum €250k applies to certain renovation/convert-to-residential assets; €400k in most ready-to-move markets; €800k in prime zones (Athens center, Thessaloniki, Mykonos, Santorini). Alternative routes (funds/bonds/bank deposits) from €350k. Naturalization generally after 7 years of legal residence (with language/civics). (Imin Caribbean)
Spain (golden visa ended) — The golden visa program officially ended on 3 April 2025. For Spain today, look to other residence routes (entrepreneur, high-skilled, digital-nomad, non-lucrative). Standard naturalization is 10 years (shorter for certain nationals). Existing golden-visa holders keep status. (Global Citizen Solutions)
Italy (investor visa + flat-tax option) — Italy offers a 2-year Investor Visa (renewable) via qualifying stakes from €250k–€2m (e.g., startups, companies, government bonds). Separately, the non-dom flat-tax regime lets qualifying new residents elect a €200k/year levy on foreign income (up to 15 years). Standard naturalization typically 10 years of residence. (Global Residence Index)
UAE (10-year “Golden Visa”) — A property-investor path exists from AED 2,000,000 (~US$545k), including with bank financing. Expect renewability and generous stay flexibility—but note the UAE does not offer a routine naturalization track from this visa. Citizenship grants are rare and discretionary. (Get Golden Visa)
Thailand (LTR Visa) — The 10-year Long-Term Resident (LTR) visa targets wealth/global professionals; one track includes US$500k+ in Thai government bonds/FDI/property. The LTR is excellent for domicile and work authorization, but Thai citizenship requires a separate, longer path (permanent residency then naturalization, language, etc.). (ThaiEmbassy.com)
One-Glance Comparison (2025)
Country | Program status | Typical qualifying route(s) | Min. Investment (headline) | Tax-residence angle | Indicative naturalization path |
---|---|---|---|---|---|
Portugal | Open, real estate removed | Funds, R&D, culture, company/jobs | €250k–€500k+ (by route) | NHR phased out; standard rules apply; structure carefully | ~5+ years residency (A2 Portuguese) (Global Citizen Solutions) |
Greece | Open, thresholds tiered | Real estate (tiered), funds/bonds/deposits | €250k / €400k / €800k (zone-based); funds from €350k | Standard Greek tax rules; plan for worldwide reporting if resident | ~7 years residency (language/civics) (Imin Caribbean) |
Spain | Closed (Apr 3, 2025) | Use non-golden alternatives (entrepreneur, DNV, etc.) | n/a | Spanish tax if resident; other visas may allow flexible presence | ~10 years (shorter in limited cases) (Global Citizen Solutions) |
Italy | Open | Investor Visa; separate €200k non-dom flat tax (elective) | €250k–€2m (by asset) | €200k flat tax on foreign income (elective, up to 15 yrs) | ~10 years residency (Global Residence Index) |
UAE | Open | 10-yr Golden Visa (incl. property) | AED 2m property | Territorial system; no tax on most personal income | No routine naturalization via GV (Get Golden Visa) |
Thailand | Open | LTR visa (multiple tracks) | US$500k (for “Wealthy Global Citizen” track) | Territorial elements; remittance rules matter; plan carefully | PR then citizenship (longer path) (ThaiEmbassy.com) |
Strategy Notes for Serious Investors
- Residency now, passport later: In Europe, naturalization typically takes 5–10+ years of lawful residence with language/integration. Your day-count and genuine ties matter—plan to actually spend time where you aim to naturalize. (Get Golden Visa)
- Real estate ≠ golden visa everywhere: Portugal removed real estate; Spain ended its scheme. Greece remains property-forward but with higher, zone-based thresholds—prime stock requires €800k. (Global Citizen Solutions)
- Tax planning is a separate track: Residence permits don’t automatically optimize taxes. Italy’s flat-tax regime is elective and distinct from the investor visa; the UAE offers simplicity without a citizenship lane. Model your effective tax rate and reporting before you move. (Golden Visas)
- Asia plays: UAE and Thailand LTR are superb for mobility, lifestyle, and operating bases; treat citizenship as unlikely/long-dated. (Get Golden Visa)
Great—here’s a fully costed, investor-grade “map” you can drop into Invest Offshore. It assumes a globally mobile HNW family of 3–5, with portable business income and portfolio assets. Numbers are round-trip, 2025-current, and meant for planning (not legal/tax advice).
