Securing Your Future: A Comprehensive Guide to Portugal and Italy's Golden Visas
A strategic analysis for U.S. investors and advisors seeking European residency through investment
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The Rise of Global Mobility Strategies
Beyond Contingency Planning
Pursuing global mobility and alternative residencies has become an increasingly prominent strategy for U.S. high-net-worth individuals (HNWIs) and their families. This trend reflects a proactive approach to long-term planning, where securing a "Plan B" extends beyond mere contingency.
Lifestyle Enhancement
What was once considered a backup plan is evolving into a primary strategy for diversifying personal and financial interests on a global scale. This shift is driven not just by a desire for safety or stability, but by the allure of desirable European countries, access to different cultures, educational systems for children, and new business or retirement environments.
Leading European Options
Within this landscape, Portugal's Golden Visa and Italy's Investor Visa program have emerged as two of the most discussed options, each offering unique pathways to European residency and potential citizenship.
Portugal vs. Italy: Core Program Features
Portugal Golden Visa
Program Type
Residency-by-investment ("Golden Visa") program
Minimum Investment
€250,000 (donation to cultural heritage). Other popular options include €500,000 in investment funds
Processing Time
~2 months on average (government aiming for this timeframe with 2024 fast-track measures). Historically 2-8 months
Residency Permit Validity
Initial 2 years, renewable for 3 years (2+3 structure)
Physical Stay Requirements
Very low: 7 days in first year, 14 days per subsequent 2-year period (total 35 days over 5 years)
Italy Investor Visa
Program Type
Residency-by-investment (Investor Visa) program
Minimum Investment
€250,000 (innovative startup). Other options: €500,000 (Italian company), €1M (philanthropic donation), or €2M (government bonds)
Processing Time
~3 months (Nulla Osta in ~30 days, total under 3-4 months); one of the fastest in Europe
Residency Permit Validity
Initial 2-year visa, converts to 2-year residence permit upon arrival, renewable for 3 additional years (2+3 structure)
Physical Stay Requirements
Minimal: No full-time residency required to maintain visa. Visiting ~once per year is practically sufficient for renewal
Path to Citizenship & Family Inclusion
Portugal Citizenship Path
Eligible after 5 years of legal residency
  • Minimal physical presence required (35 days over 5 years)
  • A2 level Portuguese language exam
  • Clean criminal record
  • Demonstrate ties to Portuguese community
Dual citizenship allowed with U.S.
Italy Citizenship Path
Eligible after 10 years of continuous actual residency
  • Must physically reside in Italy for majority of each year
  • B1 level Italian language proficiency
  • Evidence of sufficient income generated in Italy
  • Show successful integration into Italian society
Dual citizenship allowed with U.S.
Family Inclusion
Portugal: Spouse/partner, children under 18, dependent adult children up to 26 (unmarried, full-time education), dependent parents over 65
Italy: Spouse, children under 18, adult children only if unable to support themselves due to serious health conditions, dependent parents over 65
Portugal's Golden Visa Investment Options

Investment Funds (€500,000)
Most popular option post-2023 reforms
Cultural Heritage Donation (€250,000)
Non-refundable contribution to arts/culture
Business Investment (€500,000)
Must create 5+ jobs or preserve 10+ jobs
Scientific Research (€500,000)
Contribution to research institutions
A pivotal development for Portugal's Golden Visa was the "Mais Habitação" (More Housing) law enacted in 2023. This legislation brought an end to all real estate-based investment options for the Golden Visa program, including direct property purchases and real estate rehabilitation projects. The €1.5 million capital transfer option was also removed.
The investment must be made upfront, either before or at the time of submitting the Golden Visa application, and proof of this commitment must accompany the application.
Italy's Investor Visa Investment Options

Innovative Startup (€250,000)
Lowest entry point but highest risk
Italian Company (€500,000)
Investment in established businesses
Philanthropic Donation (€1,000,000)
Non-refundable contribution to public interest
Government Bonds (€2,000,000)
Highest security but largest investment
A key procedural advantage for Italy is that applicants first submit their visa application indicating their chosen investment. Only after receiving a certificate of no impediment (Nulla Osta) from the Investor Visa Committee do they need to make the investment. This must be completed within three months of entering Italy on the investor visa.
