Italy vs Portugal Golden Visa: Head-to-Head Comparison for 2026

All figures carry a last-verified date. Re-verify against the source before making an investment decision.

The Italy Investor Visa — formally the Visto per Investitori — was introduced by the Italian 2017 Budget Law (Law 232/2016) and is administered by the Ministry of Enterprises and Made in Italy (MIMIT). As of June 2026, four investment routes qualify.

The investor subscribes to or acquires equity in an innovative startup registered with the Italian Companies Register under the qualifying criteria established for that classification. This is the programme's lowest entry point and carries the highest risk profile given the early-stage nature of qualifying companies. Capital recovery depends entirely on the company's performance; there is no guaranteed return.

The investor acquires shares or equity capital in a registered Italian limited company operating in Italy that falls outside the innovative-startup classification. This route targets established businesses rather than early-stage ventures.

The investor holds Italian government bonds with a maturity of at least two years. This is the programme's largest minimum outlay. The current threshold is €2,000,000 — a superseded €1,000,000 figure circulates in older content and is no longer correct.

The investor makes a donation to a qualifying Italian non-profit organisation operating in culture, education, immigration management, scientific research, or heritage restoration. This is not a financial investment — the capital is not recoverable.

Unlike Portugal or Greece, Italy does not permit direct real-estate purchases to qualify for the investor visa and has given no indication of adding a property route. As of December 2025, no qualifying investment-fund route exists under the programme.

Non-EU nationals may apply provided they:

• Hold the investable capital outside Italy and can document its source (anti-money laundering due diligence is conducted during the application)
• Meet the minimum investment threshold for their chosen route
• Have a clean criminal record
• Hold valid travel documentation

No prior Italian tax residency, business relationship, or connection to Italy is required before applying.

The Italian investor residence permit is valid for two years on first issue, renewable for further two-year periods while the qualifying investment is maintained at the required level.

Italy's Investor Visa programme does not impose a minimum physical presence requirement to maintain the investor visa permit during its regular validity period. Investors may reside outside Italy for most of the year without surrendering the permit, provided the qualifying investment is maintained.

Physical presence requirements apply at later stages: investors who wish to apply for permanent residency must demonstrate actual continuous residence with at least 184 days per year in Italy. The same threshold applies to the naturalisation stage.

Investors may apply for permanent residency (permesso di soggiorno CE per soggiornanti di lungo periodo) after five years of legal and continuous residence in Italy. Requirements include: at least 184 days per year of physical presence, a minimum level of Italian language proficiency (A2), and no disqualifying criminal record. Permanent residency is a separate administrative route, not an automatic feature of the investor visa programme.

Italian citizenship through naturalisation requires ten years of legal and continuous residence in Italy, with physical presence of at least 184 days per year, plus Italian language proficiency at B1 level, integration, criminal-record, and tax-compliance requirements. Simply holding an Italian investor visa without residing in Italy does not count toward the naturalisation requirement.

Italy's optional substitute-tax regime for new residents under Article 24-bis TUIR is a relevant suitability factor for investors evaluating Italian tax residence alongside the investor visa.

For taxpayers who transfer civil residence (Article 43 Codice Civile) to Italy on or after 1 January 2026:

• Optional substitute tax on foreign-source income only: €300,000 per year
• Supplement per qualifying family member joining the election: €50,000 per year
• Maximum duration of the election: 15 tax periods

Italian-source income remains taxable at ordinary IRPEF rates and is not covered by the substitute tax.

The art. 24-bis election is available only to investors who become Italian tax residents. Establishing Italian tax residence requires fulfilling the Italian residence test (civil-residence registration or 183-day presence rule under TUIR). The investor visa alone does not make an investor an Italian tax resident.

Investors who elected art. 24-bis before 1 January 2026 continue at the rate applicable at their election:

• €200,000/year (+ €25,000 per family member) for elections between August 2024 and December 2025
• €100,000/year (+ €25,000 per family member) for elections before August 2024

The new €300,000/year figure does not apply retroactively to pre-2026 elections.

Required caveats: The flat-tax regime is an election, not a guaranteed tax outcome. Italy is not a zero-tax jurisdiction — ordinary Italian income tax (IRPEF) continues to apply to Italian-source income regardless of the art. 24-bis election. Comparative tax-superiority claims require separate Legal sign-off. Specialist tax advice from a qualified Italian tax adviser is required before making the election.

