Golden visas by passport

United States

US citizens can apply for the Portugal, Greece and Italy golden visas on the same terms as anyone else. What makes it different for Americans is the IRS: you keep filing US returns wherever you live, you report foreign accounts and assets, and a European investment fund can be a "passive foreign investment company" with its own reporting and tax rules. Sort the US tax side before you pick the route.

US tax filing follows you everywhere

The IRS says filing rules are generally the same whether you live in the United States or abroad, and US citizens are taxed on their worldwide income.

Living abroad gives you an automatic extension to June 15 to file. Two reporting rules matter on day one:

• FBAR (FinCEN 114): required when your foreign financial accounts together exceed $10,000 at any time in the year.
• Form 8938: for taxpayers living abroad, single filers report when specified foreign assets exceed $200,000 on the last day of the year or $300,000 at any time; married couples filing jointly at $400,000 or $600,000.

The foreign earned income exclusion ($130,000 for 2025 and $132,900 for 2026) covers earned income such as wages and professional fees. It does not cover pensions, Social Security, dividends or fund returns, which is what most golden visa investors live on.

Funds and the PFIC problem

Portugal's main golden visa route is a fund investment, and under the IRS tests a foreign fund will usually fall within the definition of a passive foreign investment company (PFIC), which means Form 8621 and potentially harsh tax treatment.

The IRS defines a PFIC as a foreign corporation where 75% or more of income is passive, or at least 50% of assets produce passive income. The IRS text does not say "foreign funds are PFICs" in so many words; that is our reading of the tests, and it is why Americans ask fund managers whether they provide the annual statements needed for the more favorable elections.

This is the single biggest reason American readers look at Greece's property route or Italy's company route as well as Portugal's funds.

Treaties, and why they help less than you think

The United States has income tax treaties with Portugal, Greece and Italy, but IRS Publication 54 notes that treaty benefits are generally not available to US citizens who do not live in the United States.

In practice that means credits for foreign tax, not exemptions, do most of the work. Your US and local advisers need to talk to each other.

Travel and documents

US passport holders can visit Schengen countries without a visa for up to 90 days in any 180 day period, which is enough for Portugal's seven day stay or Greece's biometrics trip.

Every country will ask for a criminal record certificate. For Americans that is usually the FBI Identity History Summary with an apostille.

Which country fits most American movers

If you want a home you will use and simple US reporting, Greece's property route is often the cleaner fit; if you want Portugal, check the fund's US tax reporting before anything else; Italy suits Americans who want to back or run a business.

• Portugal: €500,000 fund route, seven days in year one, ten years to citizenship. Retirees with steady pension income may find the D7 visa a better fit than any golden visa.
• Greece: one home from €400,000 (€800,000 in Athens, Thessaloniki, Mykonos, Santorini and larger islands), no minimum stay.
• Italy: €250,000 startup or €500,000 company or venture capital fund, with €1,000,000 of funds shown.

Questions we hear most

Can US citizens get the Portugal golden visa?

Yes. Nationality does not change the rules, but the fund route raises US tax questions (PFIC reporting) you should settle first.

Do I still pay US taxes with a golden visa?

You still file. US citizens are taxed on worldwide income wherever they live, with credits and exclusions that may reduce what you owe.

Does the foreign earned income exclusion cover my investment income?

No. It covers earned income like wages, not pensions, dividends or fund returns.

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United Kingdom

Since Brexit, a British passport gets you up to 90 days in any 180 day period in Portugal, Greece or Italy, and no more. A golden visa is one way to get past that limit without a job offer: it gives you residence in one country, renewable while you keep the investment.

What changed for Brits after Brexit

UK travel advice for all three countries now says British visitors can stay up to 90 days in any 180 day period without a visa or permit, and the EU's Entry/Exit System records each crossing.

That is the reason most British readers write to us. A second home in the Algarve or the Peloponnese used to be a place you could stay in all spring. Now the 90 day rule counts every day across the whole Schengen area. Registration in the Entry/Exit System is free.

