Just to close the loop on the D2 visa, this is what my attorney said:
Unfortunately, each local office of AIMA applies its own internal rules, and in Setúbal, they considered that the applicable fee was the one for the Golden Visa.
I did in fact try to discuss the matter with the officer at the time, as she believed that the Golden Visa fee was the correct one to apply, but given the specific circumstances of your case, I decided not to insist at that moment and allowed the matter to proceed as it was.
We have already dealt with similar cases where clients were required to pay the Golden Visa fee, and we later submitted refund requests arguing that the amount had been charged incorrectly.
We can do it if you want, explaining them that the correct fee should have been the one corresponding to the Residence Permit for Entrepreneurial Activity, and not the Residence Permit for Investment Activity (Golden Visa), since the investment model in question had already been revoked at the time, arguing that the applicable legal framework was that of the Residence Permit for Entrepreneurial Activity, due to the effect of Law no. 56/2023, of 6 October.
Under your specific case I have some doubts if we should do it now, but I’ll leave it up to you to decide what you think is best, and I will act accordingly