The Portugal Golden Visa operates as the ARI (Autorização de Residência para Investimento) under Article 90-A of Portuguese immigration law, administered by AIMA (Agência para a Integração, Migrações e Asilo).

Under the Mais Habitação reform, Portugal removed direct real-estate investment as an eligible ARI route, effective late 2023. Property purchases no longer qualify for a Golden Visa. The programme remains open on non-real-estate routes.

Since 2024, the programme has operated entirely on fund-based and qualifying non-real-estate routes. The regulated-fund market for ARI investors is now established, with active CMVM-authorised funds running application pipelines.

Qualifying investment funds or venture capital funds — minimum €500,000

Investment in non-real-estate funds regulated under Portuguese securities law with their registered office in Portugal, investing at least 60% of their portfolio in Portugal-incorporated companies. This is the primary route used by the majority of current ARI applicants.

Support for artistic production or national cultural heritage — minimum €250,000

Contribution to cultural or artistic entities, cultural heritage restoration, or national heritage bodies under conditions defined by the competent Portuguese public authority.

Scientific research route — minimum threshold to be confirmed with AIMA

AIMA Art. 90-A lists a scientific research route. The current minimum investment threshold is not confirmed here — verify directly with AIMA or an authorised adviser before committing capital.

Company capital with job creation — minimum threshold to be confirmed with AIMA

AIMA Art. 90-A lists a company-capital route with job-creation conditions. The current minimum threshold requires direct confirmation with AIMA or an authorised adviser.

The Portugal ARI card is issued for two years on first issue and renewable for further two-year periods while the qualifying investment is maintained.

Portugal requires a low but non-zero minimum physical presence:

• 7 days in the first year of the permit
• 14 days per each subsequent two-year renewal period

This deliberately low threshold allows internationally mobile investors to maintain the permit without relocating to Portugal. It is one of the key distinctions from programmes that require longer annual stays.

Permanent residency is a separate route available after 5 years of legal residence in Portugal, subject to separate requirements including Portuguese language proficiency and a clean criminal record. Permanent residency is not automatic and requires a separate application to AIMA.

Portugal's naturalisation rules changed materially with Lei Organica n. 1/2026, published in Diário da República n. 95/2026 and in force from 2026-05-19.

For nationality applications filed from 2026-05-19 onward:

• CPLP nationals (Portuguese-speaking countries) and EU/EEA nationals: 7 years of legal residence required
• All other nationalities: 10 years of legal residence required

Administrative nationality procedures already pending at IRN (Instituto dos Registos e do Notariado) on 2026-05-19 remain subject to the prior law under Article 7.2.

Critical compliance note: Permanent residency after 5 years and citizenship are separate milestones. Do not conflate them. Current Portugal Golden Visa holders are not grandfathered for citizenship unless a nationality procedure was already pending before 2026-05-19.

Portugal's NHR (Non-Habitual Resident) regime closed to new applicants in early 2025. Its successor — IFICI (Incentivo Fiscal à Investigação Científica e Inovação) — is narrower and activity-gated.

• Legacy NHR: Applies to individuals who registered as NHR by 31 March 2025 and remain within their ten-year window. Not available to new applicants.
• IFICI: Open to new tax residents from April 2025. Covers qualified professionals in scientific research, technology, innovation, and other defined high-value activities. Passive investors, retirees, and most investment-income recipients do not qualify. Application requires approval from a competent entity before AT (Autoridade Tributária) registration.

Key practical point: A Portugal ARI residence permit does not automatically create Portuguese tax residence. Many investors hold the permit, visit Portugal 7–14 days per year as required, and remain tax resident elsewhere. Crossing the 183-day threshold or maintaining a habitual home in Portugal on 31 December triggers tax residence.

Tax implications of the Portugal ARI — and any special regime — require qualified Portuguese tax advice before triggering tax residence.

The investment structure under each programme materially affects capital risk, liquidity, and exit options.

The government-securities route offers the most predictable capital-recovery framework but requires the largest outlay. Startup equity provides the lowest entry point but carries commensurate venture risk and limited secondary-market liquidity. The philanthropic route involves permanent capital transfer with no investment return.

