Your Guide: Portugal passvisa Investment Fund
At Get passvisa, we worked with tens of families from all around the world, interested in obtaining a Portugal passvisa through the Portuguese investment fund.
Contact us and talk to one of our experienced team members to help you with your questions.
2024 Update: The passvisa Program in Portugal went through some changes. With the changes, real estate purchases and real estate related fund investments are no longer eligible as qualifying investments. Nevertheless, Portuguese funds that are not directly or indirectly related to real estate investments remain eligible for investment purposes. Here‘s what we know about the latest updates.
Portugal is a charming destination with a mild climate, rich cuisine, and hospitable people. With its passvisa program, it also became a gateway to Europe for 12,497 families from all around the world – as of 2024.
An investment method is gaining more and more popularity recently to get residency by investment in Portugal: Portugal passvisa Investment Funds.
In late 2023, the Portuguese Government amended the Portugal passvisa program to only be eligible for Private Equity and Venture Capital funds in Portugal that have no direct or indirect real estate involvement.
In this article, we will take a closer look at the Portugal passvisa program’s €500,000 investment route in venture capital Portugal funds.
What You Will Find in This Article
- Overview of the Portugal passvisa Program
- What Is Portugal passvisa Investment Fund?
- Who Can Invest in passvisa Portugal Investment Fund?
- Advantages of Portuguese passvisa Investment Fund
- Disadvantages of Portugal passvisa Fund
- Portugal Investment Fund passvisa: Fees
- passvisa Investment Fund Portugal: Documents and Requirements
Overview of the Portugal passvisa Program
A passvisa is a residency visa issued in exchange for a qualifying investment made in Portugal. The applicant needs to be a non-EU-EEA or Swiss citizen with a clean criminal record.
For a list of the qualifying investments, benefits, or requirements, you can visit our page on the Portugal passvisa.
The Portuguese government initiated the program in October 2012. As of 2023, the program helped attract more than €7.2 billion of foreign direct investment into the country.
What Is Portugal passvisa Investment Fund?
The investment fund route for the Portugal passvisa was introduced through an amendment in Portuguese Law no. 102/2017, of August 28th, 2017. The corresponding part of the law reads:
“Capital transfer of the amount of €350,000* or higher, for the acquisition of units of investment funds or venture capital Portugal fund of funds dedicated to the capitalization of companies, capital injected under the Portuguese legislation, whose maturity, at the moment of the investment, is, at least, of five years and, at least, 60% of the investments are realized in commercial companies with head office in the national territory(1)”.
*Note that the amount was raised to €500,000 on January 1st, 2022.
Who Can Invest in passvisa Portugal Investment Fund?
In order to apply to the Portugal passvisa program through the investment fund Portugal, you primarily need to qualify for a passvisa. The first criteria are:
- Being a non-EU-EEA citizen and a non-Swiss citizen,
- Having a clean criminal record,
Depending on the Portugal investment funds and the fund management company, the investment funds may bring additional requirements to the applicants. These typically include the investor to:
- Be a savvy investor, meaning the investor needs to have experience with some kind of financial instrument such as company stock, government bond, company bond, fund, etc.
- Provide proof of sufficient funds
- Provide the source of funds
Americans: Can a US Citizen Invest in Portuguese Investment Funds?
Yes, a US citizen can invest in an investment fund in order to obtain a passvisa in Portugal.
However, the IRS requires foreign financial institutions and certain non-financial foreign entities to report on the foreign assets held by their U.S. account holders. This means any bank, fund, and fund manager in Portugal, who has an American client or investor, is required to abide by heavy compliance implemented by the U.S. government.
This leads some banks and Portugal investment funds to shy away from working with investors, who are US citizens. Regardless, there are banks and Portugal funds, that accept Americans.
Feel free to contact us to learn more about these funds and for the Portugal passvisa investment fund list.