This "invest later" model is a significant de-risking feature, as capital is not committed until eligibility is confirmed, preventing funds from being tied up unnecessarily if an application were to fail for unforeseen reasons.
Application Process & Timeline Comparison
1
Portugal Application
Make qualifying investment first
2
Submit to AIMA
Agency for Integration, Migration and Asylum
3
Biometric Data
In-person appointment required
4
Approval
~2 months (target) to 8 months (historical)
1
Italy Application
Submit online to Investor Visa Committee
2
Nulla Osta
Pre-approval within ~30 days
3
Obtain Visa & Travel
From Italian consulate in home country
4
Residence Permit
Convert visa at local Questura within 8 days
5
Complete Investment
Within 3 months of entry
Physical Presence Requirements
7
Days in Portugal
Minimum stay required in first year
14
Days per Period
Required in each subsequent 2-year period in Portugal
35
Total Days
Minimum physical presence in Portugal over 5 years
1
Annual Visit
Approximate minimum visits to Italy per year to maintain visa
Both programs have exceptionally low physical presence requirements for maintaining residency status. However, a critical distinction arises for Italy: while the visa can be maintained with minimal visits, citizenship eligibility requires actual, continuous long-term residence in Italy, not just periodic visits.
Residency Permit Validity & Renewal
Initial Permit
Both programs issue initial 2-year permits
Renewal Requirements
Maintain investment and meet minimal stay requirements
Renewal Period
Both follow 2+3 year structure (5 years total)
Path to Permanent Status
Both offer permanent residency after 5 years
For Portugal, renewals are contingent upon demonstrating that the qualifying investment has been maintained and that the minimal physical stay requirements have been met.
For Italy, renewal requires showing that the investment has been continuously maintained and that the applicant has a clean criminal record. The renewal application is reviewed by the Investor Visa Committee, and approval rates are historically high provided all conditions are met.
Tax Implications for U.S. Citizens
U.S. Worldwide Taxation Principle
U.S. citizens (and green card holders) are taxed by the United States on their worldwide income, regardless of where they reside, unless they formally renounce their U.S. citizenship. The special tax regimes offered by Portugal and Italy primarily affect the local tax liability in those countries on certain types of income.
Portugal's NHR 2.0 / IFICI Regime
The IFICI regime aims to attract qualified professionals engaged in specific high-value activities. Those who qualify and become Portuguese tax residents can benefit from a flat 20% tax rate on their Portuguese-sourced employment or self-employment income from eligible activities for a period of 10 years.
Furthermore, they may be exempt from Portuguese tax (0% rate) on most categories of foreign-sourced income, including dividends, interest, capital gains, and rental income, provided certain conditions under tax treaty rules are met.
Italy's €200,000 Annual Flat Tax
Individuals who transfer their tax residence to Italy can opt to pay an annual lump-sum substitute tax of €200,000 on all their foreign-sourced income, regardless of the actual amount of that income. This regime can be applied for up to 15 years.
A significant advantage of this regime is the exemption from detailed reporting of foreign assets in the Italian tax return. Furthermore, individuals under this regime are exempt from Italian inheritance and gift taxes on assets held outside Italy.
Tax Residency Optionality
A key benefit for Plan B investors is that neither the Portuguese Golden Visa nor the Italian Investor Visa forces an individual to become a tax resident of that country if their physical presence remains below the threshold for tax residency (typically less than 183 days per year). This allows HNWIs to hold the residency option while primarily remaining U.S. tax residents.