Portugal ARI's fund route requires €500,000 in a regulated Portuguese investment fund. Key considerations before committing:

• Funds must invest at least 60% of their portfolio in Portugal-incorporated companies.
• Holding periods, redemption windows, and liquidity terms vary by fund. Review the fund's prospectus and subscription documentation.
• The investment must remain committed while the ARI is active; early redemption may affect permit status.
• CMVM-regulated funds provide a standardised oversight framework absent from Italy's direct-investment routes, but neither oversight nor regulation eliminates investment risk.

Consult a qualified financial adviser and review the relevant fund prospectus before committing capital to either programme.

Both programmes allow the primary investor to include close family members under their permit.

Family members receive their own permits and may reside in the country for the duration of the principal investor's permit. For both programmes, dependants must typically gather documentation simultaneously with the main applicant given parallel processing timelines. Confirm current family-inclusion conditions with the relevant authority or an authorised adviser before applying.

Two significant legislative developments in the twelve months to June 2026 directly affect this comparison.

From 2026-05-19, most non-EU and non-CPLP nationals must accumulate 10 years of legal residence before applying for Portuguese naturalisation. The prior rule continued only for applications already pending at IRN before that date.

If Portuguese citizenship within the shorter prior timeframe was the primary objective, this change materially alters the calculation. The 10-year track is now the realistic timeline for most nationalities choosing the Portugal ARI from 2026 onward.

The Italy art. 24-bis substitute tax rose to €300,000 per year for new Italian tax residents establishing civil residence from 1 January 2026 onward. The family-member supplement also increased to €50,000 per year.

Investors who planned to combine the Italy Investor Visa with art. 24-bis Italian tax residence now face a materially higher annual flat-tax cost compared with pre-2026 figures. Investors who elected art. 24-bis before January 2026 are grandfathered at their election-date rate.

The Portugal ARI has operated exclusively on fund-based and qualifying non-real-estate routes since late 2023. The programme has stabilised, AIMA has continued processing applications, and the regulated-fund market for ARI investors is now active with multiple CMVM-authorised funds.

The right programme depends on individual circumstances that only an authorised adviser can assess. The following is a general orientation, not a personalised recommendation.

Italy Investor Visa may be relevant for investors who:

• Can commit €250,000–€500,000 in equity-linked instruments or €2,000,000 in government securities
• Prefer direct investment into the Italian economy over a pooled fund structure
• Are prepared for a 10-year naturalisation track with at least 184 days/year physical presence
• Are considering Italian tax residence and the art. 24-bis regime (subject to specialist tax advice and eligibility assessment)
• Are comfortable with the programme's direct-investment risk profile across four asset classes

Portugal ARI may be relevant for investors who:

• Prefer a regulated, fund-based investment structure of €500,000 within an established CMVM-oversight framework
• Want to maintain European residency with minimal physical presence (7–14 days per year)
• Have a long-term objective of Portuguese permanent residency after 5 years
• Accept the 10-year naturalisation track for most nationalities (or qualify for the 7-year CPLP/EU track)
• Value AIMA's digital processing infrastructure and the active ARI practitioner market

Important: neither programme is suitable for investors seeking:

• A promise of certain approval — residency and citizenship outcomes for both programmes depend on meeting requirements and administrative processing; neither programme guarantees a result
• A real-estate-linked investment route — neither programme qualifies direct property purchases
• A short-term commitment — both require sustained capital over a multi-year period
• A rapid citizenship timeline — both programmes require years of legal residence before naturalisation eligibility

The headline investment minimum is not the full cost of either programme. Budget for government processing and application fees, legal and adviser fees (typically scoped per case), document translation and notarisation, and — for Portugal — fund subscription fees and annual management charges. These add up and vary by adviser and fund selection.

Before committing to either route, ask your adviser for a full itemised projection that covers the initial investment, application costs, renewal fees over the expected holding period, and any fund-level costs. The difference between programmes often becomes clearer once you compare the complete cost picture.

Italy Investor Visa and Portugal ARI suit different investor profiles, capital structures, tax situations, and timelines. If you are evaluating either programme as part of a wider residency or global-mobility strategy, My Golden Visa lawyers can assess your specific circumstances, eligible routes, family situation, and current processing conditions.

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My Golden Visa is an authorised investment migration consultancy. This article is for informational purposes only and does not constitute legal, tax, or financial advice. Programme rules change without notice; verify current requirements with a qualified adviser before making an investment or immigration decision.