Living part of the year in Europe

The golden visas suit the "half the year" Brit well, because Greece has no minimum stay, Italy has no continuity requirement for five years and Portugal asks for seven days in year one.

GOV.UK's living abroad guides set out the practical side once you are resident:

• Portugal: you enter on a residence visa and then apply to AIMA for the card. Residents register with the national health service (SNS); a UK GHIC or EHIC cannot be used by residents unless they have a registered S1, such as UK state pensioners. A UK licence can be used until it expires.
• Greece: after a national visa you register with the police within 90 days and apply for the permit. Public healthcare needs a Greek residence permit. You exchange a UK licence after six months of residence.
• Italy: apply for a residence permit within eight days of arrival and register residence for stays over three months. You exchange a UK licence after twelve months of residence, without a test.

Whether these general GOV.UK steps apply exactly the same way to golden visa holders is worth checking with your lawyer.

Tax: UK and the new country

A golden visa does not end UK tax residence; the Statutory Residence Test does, and spending 183 days or more in the UK in a tax year makes you UK resident under it.

The test has more parts than the day count, so read HMRC's RDR3 guide or take advice. The UK has tax treaties with all three countries, including a new UK and Portugal convention that HMRC lists as in force since early 2026, replacing the 1968 treaty. The UK's new four year foreign income regime, which replaced the remittance basis from 6 April 2025, concerns people arriving in the UK, not leaving it.

Police certificates

British applicants get a police certificate from ACRO, and because an ACRO certificate cannot get an e-Apostille it needs the paper apostille, which GOV.UK lists at £45 per document.

Which country fits

If you already own or want a home in Greece, the property route turns it into residence; if you prefer Portugal and its large British community, the fund route is the way in now that property no longer qualifies.

Italy suits Brits who want to invest in or start a business there. Compare them on Portugal vs Greece vs Italy.

Questions we hear most

Can I stay more than 90 days in Portugal as a British citizen?

Not as a visitor. You need a visa or residence permit, and a golden visa is one route to a residence permit.

Does a Portugal golden visa let me use my GHIC?

GOV.UK says residents in Portugal cannot use a UK GHIC or EHIC unless they have a registered S1. Residents register with the SNS instead.

Will I stop paying UK tax?

Only if you stop being UK resident under the Statutory Residence Test. The visa itself does not change that.

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South Africa

South African passport holders need a Schengen visa for every short trip, so a golden visa in Portugal, Greece or Italy changes daily life more for South Africans than for most. The hard parts are at home: getting the money out under exchange control, the SARS exit rules if you stop being tax resident, and a police clearance that takes weeks.

Why the Schengen visa matters

South Africa is on the EU list of countries whose citizens need a visa for short stays, so without residence every European trip means a fresh application.

A residence permit in one Schengen country ends that cycle for that country, and the European Commission notes a residence permit lets the holder travel in the Schengen area. Check the exact rules for long stays in other Schengen countries.

Moving funds out of South Africa

Treasury's 2026 Budget Review raised the single discretionary allowance from R1 million to R2 million per calendar year; larger amounts for investment go through SARS's approval for international transfers.

A €400,000 Greek home or a €500,000 Portuguese fund is well above the discretionary allowance, so most South African investors will need the SARS approval route, with its supporting documents.

Leaving SARS tax residence

South African tax residents are taxed on worldwide income, and if you stop being resident SARS treats you as having disposed of your worldwide assets, except South African immovable property, which can trigger capital gains tax.

Under the physical presence test you cease to be resident after 330 continuous full days outside South Africa, and you declare the change on form RAV01. A golden visa alone does not end SA tax residence; your life does. South Africa has tax treaties with Portugal, Greece and Italy.

Documents from South Africa

Start the police clearance first: SAPS charges R190 and quotes about fifteen working days excluding postage, and reports a backlog.

You can apply abroad through a local police station or a South African mission. The certificate then goes to DIRCO for legalization; DIRCO ended walk ins on 1 September 2026 and works by booking. Whether a country needs DIRCO legalization or an apostille for your file is a question for your lawyer.