Portugal's Tax Benefits for New Residents
20% Flat Tax Rate
On Portuguese-sourced employment or self-employment income from eligible high-value activities
0% Tax on Foreign Income
Exemption from Portuguese tax on most categories of foreign-sourced income under certain conditions
10-Year Benefit Period
The IFICI regime benefits last for a decade from becoming a tax resident
Cryptocurrency Advantage
Gains from crypto assets held for more than 365 days are generally tax-free for individuals
Eligibility for IFICI is stricter and more narrowly defined than the old NHR. It is no longer a universal tax break for all new residents. Notably, retirees living primarily off passive foreign income, who were significant beneficiaries of the old NHR, are less likely to qualify under the new IFICI rules unless their income or activities fall within the specified professional categories.
Italy's Tax Benefits for New Residents
€200,000 Annual Lump-Sum Tax
Fixed annual payment covers all foreign-sourced income regardless of actual amount, potentially offering significant savings for ultra-high-net-worth individuals with substantial foreign income
Family Extension Option
The flat tax regime can be extended to qualifying family members for an additional annual lump-sum payment of €25,000 per member
Simplified Reporting
Exemption from detailed reporting of foreign assets (e.g., bank accounts, real estate) in the Italian tax return
Inheritance Tax Exemption
Individuals under this regime are exempt from Italian inheritance and gift taxes on assets held outside Italy
15-Year Duration
The regime can be applied for up to 15 years, offering long-term tax planning stability
Quality of Life Comparison
Portugal Lifestyle
  • Consistently ranks high for expatriate quality of life
  • Mild climate, particularly in Lisbon and the Algarve
  • Stunning coastline and rich history
  • English widely spoken in major cities
  • Lower cost of living than many Western European countries
  • Renowned for safety, often cited as one of the most peaceful countries globally
  • Laid-back, family-friendly environment
  • Access to public National Health Service (SNS)
Italy Lifestyle
  • Unparalleled cultural lifestyle, steeped in art, history, fashion, and world-renowned cuisine
  • Diverse regions from Alpine north to Mediterranean south
  • English spoken in tourist centers, but Italian beneficial for deeper integration
  • Cost of living varies significantly by region
  • Major cities like Rome and Milan can be expensive
  • Smaller towns and southern regions can be quite affordable
  • Highly regarded public healthcare system (SSN)
  • Rich social fabric and community life
Travel and EU Mobility Benefits
Schengen Area Access
Both Portuguese and Italian residence permits grant the holder and their included family members the right to live in the issuing country and travel freely throughout the Schengen Area, which comprises 27 European countries without internal border controls.
Unrestricted Travel
Residence permits override the standard 90-day Schengen limitation for tourists, allowing for much longer stays and greater flexibility in exploring Europe.
EU Citizenship Benefits
Upon obtaining citizenship, you gain an EU passport granting visa-free or visa-on-arrival access to over 180 countries worldwide.
Freedom of Movement
EU citizenship confers the right to live, work, study, and retire in any other EU member state, as well as in EEA countries and Switzerland.
Program Stability and Recent Changes
Portugal's Recent Changes
Portugal implemented significant changes in late 2023 with the "Mais Habitação" law, most notably eliminating real estate investment as a qualifying option for the Golden Visa. The program was restructured to focus on other investment types like funds, donations, and business investments, but it was not terminated.
These changes do not retroactively affect existing Golden Visa holders. A new "Portugal Social Support Visa," potentially requiring a €250,000 donation to social projects, is also reportedly being introduced, though final details are pending.
This overhaul, while grandfathering existing investors, has introduced a degree of uncertainty for new applicants and signaled a potential shift in the program's long-term direction.
Italy's Program Stability
Italy's Investor Visa program has demonstrated greater stability in recent years, with no major restrictive changes. In fact, past adjustments included reductions in investment thresholds for startup and company investments to attract more applicants.
The government has also focused on streamlining the application process. The most notable recent changes were the 2023 suspension of applications from Russian and Belarusian nationals due to EU sanctions, and a fiscal policy change in 2024 that increased the annual flat tax for new high-net-worth residents from €100,000 to €200,000.
Italy's program has reportedly seen growing interest, particularly as other European countries have paused or restricted their own Golden Visa offerings.
