Greece vs Portugal Golden Visa Comparison 2026

Greece vs Portugal Golden Visa Comparison 2026

Greece and Portugal both run residency-by-investment programs that European Union passports and tax planners have been recommending for the past decade. They are now structurally different programs. Portugal removed real estate from the Golden Visa in October 2023 under Law No. 56/2023 ("Mais Habitação"). Greece kept real estate, but raised thresholds and rebuilt the zoning under the August 2024 amendments to Law 4251/2014. This is a side-by-side comparison of how the two work in 2026 for an investor weighing them against each other.

Can foreigners get residency by buying property in Greece?

Yes. Greece runs an active real estate Golden Visa under Article 20B of Law 4251/2014, with three investment tiers depending on location and property type. The program is one of the few remaining European routes where a residential property purchase still produces a residency permit.

Can foreigners get residency by buying property in Portugal?

No. Portugal's Golden Visa stopped accepting real estate investments on October 7, 2023, when Law No. 56/2023 came into force. Residential, commercial, and rehabilitation property routes were all eliminated, along with the EUR 1.5 million capital transfer option. Property purchases made after that date do not qualify a foreign buyer for a Portuguese Golden Visa.

What is the minimum investment for the Greek Golden Visa?

The minimum is EUR 250,000 for the Zone C heritage-restoration and commercial-conversion tier, EUR 400,000 for Zone B (most of mainland Greece outside the major metros), and EUR 800,000 for Zone A (Attica including Athens and Piraeus, Greater Thessaloniki, Mykonos, Santorini, and islands with more than 3,100 residents). Properties in Zones A and B must be at least 120 square meters; Zone C has no minimum size.

What is the minimum investment for the Portuguese Golden Visa?

The active routes in 2026 are EUR 500,000 in a qualifying Portuguese investment fund regulated by the CMVM, EUR 500,000 in research activities through an accredited Portuguese institution, EUR 250,000 in cultural or artistic projects, and EUR 500,000 in company incorporation or expansion creating at least ten jobs. The EUR 500,000 fund route is by far the most used.

What kind of property qualifies for the Greek Golden Visa?

Zone A and B require a single residential property of at least 120 square meters at the qualifying value. Zone C only qualifies if the property is either a commercial building converted to residential use, or a listed heritage building being restored under the supervision of the Greek Ministry of Culture. Plot purchases for construction are allowed if a construction contract is signed within the same notarial deed.

How long does the Greek Golden Visa take to process?

The full process from property purchase to issuance of the five-year residence permit takes six to nine months in 2026. The breakdown is: AFM (Greek tax number) and bank account opening, due diligence and notarial deed, registration at the Land Registry (Ypothikofylakeio) or the Cadastre (Ktimatologio), biometric appointment at the relevant decentralized administration, and issuance of the blue residence card.

How long does the Portuguese Golden Visa take to process?

Backlog at AIMA (Agency for Integration, Migration and Asylum) has stretched processing to between 18 and 36 months in 2026. The investment is made on day one and the application is filed, but biometric appointments are scheduled long after the application is accepted. Time toward Portuguese citizenship now begins from the day the application is filed (not the day the card is issued) following the May 2024 jurisprudence confirmed by Portuguese Supreme Administrative Court rulings.

Do I have to live in Greece or Portugal to keep the residency?

Greece has no physical presence requirement. You can never set foot in Greece and the permit renews every five years as long as you keep the investment. Portugal requires a minimum of seven days per year on average across the five-year period (14 days in any two-year window) to maintain the permit and to qualify for citizenship after five years.

When can I apply for citizenship in Greece?

Seven years of legal residence are required for Greek citizenship under Law 3284/2004 as amended, with a Greek language test (at level B1) and an integration interview. Time on the Golden Visa counts if you are physically present, which most Greek Golden Visa holders are not, making citizenship a rare outcome of this specific program.

When can I apply for citizenship in Portugal?

Five years of legal residence under the Portuguese Nationality Law (Law No. 37/81 as amended) are required, with an A2 Portuguese language test. After the 2024 jurisprudence, the five-year clock starts on the date of the Golden Visa application, not the card issue date, which is what makes Portugal's program attractive despite the AIMA backlog.

What taxes apply on Greek Golden Visa property?

Property transfer tax is 3.09 percent of the higher of the contract price or the objective value (antikeimeniki axia), plus notarial fees of 1 to 1.5 percent, registry fees of 0.5 percent, and a lawyer's fee of 1 to 1.5 percent. The annual ENFIA property tax applies based on size, location, and value. Rental income is taxed at progressive rates from 15 percent to 45 percent.

What taxes apply on the Portuguese fund route?

There is no acquisition tax on the fund investment. The fund itself pays Portuguese corporate tax inside the structure, and capital gains on exit are taxed under Portuguese personal income tax (IRS), generally at 28 percent for non-residents or at the marginal rate for tax residents. There is no IMT (property transfer tax) and no IMI (annual property tax) on the fund route.