Dual citizenship

Home Affairs says the Constitutional Court found section 6(1)(a) of the Citizenship Act invalid from 6 October 1995, so South Africans who took another nationality after that date without permission did not lose SA citizenship.

That matters for the long game, because citizenship in Portugal, Greece or Italy no longer has to mean giving up your South African passport. It does not cover people who renounced voluntarily.

Which country fits

Portugal is the most familiar landing for South Africans, through the fund route now that property no longer qualifies; Greece suits those who want to own a home; Italy suits entrepreneurs.

See the Portugal, Greece and Italy guides.

Questions we hear most

Do South Africans need a Schengen visa?

Yes, for short stays. A residence permit in a Schengen country removes that need for the country that issued it.

How much money can I take out of South Africa?

The single discretionary allowance is R2 million per calendar year after the 2026 Budget. Larger investments need SARS approval for international transfers.

Will I lose my South African citizenship?

Home Affairs says no for people who acquired another nationality after 6 October 1995, following the Constitutional Court ruling.

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India

For Indian residents the deciding number is not Europe's minimum but the Reserve Bank of India's: the Liberalised Remittance Scheme lets each resident individual send up to USD 250,000 per financial year, including for property and investment abroad. That limit, the tax collected at source on remittances, and India's position on dual citizenship shape which golden visa works.

Sending investment money out of India

Under the RBI's Master Direction you can remit up to USD 250,000 per financial year (April to March), and permitted purposes include buying property abroad and overseas investment.

Family members can combine their limits, but for capital account transactions such as property only where they are co owners. So a couple buying a Greek home together may be able to use two limits in one year, while a single investor in a €500,000 Portuguese fund may need more than one financial year. The euro amount you can reach depends on the exchange rate on the day.

Tax collected at source

Remittances above ₹10 lakh in a year attract tax collected at source, which the Finance Bill 2026 memorandum gives as 20% for purposes other than education and medical treatment.

TCS is credited against your income tax, so it is cash flow more than cost, but on a large remittance it is a lot of cash.

Residency now, citizenship later: the citizenship question

A golden visa does not affect your Indian citizenship; naturalizing in Portugal, Greece or Italy later is a different decision, because India does not generally allow dual citizenship.

Many Indian families treat European residence as the goal and decide on citizenship much later, if at all. That makes Greece (no minimum stay) and Italy (no continuity requirement for five years) worth a close look.

Documents from India

Indian passport holders need a Schengen visa for short visits, and the police clearance certificate is applied for through Passport Seva, including at Post Office Passport Seva Kendras since 28 September 2022.

Plan the biometrics trip around the Schengen visa appointment, because you will need a visa to enter until the residence permit is issued.

Which country fits

Greece's €400,000 home route is often the most straightforward fit with LRS limits for a couple buying jointly; Portugal's €500,000 fund route needs more planning; Italy's startup route needs €1,000,000 shown as available and transferable to Italy.

See Portugal vs Greece vs Italy.

Questions we hear most

Can an Indian citizen get a Portugal golden visa?

Yes. The route is the same for every nationality. The practical limit is the LRS cap of USD 250,000 per person per financial year.

Can I buy a Greek golden visa property under LRS?

Acquiring property abroad is a permitted purpose under the RBI Master Direction, within the annual limit.

Do I need a Schengen visa to go for biometrics?

Yes, until the residence permit is issued.

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Gulf residents (UAE and other GCC states)

If you live in the UAE or elsewhere in the Gulf, a European golden visa is usually a second base, not a move. Greece (no minimum stay) and Italy (no continuity requirement for five years) fit that best, Portugal asks for a few days a year. Two things decide the details: the passport you hold, not where you live, and the tax you could take on by spending too long in Europe.

Your passport, not your residence, decides your visa

Of the Gulf states, only UAE nationals are visa exempt for Schengen short stays under the EU visa list; nationals of Bahrain, Kuwait, Oman, Qatar and Saudi Arabia need a visa.