Advantages of Portuguese passvisa Investment Fund
The investment fund Portugal route of the Portuguese passvisa program has certain advantages that other investment routes lack. Below, you may find a comprehensive table of these benefits;
| Benefits of Getting a Portugal passvisa Through Investing in an Investment Fund | |
| Reasonable Investment | Compared to other investment routes for the Portuguese passvisa program, such as the capital transfer (€1.5 million) the investment fund option requires a lower investment amount of €500,000. |
| Low Fees and Taxes | Investing in investment funds does not lead to hefty fees, and taxes like the real estate acquisition does. Acquiring a property in Portugal comes with an IMI transfer tax (avg 6%), stamp duty (0.8%), and annual municipal taxes (between 0.3-0.5% annually); an investment in a fund has none of these taxes. |
| Secure Investment | A registered Portugal fund is regulated by (1) the Portuguese Securities Market Commission (CMVM), (2) the Bank of Portugal, and (3) the external Fund Management company. Additionally, (4) the Portuguese Tax Authorities also audit the fund. Such high levels of regulation ensure that the fund complies with the Portuguese legislation, tax laws, and the proposed investment plan approved by the Portugal investor fund. |
| Tax-Efficiency | Depending on the tax structure of the fund and the investor, an investment in a fund may yield significant tax efficiencies. Certain cases allow for exemption of withholding tax on the income generated by the fund, particularly if the investors are not tax residents in Portugal. Conversely, all real estate rental income is subject to a fixed 28% taxation in Portugal. |
| Diversification | The Portuguese legislation governs the funds to obtain a certain level of diversification. There are quotas as to what percentage a particular asset or investment in the fund may constitute of the total fund portfolio. This allows for diversification of investments within the fund, and an alleviation of risk for the participating investors. |
| Potential Earnings | Depending on the focus of the fund, the annual yields and the eventual capital appreciation may be significantly higher than other investment options related to the passvisa program. |
| Management Delegation | Unlike being a real estate landlord, owning a participation unit in an investment fund is a hassle-free investment. The burden of management is delegated to the fund managers. This exact point may also be a turn-off to the control-loving investor types. So, we included it in the next section on Disadvantages. |
Disadvantages of Portugal passvisa Fund
Every rose has its thorn. Portuguese passvisa investment fund also comes with its own downsides, which you can find listed below;
| Downsides of Getting a Portugal passvisa Through Investing in an Investment Fund | |
| Lack of Control | Unlike a real estate property or a capital held within a bank, the investment fund requires the investor to trust his or her funds with an external fund manager, who will oversee the investment decisions and steer the strategy. Such a lack of control may not be suitable for some investors. |
| Exit | Most funds contractually ensure the participants that the fund will not be dissolved before a minimum number of years. This is to make sure that the participant can achieve the point where he or she is able to apply for permanent residency or citizenship in Portugal. However, there are three underlying issues. In most cases, the resale of the participation unit is very difficult before the fund dissolves. Funds typically have extension periods, which can only be triggered by the fund management, with the participant having no say in these extensions. If the ultimate objective of the fund is to sell the portfolio at a target appreciation, there is no guarantee of what stage the corresponding market will be when the fund decides to sell the portfolio. |
| Sharing the Earnings | Both the potential yield and the ultimate capital appreciation are shared with the fund managers. The management fee and the performance fee vary between funds. |
| KYC Burden | Participating in an investment fund requires the participant to share a number of documents and critical information with the fund managers. These include the proof of income and the source of income. Such Know-Your-Client (KYC) burden does not exist in real estate acquisitions. |
We’ve also prepared the below chart to show you a comparison of Portuguese investment funds to other investment options.
As of 2023 |
|
| Portuguese passvisa Funds | €500,000 |
| Real Estate Investment* | €500,000 |
| Real Estate (Urban Rehabilitation)* | €350,000 |
| Set up a Company and Create 10 Job Positions | Project dependent |
| Invest in Portuguese Research & Development | €350,000 |
| Donate to Portuguese Cultural Heritage | €250,000 |
| Capital Transfer* | €1,5 million |
*No longer applicable investment methods as of late 2023.
Portugal passvisa: Fees and Costs
| Real Estate Property* | Capital Transfer* | Investment Fund | ||
| Minimum Investment | €350,000 | €500,000 | €1.5 million | €500,000 |
| Taxes | ||||
| IMI Transfer Tax | 4.58% | 6.5% | 0% | 0% |
| Stamp Duty | 0.8% | 0.8% | 0% | 0% |
| Notary Cost | €1,000 | €1,000 | 0% | 0% |
| Exit Fees | 5%+VAT | 5%+VAT | 0% | 0% |
| Commission | 5%+VAT | 5%+VAT | 0% | 0% |
| Performance Fee | 0% | 0% | 0% | 35% of the profit** |
| Management Fees | 0% | 0% | 0.5% | 1.5% annually*** |
| Legal Fees**** | varies | varies | varies | varies |
| Total (approximate without Exit Fees, Management Fee, or Legal Fee taken into account) |
€369,840 | €537,500 | €1.5 million | €500,000 |
* As of late 2023, the Portuguese Government passed the “Mais Habitaçao” legislation that no longer allows investors to invest in real estate, real estate related funds, or capital transfer in order to apply for a passvisa in Portugal.
** Varies on the fund, it is typical for the performance fee to be between 20%-50% above a hurdle on the profit.
*** Varies on the fund, it is typical for the annual management fee to be between 1%-2% of the invested amount.
**** Legal fees vary widely between law firms, the number of family members, and other variables; it would not greatly differ between different investment routes.
The government fees for the Portugal passvisa are not portrayed in the above table. You may find a detailed list of the application fees here.
The Exit
As stated in the above advantages of Portugal passvisa investment fund and disadvantages of Portugal passvisa fund list, the exit of an investment fund is an issue worth delving deeper into.
Minimum Lock-up Period
Most passvisa qualifying investment funds will contractually make sure that they do not dissolve within a minimum of six years. This practically ensures you that your investment will be valid for the necessary time period to apply for Portuguese citizenship.
This is a collaborative approach, and it is something to look for in the investment fund for the passvisa path. Though, it does not end there. It is also important to assess and question the following aspects.