Residency ≠ Citizenship Map (2025)
Goal: secure tax residence now + optional path to EU naturalization later.
Operating baseline: maintain one primary tax home and 1–2 “bolt-holes” for mobility and business.
Country Stack & Costs (what you spend, what you get)
Portugal — GV (non-property routes only)
- What works now: regulated funds, R&D, culture, or job-creation (real estate removed). Typical ticket €250k–€500k+ depending on route. (Get Golden Visa)
- Fees (family of 4): govt + biometrics/legal ~€15k–€35k over the first two years.
- Time-on-ground: historically light for residence card maintenance (verify per route), but naturalization requires ~5+ years legal residency, A2 Portuguese. (Portugal Pathways)
- Tax angle: NHR is sunset; standard rules apply—plan pre-arrival (CFC, step-up, fund character).
- Use case: best EU passport path via non-property capital.
Greece — Golden Visa (tiered thresholds)
- Real estate thresholds (2025 rules): €800k prime (Attica incl. Athens, Thessaloniki, Mykonos, Santorini); €400k many zones; €250k still possible in specific areas/renovations; financial-asset routes from €350k. (Global Citizen Solutions)
- Fees (family of 4): taxes, notary, lawyers, cards ~€18k–€35k + purchase costs.
- Naturalization: generally 7 years legal residence + language/civics.
- Tax angle: standard Greek residence if you center life there; structure rental yield and exit.
- Use case: property-led EU foothold; credible passport path if you truly reside.
Italy — Investor Visa + Flat Tax (separate levers)
- Investor visa tickets: €250k innovative startup, €500k Italian company, €1m public-interest donation, €2m gov’t bonds (2-year visa, renewable). (Investor Visa)
- HNWI flat tax (optional): €200k/yr on foreign-sourced income (add €25k per dependent), up to 15 years. (Italian Citizenship Assistance –)
- Fees (family of 4): legal/consular/residence ~€8k–€20k + the qualifying investment.
- Naturalization: typically 10 years residence.
- Use case: high-control EU base with predictable tax on global income via the flat-tax election.
Spain — Golden Visa ended (April 3, 2025)
- Status: program ended; look instead at entrepreneur, highly-skilled, digital-nomad, or non-lucrative visas. Existing holders keep status. (El País)
- Naturalization: usually 10 years (shorter for select nationalities).
- Use case: lifestyle hub with alternative residence routes—no “GV” today.
UAE — 10-year Golden Visa (property investor)
- Property route: market value ≥ AED 2,000,000 (title deed / official valuation; financing allowed within limits). (u.ae)
- Fees (family of 4): visa, medicals, ID, sponsor ~AED 12k–25k initial.
- Naturalization: not a routine path from GV; citizenship is exceptional. (u.ae)
- Tax angle: territorial; simple personal tax profile; manage PE risks for operating companies.
- Use case: operational HQ + tax simplicity + connectivity—treat passport as unlikely.
Thailand — LTR (10-year)
- Wealthy Global Citizen track: US$1m net assets and US$500k combined into Thai gov’t bonds/FDI/property; income criteria apply (policy updated 2025). (LTR Visa Thailand)
- Fees (family of 4): visa fees + work permit(s) typically US$3k–8k total.
- Naturalization: long path (PR first, language).
- Use case: Asia base with work authorization and favorable remittance planning.
Day-Count & Compliance (how much time to spend)
Country | Maintain residence permit | Tax residence (typical trigger) | Passport path realism |
---|---|---|---|
Portugal | Historically light physical presence; confirm per route | Center of life + >183 days | Strong if you truly reside 5+ yrs. (Portugal Pathways) |
Greece | Maintain property/permit; day-count minimal for the card | Center of life + >183 days | Credible at ~7 yrs with ties |
Italy | Maintain permit; make qualifying investment | >183 days or center-of-life | Long-dated (10 yrs), strong with flat tax |
Spain | Alt visas vary | >183 days | Long-dated (10 yrs), no GV now. (El País) |
UAE | Visa validity not day-count heavy | Generally no personal income tax; avoid creating foreign PE | Unlikely via GV |
Thailand | LTR conditions + reporting | Typically >180 days; remittance rules matter | Long-dated, PR first (LTR Visa Thailand) |
Structure: Where to hold assets & run income
Operating Co (OpCo):
- UAE Free Zone (e.g., DIFC/ADGM/DWTC) for international services, contract flow, banking access, and VAT where needed (mind ESR and PE in client locations).
