Portugal’s recent reforms have effectively ended the country’s most popular pathway for high‑net‑worth individuals: the Golden Visa tied to real‑estate purchases. Starting in 2024 the Non‑Habitual Resident (NHR) tax regime—once a major draw for retirees and crypto investors—will be replaced by a standard tax rate that can reach 40‑50 % on worldwide income. The changes remove the low‑tax advantage that made Portugal a favored destination for wealthy expatriates.
What the Portuguese changes mean
- Golden Visa by real estate eliminated – Only investment‑ or science‑based visas remain, which are less straightforward for most applicants.
- NHR tax exemption phased out – From 2024, foreign‑source income, including pensions and crypto gains, will be taxed at the regular Portuguese rates (up to 50 %).
- Impact on retirees and crypto investors – Those who previously paid minimal tax on pensions or crypto profits will now face substantially higher liabilities.
These reforms push many prospective residents to look elsewhere in Europe for more favorable tax and residency options.
Alternative European programs for high‑net‑worth individuals
Italy – €100 k lump‑sum tax regime
- Flat tax: €100 000 per year on worldwide income, regardless of the actual amount earned.
- Eligibility: Targeted at individuals with annual profits exceeding €1 million.
- Residency and citizenship: An easy residency permit can be obtained by paying the lump sum; after ten years of residence, applicants may apply for Italian citizenship.
- Lifestyle: Access to diverse climates—from Alpine north to Mediterranean south (e.g., Milan, Sicily, Sardinia).
Spain – Golden Visa + Beckham Law
- Golden Visa routes:
- Deposit €1 million in a Spanish bank, or
- Purchase property for at least €500 000.
- Beckham Law tax exemption: Offers a 5‑year (extendable to 6 years) reduced tax rate on foreign‑source income, effectively 0 % tax on income earned outside Spain.
- Domestic tax: Only Spanish‑source income (e.g., a €20 000 local bank deposit) is taxed.
- Citizenship shortcut: Citizens of Latin American countries (including Puerto Rico) can apply for Spanish citizenship after two years of residence.
Malta – Permanent residency and citizenship by investment
- Residency by donation: €150 000 contribution grants permanent residency, allowing lifelong residence.
- Citizenship by donation: Approximately €1 million can secure Maltese citizenship.
- Tax regime: Flat 10 % personal income tax; long‑term crypto holdings are exempt, making it attractive for investors planning large exits.
Greece – Real‑estate Golden Visa
- Investment thresholds: €250 000 in most areas, or €500 000 in prime locations such as Athens or Santorini.
- Residency: No minimum stay required; the visa can be maintained indefinitely as long as the investment remains.
- Citizenship path: After seven years of residence, applicants may apply for citizenship, though approval is unlikely without actual residence and language proficiency.
Key considerations for prospective applicants
- Tax exposure: Compare the effective tax rate on worldwide income versus the flat‑tax or exemption regimes offered by each country.
- Investment size vs. benefit: Real‑estate requirements (Spain, Greece) can be higher than lump‑sum contributions (Italy, Malta).
- Residency obligations: Some programs (Italy, Malta) require physical presence only for citizenship, while others (Spain’s Beckham Law) allow limited tax residency with minimal domestic income.
- Long‑term goals: If the primary aim is a second passport, assess the timeline to citizenship (e.g., ten years in Italy, two years in Spain for certain nationals, seven years in Greece).
These alternatives illustrate that, despite Portugal’s tightening of its Golden Visa and tax incentives, other European jurisdictions still provide pathways for wealthy individuals to obtain residency or citizenship while maintaining favorable tax positions.
