Costs of securing Golden Visa

Residencies & citizenships Portugal Golden Visa šŸ‡µšŸ‡¹
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I am considering purchasing a semi-detached unit in a development currently under construction by a well-established Portuguese hotel conglomerate in the Algarve that I am hopeful will qualify for the Portugal Golden Visa program. Using the map coordinates provided for the development on Nomad/Gateā€™s Find properties in low- and high-density areas that qualify for Golden Visa in 2022! search engine it gives this result:

Located in a low-density region
The area is considered non-interior
Only non-residential real estate investments are eligible for Golden Visa purposes (such as hotels, offices, etc)
Minimum investment is ā‚¬280,000 for qualified refurbishment/rehabilitation projects, otherwise ā‚¬400,000

So, the apparent question is whether the units being sold in the resort constitutes a non-residential commercial real estate investment (such as hotels, offices, etc.). The proposed purchase price meets the ā‚¬400,000 threshold. However, the fact that the unit is available as a residence if we were to so choose, I am concerned it will not qualify. The developer has a touristic license as it is a large well-established hotel group in Portugal. We do not intend to use the property as a full-time residence during the five-year period to qualify for citizenship under the Golden Visa program and we intend to enter into a rental contract with the developer so that the unit can be rented out for the majority of the year.

Yet, I am concerned that because the property, after purchase, is ours to inhabit as we see fit, that this opportunity (whether it is exercised or not) disqualifies it as a commercial property investment. Does anyone have any insight on this issue?

Does anyone know what is the legal language is for this determination whether it be a regulation or statute or edict? Does anyone know whether there are criteria other than the language of the legal writing itself that the Portuguese government will consider in making its determination on whether such an investment constitutes a non-residential commercial real estate investment?

Does anyone know whether there have been any determinations already passed on by the Portuguese government for similar developments in the Algarve? Nomad/Gateā€™s Find properties in low- and high-density areas that qualify for Golden Visa in 2022! search engine identifies only the Lagos Marina Hotel as available real estate development that qualifies.

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Hi Frank,

I donā€™t know for certain whether your chosen property would qualify as commercial real estate, but to me it does sound like it would (assuming you donā€™t actually reside there for any meaningful portion of the year). That being said, Iā€™m not super familiar with the finer details regarding limitations on your own use of a commercial property. Most of these types of projects that Iā€™ve come across specifies a limited amount of days (perhaps in the rental contract) in which the owners may use the property themselves during the investment period.

Perhaps others can share their experiences in this regard?

To be clear, Iā€™m sure there are many other projects that qualify in the Algarve. Weā€™re working on adding more ā€œinventoryā€ to our search tool, but itā€™s in no way meant to be seen as an exhaustive list. Also, these projects donā€™t need (nor do they usually get) any sort of pre-approval from the Portuguese governmentā€”unlike how many other CBI/RBI programs are run. In some cases developers will get a sworn statement from a lawyer that their project qualifies according to the current regulationā€”have the developer offered anything like this?

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Yes. EUR 500K since Jan 1, 2022.

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Iā€™ve been advised that, if itā€™s a commercial property in a low density area of the Algarve, the minimum is ā‚¬410,000.

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All third country citizens who conduct an investment activity, as an individual businessperson or through a company set up in Portugal or in another EU Member State, may apply for a Residence Permit for Investment, by one of the following investment routes:

|Until 31 December 2021 | Changes introduced as from 1 January 2022|

1 - Capital transfer with a value equal to or above 1 million Euro | 1- Capital transfer increased to 1,5 million Euros|
2 - The creation of, at least, 10 job positions | 2 - The same
3 - The purchase of real estate property with a value equal to or above 500 thousand Euros | 3 - Residential real estate property investment is restricted to Azores, Madeira and low density areas
4 - The purchase of real estate property, with construction dating back more than 30 years or located in urban regeneration areas, for refurbishing, for a total value equal to or above 350 thousand Euros | 4 - Residential real estate property investment is restricted to Azores, Madeira and low density areas
5 - Capital transfer with a value equal to or above 350 thousand Euros for investing in research activities conducted by public or private scientific research institutions involved in the national scientific or technologic system | 5 - Capital transfer increased to 500 thousand Euros
6 - Capital transfer with a value equal to or above 250 thousand Euros for investing in artistic output or supporting the arts, for reconstruction or refurbishment of the national heritage, through the local and central authorities, public institutions, public corporate sector, public foundations, private foundations of public interest, networked local authorities, local corporate sector organizations, local associations and public cultural associations, pursuing activities of artistic output, and reconstruction or maintenance of the national heritage | 6 - The same
7 - Capital transfer of the amount of 350 thousand Euros, or higher, for the acquisition of units of investment funds or venture capital 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 is realized in commercial companies with head office in national territory
| 7 - Capital transfer increased to 500 thousand Euros
8 - Capital transfer of the amount of 350 thousand Euros, or higher, for constitution of a commercial society with head office in the national territory, combined with the creation of five permanent working jobs, or for the reinforcement of the share capital of a commercial society with head office in national territory, already existing, with the creation or keeping of working jobs, with a minimum of five permanent jobs, and for a minimum period of three years. | 8 - Capital transfer increased to 500 thousand Euros|

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Hi, quick question. What is the minimum number of trips one would need to make from biometric appointment to getting passport? Asking as I live I far away Singapore with a 8 month old who is also supposed to be part of the application.

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Hi Hemant, As I know it, 1 for Biometrice, 1 for the 7 day stay after you recieve the card, 1 between 2nd and 3rd year - 14 day stay + Biometrics for renewal. 1 more between 4th and 5th year for the same reason. So 4 trips minimum till you apply for the passport. Iā€™m also based in Singapore. PM me your contact so we can chat about this

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Great spreadsheet!! Iā€™m late to the party, just seeing it now. Nicely done.

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Hi, Can you plz guide, why you did not choose CITI or HSBC banks? as they have lower charges

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This is awesome, thanks Jim.

Do you mind open source the excel and letā€™s us review formulas or add a selector on family members? Four seems to much.

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Hi, Super helpful spreadsheet! Thanks very much for taking the time. I do have one question
ā€œ1 year Residence Permit ā‚¬5,325ā€. What is this fee? I am having trouble finding reference to anything else that contributes that much to the total. I am just starting so it is possible I have missed it. Really appreciate your time and input. Thanks bg

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it has been a while since I put this together, but if my memory serves me right that is what you pay for the issuance of the residence permit.

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Just to add that there are different costs for each step (application reception and analysis to pre-approval, application approval to provision of first residence permit, approval of renewal permit etc). The relevant law is at https://files.dre.pt/1s/2020/08/16400/0004700060.pdf and at: LEGISPƉDIA SEF - Taxas/encargosā€¦ To find the costs of the ARI application within the law, go to Section IV - TĆ­tulos de residĆŖncia and Item 3: - Por tĆ­tulos de residĆŖncia para atividade de investimento which details each component cost- eg (a) reception and analysis of the application ā‚¬533; (b) provision of first residence permit ā‚¬5325 (c) renewal of residence permit ā‚¬2663 etc. The costs have gone up slightly for each component being assessed in 2022, not yet reflected in the law (or perhaps there is an amendment to the law). Costs are now: (a) ā‚¬539.66, (b) ā‚¬5391.56 (c) ā‚¬2696.29.