Guide to Golden Visas: Best Residency by Investment Programs Compared

Updated Nov 13, 2025

Key Takeaways

  • Immigration is the legal process to live, work, study, or invest in another country, with options ranging from family sponsorship to investment migration.
  • Residency by investment (RBI) gives residence rights, while citizenship by investment (CBI) grants a passport. The benefits, obligations, and timeframes differ significantly.
  • Total cost is more than the headline investment. Budget for legal fees, government charges, taxes, due diligence, fund fees, and ongoing renewal costs.
  • Physical presence rules and tax residency are not the same. You can often keep a residence permit with minimal stays, but you usually become tax resident based on time spent or ties to the country.
  • There is a market shift from real estate to investment funds in major programs like Portugal and Spain, with Greece and Hungary offering mixed routes and Malta providing both RBI and CBI paths.
  • Lawyers help you avoid refusals, structure investments, prove source of funds, and stay compliant as rules change quickly.

What is Immigration?

Immigration is the legal process of relocating to another country to live, work, study, invest, or reunite with family. It covers temporary visas, long-term residence permits, permanent residence, and, ultimately, citizenship. Each status gives different rights and obligations.

Key pathways include:

  • Family: joining a spouse, partner, parent, or child.
  • Work: employer-sponsored permits or points-based systems.
  • Study: student visas that can lead to post-study work.
  • Protection: asylum or humanitarian protection.
  • Investment: making a qualifying investment to obtain residency or, in limited cases, citizenship.

Important terms:

  • Visa: entry authorization to travel to a country for a specific purpose and time.
  • Residence permit: permission to live in a country for a defined period, often renewable.
  • Permanent residence: indefinite right to live in a country after meeting residence criteria.
  • Citizenship: full membership of a state, usually with voting rights and a passport.

Investment migration comes in two forms. Residency by investment (RBI) grants residence rights first, often with a later path to citizenship through naturalization. Citizenship by investment (CBI) grants a passport after strict due diligence and investment, usually with a residence or connection period.

Why Might You Need Legal Help with Immigration?

You may need a lawyer because immigration rules are complex, evidence-heavy, and change often. Mistakes can lead to refusals, delays, or future compliance risks. A lawyer improves approval odds and protects your long-term plan.

How lawyers add value:

  • Eligibility mapping: matching your goals and profile to the right route.
  • Document strategy: preparing compliant forms, translations, apostilles, and certified copies.
  • Investment structuring: reviewing funds or property, escrow terms, and exit strategies.
  • Source of funds: building an audit trail for anti-money-laundering checks.
  • Risk management: identifying red flags in background checks and fixing issues before filing.
  • Process control: tracking deadlines, renewals, family add-ons, and travel constraints.
  • Change management: adapting to policy shifts, fee changes, or closure of routes.

How Does the Immigration Process Work?

The immigration process follows a predictable sequence: choose the right pathway, prepare evidence, apply, attend biometrics or an interview, receive a decision, and maintain your status. Investment routes add due diligence, source of funds reviews, and investment completion steps.

  1. Define your goals: travel freedom, education, work rights, or a future passport.
  2. Choose a pathway: family, work, study, protection, or investment.
  3. Confirm eligibility: age, health, character, finances, language, and insurance.
  4. Plan the budget: include total cost, not just the investment headline.
  5. Collect documents: passports, civil records, bank statements, tax returns, and proof of funds.
  6. Make the investment or obtain sponsorship: fund subscription, property contract, or employer letter.
  7. Submit applications: online or paper filings, pay fees, and book biometrics.
  8. Respond to requests: provide extra documents or attend an interview if asked.
  9. Receive decision and finalize: visa issuance, entry, and residence permit activation.
  10. Maintain compliance: meet stay requirements, renew permits, and file taxes if applicable.
  11. Upgrade status: apply for permanent residence or citizenship if eligible.

Investment Migration at a Glance

Investment migration is highly requested in Europe for Schengen access and globally for business connectivity. It has shifted away from pure real estate to regulated funds and job creation models, with sharper due diligence and clearer physical presence rules.