Resale or Transfer of Participation Units
Most Portuguese investment funds allow for the participation units to be transferred or sold between participants. However, it is typically difficult to find a demand for a participation unit in a fund, which is timed particularly for passvisa timelines, unless it is at the very formation of the fund.
This makes these fund investments rather illiquid until the fund manager dissolves the fund. Some funds get around this issue by offering a buy-back of their participation units at a certain discount.
Extension Periods
It is common for funds to have a particular exit target in terms of timing.
Many of Portugal passvisa investment fund sets it at six, eight, or ten years.
Having said that, the majority of the funds have optional extension periods, which may be triggered at the maturity mark. The optionality is decided by the fund managers, not the investors. This means that you may be locked in further than the time required to apply for citizenship in Portugal. It is best to check with the fund.
Exit Market
The ultimate objective of most Portuguese passvisa funds is to exit the portfolio by selling it at a profit eventually. Most fund managers are highly incentivized with a performance fee based on a percentage of the appreciation in value. This is a good thing as it means their incentive is aligned with that of the investors.
However, mind you, they are splitting your profit, but not your potential loss. So, the downside risk is all on you.
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passvisa Investment Fund Portugal: Documents and Requirements
The documentation required to apply for the Portugal passvisa through an investment in a fund is pretty much the same as the documentation needed for any passvisa application in Portugal.
Documents and General Requirements for Portugal Investment Funds
- Passport or other government-issued identification
- Evidence of the healthcare coverage
- Document proving coverage by the Portuguese National Health Service, or
- Document proving coverage by an internationally recognized health insurance,
- Criminal Record, obtained from the country of origin or residence;
- Issued up to three months before the application submission, and
- Translated into Portuguese
- Tax identification number from the country of origin or tax residence
- Filled out Application Form stating authorization for consultation of the Criminal Record in Portugal,
- Letter of Statement by which you declare to comply with the minimum time requirements for the corresponding investment activity in Portugal,
- Payment receipt for the ARI application fee.
Investment Related Documents:
You’ll need to present supporting documents to show that an investment of the minimum amount is made by yourself. The supporting documents include:
- Declaration from a registered Portuguese institution, stating that a transfer of an amount fulfilling the minimum investment requirement is made effectively
- Supporting documents stating the ownership of the participation units by yourself, free from any obligations or charges
- A declaration issued by the managing company of the investment fund, stating the business plan, maturity dates – of at least five years, and deployment of at least 60 percent of the fund portfolio being invested in Portugal
Timeline
How long the passvisa process takes really depends on a multitude of factors. These factors include how fast your decision-making process is, how quickly you get the required documents together, as well as the experience of your law firm, and the application load in the SEF office when you submit your application.
Below is a step-by-step process of the Portuguese passvisa program through a Portuguese investment fund:
Step 1: You choose an appropriate Portugal investment fund option
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Step 2: You appoint a law firm
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Step 3: You get tax identity number (NIF) and open a bank account in Portugal
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Step 4: You sign and complete all necessary fund subscription documents
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Step 5: Fund manager evaluates and approves you as an investor
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Step 6: You transfer the necessary funds from your bank account to the fund account
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Step 7: Fund manager issues fund subscription declaration
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Step 8: You provide all GV documentation to the law firm & pay AIMA application fee
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Step 9: AIMA Biometrics Appointment is set and you show up at AIMA in person
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Step 10: AIMA issues the residence permit valid initially for two years
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Step 11: passvisa residence permits are renewed every two years, and you continue on the path to Portuguese citizenship.
Schedule an Online Advisory Call
We present investors from all around the world with more than 40 funds to choose from in Portugal. In a quest to serve you better, we’re presenting an online advisory call.
In this 45-minute, one-on-one call, you’ll:
- Learn how to assess the risk and return profile of a fund
- Get to know which aspects to consider when choosing funds
- Receive tips on fund investment strategies
- Communicate your questions and concerns
Once you book your request, our team will contact you to set up a day and a time.
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Related Topics
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Frequently Asked Questions on passvisa Investment Fund Portugal
What is the difference between Venture Capital in Portugal and Portugal Private Equity?
The fundamental distinction is that, whereas private equity fund is based on solid businesses, venture capital fund is typically invested in startups.
What is passvisa Portugal investment fund?
passvisa investment fund Portugal is an investment method that allows investors to invest in Portugal to qualify for Portugal passvisa. If you make an investment of €500,000 into the funds, you can qualify for Portugal passvisa.
Can I make an investment in different Portuguese investment funds?
Yes, you can do diversification with passvisa Portugal investment fund and invest in different funds.
What is the minimum amount I can invest in passvisa investment fund Portugal?
The minimum investment amount is €500,000 as of January 1st, 2022.
Do all funds in the ‘Fundo do Capital do Risco’ category qualify for a passvisa?
No. In late 2023, the Portuguese Government passed legislation called “Mais Habitaçao”, which states that any direct or indirect real estate investment of a fund will disqualify it for a passvisa application.