Who Should Choose Portugal's Golden Visa?
Fast-Track to EU Citizenship
Those prioritizing obtaining EU citizenship as quickly as possible, leveraging Portugal's five-year timeline with minimal physical presence requirements
Families with Adult Children
Applicants needing to include financially dependent adult children up to age 26 (who are unmarried and in full-time education) in their application
High-Value Professionals
Qualified professionals in high-value sectors who can benefit from Portugal's IFICI tax regime, offering a 0% tax on most foreign income and a 20% flat tax on eligible local earnings
Fund Investment Comfort
Investors comfortable with investment fund structures as the primary investment route, given the removal of direct real estate options
Lifestyle Seekers
Those attracted to Portugal's mild climate, coastal lifestyle, safety, and relatively lower cost of living compared to other Western European destinations
Who Should Choose Italy's Investor Visa?
Speed Prioritizers
Those seeking the quickest possible acquisition of initial European residency, with Italy's ~3-month processing time being a major advantage for immediate access or relocation
Lower Entry Point Seekers
Investors attracted by a lower minimum investment entry point, such as the €250,000 for an innovative startup (albeit with higher associated risk)
Ultra-High-Net-Worth Individuals
Those who can benefit from the €200,000 annual flat tax on all foreign-sourced income, especially with substantial global earnings
Risk-Averse Investors
Those who appreciate the procedural benefit of investing after visa pre-approval (Nulla Osta), reducing upfront financial risk
Italy Enthusiasts
People with a strong cultural affinity for Italy who are potentially planning for genuine long-term settlement, which is a prerequisite for its 10-year path to citizenship
Long-Term Planning Considerations
Generational Benefits
EU citizenship for children opens doors to education, work, and enhanced mobility across Europe, transforming the visa into a legacy asset that can benefit multiple generations of your family.
Inheritance Planning
Residency permits themselves are not directly inheritable. Estate planning is crucial to ensure that the qualifying investment can be maintained by heirs if the main applicant passes away, thereby preserving the family's residency status.
Investment Exit Strategies
Investors must plan for the eventual divestment of their qualifying investment, typically possible after achieving permanent residency (usually after 5 years in both countries) or citizenship.
Program Rule Changes
The investment migration landscape is subject to change. Acting sooner rather than later can be advantageous if a program's current terms are attractive. Existing permit holders are generally grandfathered under the rules applicable at the time of their approval.
Professional Guidance is Essential
Immigration Lawyers
Specialized in the chosen country's program to navigate the application process
  • Document preparation and verification
  • Application submission and follow-up
  • Regulatory compliance
Financial Advisors
To assess the suitability of investment options
  • Investment risk assessment
  • Portfolio integration
  • Exit strategy planning
Cross-Border Tax Advisors
Crucial for understanding tax implications
  • U.S. tax obligations
  • Host country tax planning
  • Special tax regime eligibility
Real Estate Consultants
For those planning to purchase property
  • Location assessment
  • Property valuation
  • Purchase process guidance
Given the financial commitments, legal complexities, evolving regulations, and critical U.S. tax implications (due to U.S. taxation on worldwide income), seeking comprehensive advice from qualified professionals is not just recommended, it is essential.
Making Your Informed Choice for a European Future
Both the Portuguese Golden Visa and the Italian Investor Visa offer compelling and valuable solutions for U.S. high-net-worth individuals and families seeking a strategic "Plan B" and enhanced global access. However, they cater to distinctly different priorities, timelines, and financial considerations.
Portugal stands out for its efficient pathway to EU citizenship with minimal physical presence and generous family inclusion policies. Italy offers rapid initial residency, a potentially lower investment threshold, and a unique tax regime for the ultra-wealthy, coupled with its undeniable lifestyle appeal.
The optimal choice is not universal; it hinges on a meticulous assessment of an individual's or family's specific long-term vision, financial capacity, risk appetite, and lifestyle preferences. By carefully weighing these factors, U.S. investors can make an informed decision that best aligns with their aspirations for a secure and enriched future in Europe.