Program Type Typical route today Headline investment Estimated total entry cost Physical presence to maintain Path to citizenship Travel rights
Portugal Golden Visa RBI Qualifying investment funds, research, arts, or business creation Commonly 500,000 EUR in funds Investment plus roughly 30,000-80,000 EUR in fees and taxes for a family of 4 Low average stay per year Possible after long-term residence and language test Schengen travel as a resident
Greece Golden Visa RBI Real estate in designated areas or financial investments Threshold varies by area and route Property route adds taxes of roughly 7-25 percent depending on VAT and fees Minimal or no stay to maintain residence Requires real residence and language for naturalization Schengen travel as a resident
Spain Investor Residence RBI Investment in shares, funds, or public debt From 1,000,000 EUR for financial assets Investment plus approximately 20,000-50,000 EUR in fees for a family of 4 Flexible stay to maintain residence Long residence with real presence required Schengen travel as a resident
Malta Permanent Residence Programme RBI Government contribution plus property lease or purchase and donation Contribution and property commitments Often 150,000-300,000 EUR plus rent or property taxes Limited presence required Separate track from CBI, not direct citizenship Schengen travel as a resident
Malta Citizenship by Naturalisation for Exceptional Services CBI-like naturalisation Substantial contribution, property, donation, and residence period High six to seven figures EUR total Often 1,000,000+ EUR including all components Residence period of 12-36 months Grants EU citizenship after approval and residency EU passport rights
UAE Golden Visa RBI Property ownership, salary, entrepreneur, or talent route Property route commonly set around 2,000,000 AED Property transfer fees about 4 percent plus visa and medical costs Flexible for golden visa holders No automatic citizenship track Residence in UAE, no Schengen rights
USA EB-5 RBI to Green Card Investment via regional center or direct, with job creation 800,000 USD in TEA or 1,050,000 USD otherwise Investment plus 70,000-120,000 USD fees and USCIS charges US residence required to maintain Green Card Permanent residence then citizenship by naturalization US work and residence rights
Hungary Guest Investor RBI Real estate fund units, property purchase, or donation Commonly 250,000-500,000 EUR depending on route Investment plus legal and government fees, property taxes if buying Minimal presence for residence validity Potential long-term path via residence rules Schengen travel as a resident

Figures above are indicative and change frequently. Total entry cost usually equals the headline investment plus government fees, legal fees, due diligence, fund subscription fees, taxes, and document costs for each family member.

Residency by Investment vs Citizenship by Investment

RBI gives a residence permit first, with a potential future path to citizenship after real residence, language, and integration tests. CBI or accelerated naturalization gives citizenship more directly but requires heavy due diligence, significant contributions, and meeting residence or connection requirements.

  • RBI benefits: live in the country, access local services, and travel regionally if allowed. Lower upfront contributions and more flexible residence.
  • CBI benefits: immediate passport and global mobility. Highest scrutiny and cost, plus strict compliance.

Physical Presence vs Tax Residency

Physical presence rules determine how many days you must spend to keep your permit. Tax residency rules determine where you owe tax, usually based on days spent, center of vital interests, or holding a tax-resident status like a Green Card.

  • Low-stay permits: some programs allow minimal annual presence to maintain residency.
  • Tax residency: often triggered by 183 days in a year, ties like home and family, or permanent resident status in some countries.
  • Planning tip: hold a low-stay residence without triggering tax residency by limiting days and ties, after advice from a tax professional.

Real Estate vs Funds - the market shift

Many programs have reduced or removed real estate options in favor of regulated funds, innovation investments, or job creation. Funds can diversify risk and align with economic goals, but require careful due diligence on managers, fees, and exit terms.

  • Real estate adds transfer taxes, VAT, stamp duty, and maintenance costs.
  • Funds add subscription fees, management fees, and lock-up periods.
  • Always assess liquidity, governance, and alignment between your timeline and the program’s eligibility rules.

Frequently Asked Questions

What is the difference between a visa, residence permit, permanent residence, and citizenship?

A visa lets you enter and stay for a limited purpose and time. A residence permit lets you live longer, often with work or study rights. Permanent residence is indefinite, and citizenship gives a passport and full political rights.

Think of it as a ladder: visa to residence to permanent residence to citizenship. Each step requires meeting stricter criteria and longer residence.

How is residency by investment different from citizenship by investment?

Residency by investment grants a residence card first, usually with a later path to permanent residence and citizenship through naturalization. Citizenship by investment or accelerated naturalization grants a passport after substantial investment and due diligence, often with a residence or connection period.

Choose RBI if you want flexibility and lower contributions. Choose CBI-like routes only if you accept higher scrutiny, higher cost, and a more complex process.

Do investment residency permits give me visa-free Schengen travel?

Yes, if your residence permit is from a Schengen state you can typically travel to other Schengen countries for short stays, subject to 90-180 day rules. This is not the same as the right to live or work in other Schengen states.

