Perhaps a few thoughts which might help. Uncertainty regarding the changes continues to exist, in summary due to the following:
- Initial reports, including those by the media, were that the changes would affect only the metropolitan areas of Lisbon and Porto. This was then “expanded” to include all coastal areas, even though to the best of my knowledge the proposed text did not change. Perhaps this confusion arose because most GVs have been issued in these two metropolitan areas and so there is an implicit association made which was not correct;
- Even if the entire continental coastal belt is under discussion, there is mention in the legislation of the intent of the legislation being to favour low-density areas and, while few, there are some low-density areas on the Coast (including the Algarve). This level of clarification needs to still be resolved;
- As regards the timing, a few versions exist: i) that everyone who has applied and has an application under way is “safe” - I think that can be assumed to be true (I put safe in inverted commas because that does not eliminate future potential changes); ii) anyone applying until March (to coincide broadly with the ratification by the President of the law, expected at the end of February) is “safe” - again, I would agree; and that anyone applying before the end of the year would be safe - this arose as a result of a statement by the economics adviser to the Prime Minister who made a statement that he would like existing processes not to be affected. I read that statement as a wish and not a certainty.
Therefore I think two things are sensible:
- If you have a deal available to close before March, close it out;
- Otherwise wait until the promulgation of the law
- Consult with a lawyer (four of the lawyers on our panel to whom I have written have not yet responded, which may be telling us something!) after that date, to ensure that the project qualifies.
Importantly, for those who are not interested in the location but want the cheapest access to a Golden Visa, consider the interior Golden Visas which actually start at €280K. We had a project near Viseu which none of the Golden Visa applicants wanted (it comes with several years of guaranteed rental) and suddenly we have had a surge in enquiries about this sort of opportunity.