- EU exposure: if you’ll hire in the EU, add a lean Portugal or Italy subsidiary for payroll and social-security.
HoldCo (capital & funds):
- Luxembourg (for regulated funds / AIFs feeding Portugal fund route) or
- UAE HoldCo (if prioritizing territorial simplicity & GCC banking).
- For Greece property, use a local SPV for acquisition/exit efficiency.
Personal accounts & custody: multi-jurisdictional private bank + brokerage, with CRS/FATCA alignment and a travel-ready liquidity buffer (6–12 months OPEX).
Sequenced Playbook (12–24 months)
- Anchor tax home (choose Italy + flat taxorPortugal with genuine residence).
- If Italy: pre-arrange Nulla Osta, pick €250k/€500k track; evaluate €200k flat tax and family add-ons. (Investor Visa)
- If Portugal: diligence regulated funds (fees, carry, liquidity) and lock your €250k–€500k ticket. (Get Golden Visa)
- Mobility bolt-hole
- UAE GV (AED 2m property) for airport access, business banking, and optional OpCo HQ. (u.ae)
- Lifestyle/asset kicker
- Greece GV with targeted yield property (zone dictates €250k/€400k/€800k) or €350k financial-asset route; model net yield after Greek taxes and maintenance. (Global Citizen Solutions)
- Asia option
- Add Thailand LTR (if you’ll winter there or hire regionally). Confirm asset and income thresholds under 2025 updates before filing. (KPMG)
Budget (planning-level, family of 4)
- Portugal (fund route): Investment €250k–€500k+; fees €15k–€35k. (Get Golden Visa)
- Greece (real estate): Investment €250k / €400k / €800k; deal costs ~10–13% (tax/fees); gov/legal €18k–€35k. (Global Citizen Solutions)
- Italy (investor visa): Investment €250k–€2m; flat tax €200k/yr (+ €25k per dependent); setup €8k–€20k. (Investor Visa)
- UAE GV (property): AED 2m property; initial visa/ID/medicals AED 12k–25k. (u.ae)
- Thailand LTR: Investment US$500k (if using WGC track) + fees US$3k–8k. (LTR Visa Thailand)
Risk & Compliance (the boring stuff that saves you)
- Source of Funds (SoF) / Source of Wealth (SoW): pre-package bank letters, audited statements, and sale agreements; cut settlement delays.
- CRS/FATCA: align account openings with your actual tax residence and day-count.
- PE/CFC traps: if OpCo contracts, teams, or directors sit in one country, you may create permanent establishment or controlled foreign company issues. Place substance where profits accrue.
- Treat naturalization as earned, not automatic: time-in-country, language, and integration are decisive in Portugal (~5 yrs), Greece (~7 yrs), Italy (~10 yrs)—and Spain no longer offers a GV path. (Portugal Pathways)
Quick chooser (what should you pick?)
- I want EU passport runway + flexible investing (not property): Portugal (fund) → UAE GV backup. (Portugal Pathways)
- I want an EU base and I’m fine with property at higher tickets: Greece (target €400k/€800k zones for prime). (Global Citizen Solutions)
- I want predictable taxes on global income: Italy + €200k flat tax (run OpCo via UAE/LU as needed). (Italian Citizenship Assistance –)
- I want lifestyle + Asia hub, not a passport: Thailand LTR add-on. (LTR Visa Thailand)
Bottom Line for Invest Offshore Readers
If you want tax residence + a credible path to a future EU passport, today’s pragmatic shortlist is Portugal (non-property routes) and Greece (tiered property or financial assets)—with Italy compelling for high-net-worths pairing the investor visa with the €200k flat-tax election. For lifestyle + business hubs without a passport path, UAE and Thailand LTR shine.
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