Always carry your passport and residence card when traveling. Rules can vary for long-stay or work rights, which remain national.

What is the real total cost for investment migration?

Total cost equals investment amount plus government fees, legal fees, taxes, due diligence, and ongoing costs. Expect meaningful add-ons of 5-25 percent depending on the route and family size.

  • Real estate: add transfer taxes, VAT or stamp duty, notary, registry, and maintenance.
  • Funds: add subscription and management fees, and local bank costs.
  • Family: multiply application and residence card fees per dependent.

Can I include my spouse, children, or parents?

Most programs allow a spouse and dependent children. Some allow financially dependent parents and, less commonly, dependent adult children with proof of dependency or study.

Age cut-offs and dependency tests vary. Include all family members in your planning to avoid later complications.

Do I need to live in the country to keep my permit?

Many RBI programs have minimal stay rules to maintain the permit. However, naturalization typically requires substantial physical presence, language, and integration.

Map your day counts carefully. If your goal is a future passport, plan for real residence years, not just holding a card.

Will I become tax resident if I get a residence permit?

Not automatically. Tax residency usually depends on time spent, ties, or specific tax rules such as being a permanent resident in some countries.

Obtain tax advice before spending extended time or creating ties like a home, business, or family presence in the country.

What evidence do I need for source of funds?

You will need to prove that your investment money is legal and traceable. Typical documents include bank statements, tax returns, sale contracts, company financials, and gift or inheritance papers.

Expect granular questions about money flows. Prepare a clear narrative with documents for each step of the funds path.

How long does the process take?

RBI permits can take a few months to over a year depending on workload, due diligence, and completeness. CBI-like or accelerated routes involve longer and deeper checks.

Build a buffer for biometrics, background checks, and unexpected document requests. Parallel processing of family members can speed things up.

Can programs change or close?

Yes. Thresholds, categories, and benefits can change quickly due to policy shifts. Real estate options have tightened, while funds and innovation routes have grown.

File early with complete applications and choose investments that will still qualify if rules change during processing.

What if my application is refused?

You may have options to appeal, reapply, or switch programs. The best strategy depends on the refusal reason and the program’s rules.

A lawyer can assess appeal prospects, correct documentation gaps, and protect your position with deadlines and representations.

When Should You Hire a Lawyer?

Hire a lawyer as soon as you define your goals and before you commit funds or sign contracts. Early advice prevents missteps, uncovers better options, and protects your exit strategy.

Key moments to get counsel:

  • Before transferring funds or signing a property contract or fund subscription.
  • When structuring ownership through companies or trusts to meet program rules.
  • If you have complex source of funds, multiple jurisdictions, or past immigration issues.
  • When programs are changing or when you need to preserve eligibility during transitions.
  • If you plan for eventual citizenship and need a multi-year residence and tax plan.

What a good lawyer will do:

  • Provide a written eligibility and cost plan covering the main route and backups.
  • List all fees and taxes per family member and per step, with payment timing.
  • Coordinate with licensed financial intermediaries and perform document checks.
  • Set a compliance calendar for renewals, minimum stays, and police certificate updates.

What are the Next Steps?

Start with a clear goal, a realistic budget, and a shortlist of programs that fit your timeline and lifestyle. Then assemble documents, choose reputable advisors, and sequence applications to avoid tax and travel conflicts.

  1. Define objectives: Schengen access, business base, education, or future passport.
  2. Shortlist programs: compare Portugal, Greece, Spain, Malta, UAE, USA EB-5, and Hungary by total cost, presence, and timeline.
  3. Map total costs: investment, fees, taxes, and renewals for your family size.
  4. Plan presence vs taxes: decide where you will actually live to avoid surprise tax residency.
  5. Prepare documents: passports, civil records, bank and tax records, proofs of source of funds, and translations.
  6. Engage professionals: immigration lawyer plus, if needed, licensed financial advisor and tax advisor.
  7. Complete investment steps: escrow, fund subscription, or property contract with proper due diligence.
  8. File applications: track biometrics, interviews, medicals, and government fees.
  9. Activate and maintain: collect residence cards, register addresses if required, and monitor day counts.
  10. Reassess yearly: review portfolio performance, program changes, and eligibility for PR or citizenship.

Pro tip: build a backup plan. If one route slows or changes, a second residency or a parallel work or study option can protect your timeline.

Country-Specific Guides

While this guide covers universal principles, specific laws vary by country. View detailed guides for your jurisdiction:

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