When comparing the Golden Visa Spain vs Portugal we must bear in mind several differences regarding its possible investments and tax benefits in both southern European countries.
Several requirements as well as tax implications are unequal between Portugal and Spain, given the recent legal modifications in Portugal. For this reason, at Golden Partners we wanted to analyze the Golden Visa Spain vs Portugal to resolve all the doubts of investors who are hesitating in which of these two countries to obtain this residence permit thanks to their investment.
Do not hesitate to contact a tax lawyer of Golden Partners.
What is Spain Golden Visa
The Golden Visa in Spain is a residence and work permit for an initial period of two years, without requiring permanence in Spanish territory to obtain it.
What is more, obtaining the Golden Visa in Spain in 2024 gives the freedom to move around the countries of the Schengen area without having to comply with long periods of stay in our country nor being obliged to prove the tax residence in Spain.
What is Portugal Golden Visa
The Portugal Golden Visa program, also known as the residence permit for investment activity (ARI), is a residency by investment scheme designed for non-EU citizens. However several benefits have been eliminated as of October 2023 by the Portuguese government.
Golden Visa Spain vs Portugal: requirements
Investment requirements for the Spanish Golden Visa
On the one hand, the Golden Visa in Spain obliges to make a capital investment in Spain and meet the requirements listed below:
- Investment of at least half a million Euros for Real estate properties: The foreign investor can make a minimum net investment in Spain of EUR 500,000 in properties such as apartments, premises or land, which are intended for both personal residence and rental as well as for generating profitability by other means.
- Investment of at least one million Euros for commercial activities: As long as the investment is destined for shares linked to real commercial activities or participations in Spanish capital companies, the foreign person who wants to acquire the Golden Visa in Spain must invest at least one million Euros.
- Investment of at least one million Euros for investment funds: Furthermore, the community or non-community investor (for example, from Peru, Mexico, Colombia, the United States, Russia, etc.) can obtain a residence permit in Spain to invest one million Euros in investment funds, venture capital funds or in closed investment funds.
- Investment of at least one million Euros for bank deposits: The investor can even use one million Euros in bank deposits in financial institutions located in Spanish territory to obtain the Golden Visa.
- Investment of at least two million Euros for public debt securities: Moreover, Spanish Golden Visa investors will be able to invest at least EUR 2 million in Spanish public debt securities such as Treasury Bills and the well-known Spanish State Bonds and Obligations.
Investment requirements for the Portugal Golden Visa
On the other hand, the Portugal Golden Visa program offers only three investment options as from October 2023:
- Investment of at least half a million Euros for an investment fund: A minimum of €500,000 subscription in a qualifying Portuguese fund. The qualifying funds include Private Equity and Venture Capital funds and exclude any fund with a direct or indirect Real Estate ties.
- Investment of at least half a million Euros in a company: Creation of a minimum of 10 new full-time jobs in a Portuguese business that is owned by the main applicant of the Golden Visa. Also, a creation of a minimum of 8 new full-time jobs in a Portuguese business formed in a low-density area in Portugal, owned by the main applicant. Or third, an investment of a minimum of half a million Euros in an existing Portuguese business, where the incorporated business must create a minimum of five new full-time jobs for at least 3 years.
- A donation of at least 250,000 or half a million Euros: the applicant must invest a minimum of EUR 250,000 in preserving national heritage in Portugal or a minimum of EUR 500,000 in a research and development activity in Portugal.
Golden Visa Spain vs Portugal: 3 main differences
Spanish Government still respects the Real Estate investment
While the Spanish Government wants to eliminate the possibility of obtaining the Golden Visa by investing at least half a million euros in Real Estate, the Portuguese Government has already eliminated this possibility as of October 2023. Therefore, as of November 2024 it is not possible to obtain the Golden Visa in Portugal through an investment in Real Estate.
Portuguese Government has no longer the capital transfer possibility
Capital transfer no longer qualifies you for a Golden Visa in Portugal as of October 2023. In the Spanish case, this possibility has never existed but you can do it through a company linked to real commercial activities in Spain.
Investment in investment funds in Portugal cannot be linked to Real Estate
Investment in Portuguese investment funds does not allow you to have direct or indirect ties with Real Estate. Spanish investment does, although it is somewhat higher, at least one million Euros.
Golden Visa Spain vs Portugal: tax implications
The validity of the traditional Non-Habitual Resident Regime in Portugal expired last March 2024. It was a regime that allowed fixed taxation of 20% on work and/or professional income, provided that these derived from an activity considered ‘High value added’.
For its part, Spain still preserves the impatriate regime (known as the Beckham Law) which among other options, allows workers posted to Spain to only be taxed in Spain on income from Spanish sources, that is, by those generated in Spanish territory during their stay. You will not be taxed on income produced abroad, normally generated in your country of origin. Additionally, you would pay a flat tax rate of 24% for income instead of the progressive rate, and from EUR 600,001 onwards, at 47%. Furthermore, the impatriate must file a Wealth Tax declaration in Spain but only for the assets that are in Spanish territory and taking into account that in some regions such as the Community of Madrid, the exemption percentages are considerable.
In addition to the tax benefits of acquiring residency in Spain, there is an important deduction in the Income Tax of Individuals who settle in the region of Madrid. Specifically, any person who has not resided in Spain in the last five years and who now wants to invest and settle in Madrid can enjoy a 20% deduction on investments made in real estate located in the Community of Madrid, in securities representative of the participation in own funds of Spanish or foreign entities, and in securities representing the transfer of own capital to third parties. This new regional deduction is subject to the new taxpayer maintaining the acquired assets for a continuous period of 6 years, and may be applicable in the year in which the investment occurs or in the following five years.
Is Spain cancelling the Golden Visa?
Despite the information published by the Spanish Government, the Golden Visa in Spain is still valid throughout the national territory, as we at Golden Partners explain both to our clients and in the media. It has been announced that it is intended to eliminate the option of investing in Real Estate to obtain the Golden Visa in Spain but there are still many months ahead and, in the event of a change of Government, it will be a measure that will not be implemented. In any case, there will always be other investment options, also broader than the Portuguese Golden Visa, as explained.
We can help you if you are thinking of making an investment in Real Estate in the Spanish real estate market, whether in the Valencian Community, the Balearic Islands, Madrid or any other part of the Spanish territory.
As specialists in Spanish Real Estate and immigration, we offer you the necessary legal advice to make the best decision for you and your family, avoiding risks and complying with both Spanish and European legislation.
At Golden Partners, we know how to take care of your assets. We remain at your entire disposal in our contact form. Do not hesitate to write to us in English, French or Spanish.
