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Eligibility of Domestic & US-Based Funds for Portugal Golden Visa
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Answer: Domestic (Portuguese) funds are eligible for the Portugal Golden Visa if regulated by the CMVM, invest 60%+ in Portuguese commercial companies, require a minimum €500,000 investment, have a five-year maturity, and exclude real estate. US-based funds are not explicitly eligible, as the program prioritizes Portuguese and EU-regulated funds, and no clear framework exists for US funds to meet the CMVM’s strict criteria.
The Portugal Golden Visa, launched in 2012, offers non-EU/EEA/Swiss nationals residency through investments, with the fund option growing in popularity since real estate was excluded in October 2023. This article examines the eligibility of domestic (Portuguese) and US-based funds for the program as of April 22, 2025.
Eligibility Criteria for Investment Funds
Qualifying funds must meet these requirements:
- Regulation: Registered with the CMVM (Portugal) or an equivalent EU regulator.
- Investment: Minimum €500,000.
- Maturity: At least five years.
- Allocation: 60%+ invested in Portuguese commercial companies.
- Non-Real Estate: No direct or indirect real estate investments.
- Structure: Typically Private Equity Funds (PEFs) or Venture Capital Funds (VCFs).
Domestic Funds: Portuguese-Based Options
Domestic funds, regulated by the CMVM, are a primary Golden Visa investment vehicle, focusing on Portuguese businesses in sectors like renewable energy, technology, and SMEs.
- Examples:
- Greentech II Fund: Sustainable forestry and agriculture.
- C2 Legacy Buyout Fund: Portuguese SMEs.
- AI Medical Fund: Health-tech startups.
- Advantages: Straightforward compliance, local expertise, and alignment with Portugal’s economy.
- Challenges: Limited fund variety, high fees (5–8%), and 6–10-year lock-in periods.
US-Based Funds: Eligibility Challenges
US-based funds are not explicitly recognized as eligible for the Portugal Golden Visa, and no established framework supports their inclusion as of April 2025.
- Regulatory Hurdles: US funds, regulated by bodies like the SEC, do not align with CMVM standards, and no bilateral agreement facilitates their approval for the Golden Visa.
- Investment Focus: Meeting the 60%+ requirement for Portuguese commercial companies is impractical for most US funds, which typically focus on global or US markets.
- Examples: No known US-based funds qualify, as the program prioritizes Portuguese and EU-regulated funds to support local economies.
- Challenges: Lack of regulatory alignment, complex compliance, and inability to meet Portugal-specific investment criteria make US funds non-viable.
Key Considerations
- Compliance: Domestic funds are CMVM-approved; US funds lack a clear eligibility path.
- Risk/Return: Domestic funds offer stability in Portuguese markets; US funds, if hypothetically eligible, might diversify but carry regulatory risks.
- Tax: Non-residents may avoid Portuguese taxes on domestic funds, but US fund investments would face US tax obligations.
Trends (2025)
- Domestic Focus: New Portuguese funds in green tech and biotech dominate.
- Regulatory Clarity: CMVM emphasizes Portuguese and EU funds, with no indication of US fund inclusion.
- Processing: Domestic fund applications take 6–12 months.
Conclusion
Domestic (Portuguese) funds are a reliable Golden Visa investment, meeting CMVM criteria and supporting Portugal’s economy with a €500,000 minimum. US-based funds are not eligible due to regulatory misalignment and the program’s focus on Portuguese and EU funds. Investors should prioritize domestic funds and seek expert advice to navigate options and ensure compliance.
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