Direct answer: Holding a golden visa does not make you a tax resident of Portugal, Italy or Greece. Days and homes do. In Portugal and Greece, more than 183 days in any twelve month period makes you resident, and so can having a home or center of life there. Your home country has its own rules, and some keep taxing you wherever you live.

For people who hold the permit as an option, the risk runs both ways: becoming tax resident in Europe without meaning to, or assuming you have left your home country's tax net when you have not.

Portugal: 183 days, or a home you mean to keep

  • You are resident if you stay more than 183 days, consecutive or not, in any twelve month period that starts or ends in the tax year (income tax code, Article 16(1)(a)).
  • You can also be resident with fewer days if you have a home in Portugal in conditions that suggest you intend to keep and occupy it as your usual residence (Article 16(1)(b)).
  • A day of presence is any day, full or partial, that includes an overnight stay (Article 16(2)).
  • The NHR regime was revoked for new entrants by the 2024 budget law. IFICI (Article 58-A of the tax benefits statute) offers 20% on qualifying employment and self employment income for ten years, for specific activities. Passive investors do not fit any of the listed categories.

Greece: home, center of life, or 183 days

  • You are resident if your permanent or main home, habitual abode or center of vital interests is in Greece, or if you are present for 183 days in total in any twelve month period, in which case residence runs from your first day of presence (Income Tax Code, Article 4). We read this in a reproduction of the code, not the Gazette.
  • A golden visa is usually a home. Whether owning it, while living elsewhere, counts as a permanent home for Article 4 is a question for a tax adviser.
  • Greece has an optional regime for new residents (Article 5A): a flat €100,000 a year on foreign income, plus €20,000 for each family member included, for up to fifteen years. It only matters if you choose to become resident.

Italy: residence, domicile or simply being there

Holding the investor permit does not by itself make you an Italian tax resident. For 2026 the test is in the income tax code (TUIR, Article 2): you are resident if, for the greater part of the tax year, counting fractions of a day, you have your residence under the Civil Code, your domicile (where your personal and family relationships mainly develop) or you are present in Italy. Being registered in the resident population register for most of the year creates a presumption of residence that can be rebutted. Presence counts on its own, so the days you spend in Italy matter even without a home there.

From 1 January 2027 Article 2 is repealed by Legislative Decree 117/2026, the new consolidated income tax code.

If you do choose to move your tax residence, Italy's optional flat tax on foreign income is €300,000 a year plus €50,000 for each family member, for people moving from 1 January 2026, if you were not resident for nine of the previous ten years. From 1 January 2027 the rule moves to Article 246 of the new income tax code, with the same amounts.

The other side: your home country

  • United States. The IRS says US citizens and resident aliens abroad are "subject to tax on worldwide income from all sources", so a European permit does not take an American out of US tax.
  • United Kingdom. Under the statutory residence test, 183 or more days in the UK makes you UK resident, with no need to consider other tests. Fewer days can still mean residence under the other tests.
  • South Africa. SARS says someone resident under the physical presence test stops being resident after at least 330 full days continuously outside the country, and that breaking residence triggers a deemed disposal of worldwide assets other than South African property.
  • Everyone. Where two countries both treat you as resident, a tax treaty between them may decide. Treaties differ.

This page is a map of the traps, not advice on your position. Take advice in both countries before you change how much time you spend where.

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Questions we hear most

Does a golden visa make me a tax resident?
Not by itself. In Portugal and Greece, tax residence depends on days spent in the country and on where your home or center of life is, not on the permit.
Is staying under 183 days enough to avoid tax residence?
Not always. Portugal can also treat you as resident if you have a home there in conditions that suggest you mean to keep it as your usual residence, and Greece looks at your permanent home, habitual abode and center of vital interests as well as days.
Can I use Portugal's NHR regime?
Not as a new entrant. NHR was revoked by the 2024 budget law, apart from transitional cases. Its replacement, IFICI, is for specific qualifying jobs, not passive investors.

Sources

  1. Código do IRS, Article 16 (tax residence), Portal das Finanças, Autoridade Tributária e Aduaneira. Official source. Last checked 28 October 2026.
  2. Estatuto dos Benefícios Fiscais, Article 58-A (IFICI incentive), Portal das Finanças, Autoridade Tributária e Aduaneira. Official source. Last checked 28 October 2026.
  3. Greek Income Tax Code (Law 4172/2013), Article 4 (tax residence), as reproduced, taxheaven.gr. Secondary source. Last checked 28 October 2026.
  4. Greek Income Tax Code (Law 4172/2013), Article 5A (alternative taxation for new residents), as reproduced, taxheaven.gr. Secondary source. Last checked 28 October 2026.
  5. TUIR (DPR 917/1986), Article 24-bis (flat tax for new residents), text in force on 28 October 2026, Normattiva. Official source. Last checked 28 October 2026.
  6. Decreto Legislativo 117/2026, Article 246 (flat tax for new residents from 1 January 2027), Normattiva. Official source. Last checked 28 October 2026.
  7. RDR3: Statutory Residence Test guidance, HM Revenue and Customs. Official source. Last checked 28 October 2026.
  8. U.S. citizens and resident aliens abroad, Internal Revenue Service. Official source. Last checked 28 October 2026.
  9. Cease to be an SA tax resident and reinstatement of SA tax resident, South African Revenue Service. Official source. Last checked 28 October 2026.
  10. Budget Review 2026, Annexure E (exchange control), National Treasury, Republic of South Africa. Official source. Last checked 28 October 2026.
  11. United States income tax treaties, A to Z, Internal Revenue Service. Official source. Last checked 28 October 2026.
  12. Portugal: tax treaties, GOV.UK, HMRC. Official source. Last checked 28 October 2026.
  13. Greece: tax treaties, GOV.UK, HMRC. Official source. Last checked 28 October 2026.
  14. Italy: tax treaties, GOV.UK, HMRC. Official source. Last checked 28 October 2026.
  15. TUIR (DPR 917/1986), Article 2 (who is tax resident), text in force from 29 December 2023 to 31 December 2026, Normattiva. Official source. Last checked 30 October 2026.
  16. Legislative Decree 19 June 2026, no. 117, Consolidated text on income taxes (GU no. 152 of 3 July 2026, in force 4 July 2026); repeals TUIR Article 2 from 1 January 2027, Normattiva. Official source. Last checked 30 October 2026.

This page is general information, not legal, tax, immigration or investment advice. Rules and fees change, so check the sources above and the date we last checked them. No approval, permit or timeline is guaranteed. We are paid for introductions; here is how.