A proposal to exempt Kuwait and Qatar was still awaiting Parliament's position when we checked. Most people living in the Gulf are not Gulf nationals, and for them the visa rules of their own passport apply. A European residence permit is what removes the visa question for the issuing country.

Applying from the UAE

You can usually apply through the consulates in the UAE as a legal resident: Italy's embassy in Abu Dhabi takes applications from holders of an Abu Dhabi residence visa through BLS International, and Dubai and Northern Emirates residents go to the Consulate General in Dubai.

Portugal's visa service provider asks for your UAE residence visa as part of the file.

Documents when you live outside your home country

Expect to need a police certificate from the UAE as well as from your country of nationality, and plan for both to be legalized or apostilled.

The tax trap

The UAE does not levy income tax on individuals, so becoming tax resident in Portugal, Greece or Italy could mean paying tax you do not pay today; in Portugal and Greece, more than 183 days in twelve months, or a home and center of life there, makes you resident.

That is why most Gulf residents we speak to want a light footprint route. Keep a record of your days. A UAE tax residency certificate may help with treaty claims.

Which country fits

Greece for a summer home you will actually use, Portugal for a fund investment with minimal stay, Italy if you want to put money into an Italian business.

See Greece, Portugal and Italy.

Questions we hear most

Do I need to give up my UAE residence?

No golden visa we cover requires it. Greece has no minimum stay, and Portugal asks for seven days in the first year.

Do Saudi or Qatari nationals need a Schengen visa?

Yes, under the EU visa list as we read it. Only UAE nationals are exempt among Gulf states.

Will I pay income tax in Europe?

Only if you become tax resident there, which depends mainly on days and where your life is centered, not on the permit.

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Brazil

Brazilians have an advantage in Portugal that no other passport on our list has: as citizens of a Portuguese speaking country they need seven years of legal residence for Portuguese citizenship, not ten, and are presumed to meet the language requirement. At the same time Italy has narrowed citizenship by descent, which many Brazilian families relied on, so a golden visa is now a real option for people who once expected an Italian passport through a grandparent.

When a golden visa makes sense for a Brazilian, and when another route does

A golden visa makes sense if you want residence based on capital rather than a job or study place; if you plan to work in Portugal, a work or other residence route may cost far less than €500,000.

Brazilians can visit Schengen countries without a visa for up to 90 days in any 180. Portugal's old "expression of interest" route, which many Brazilians used to regularize after arriving as visitors, was revoked by Decreto-Lei n.º 37-A/2024 in June 2024.

Portugal: seven years, not ten

Since 19 May 2026 Portuguese nationality needs ten years of legal residence for most foreigners but seven for nationals of Portuguese speaking countries, counted within a nine year window.

The law also presumes that nationals of Portuguese speaking countries meet the language part of the knowledge requirement. Applications pending on 19 May 2026 stay under the old five year rule. Combined with the fund route's light stay rules, this makes Portugal the obvious first look for Brazilian investors, but genuine residence still matters for nationality.

Italy after the 2025 descent reform

Decree-Law 36/2025, converted by Law 74/2025, means a person born abroad who holds another citizenship is generally considered never to have acquired Italian citizenship by descent, unless an exception applies.

The exceptions include an application or court claim filed by 23:59 Rome time on 27 March 2025, a parent or grandparent who holds or held only Italian citizenship, or a parent who lived in Italy for two continuous years after becoming Italian and before the child's birth. Families who no longer qualify can still look at the Investor Visa, but naturalization through residence then takes ten years.

Leaving Brazil for tax

If you leave Brazil permanently, the Receita Federal requires a Comunicação de Saída Definitiva by the last day of February of the following year, and a separate Declaração de Saída Definitiva by the normal income tax deadline.

You become non resident after twelve consecutive months abroad if you have not filed the communication.

Documents from Brazil

The Polícia Federal criminal record certificate is free, issued online, valid for 90 days, and reads "NADA CONSTA" if there is no final conviction.

The 90 day validity is short, so request it close to filing.

Which country fits

Portugal for most Brazilians who want citizenship eventually, Greece for a home with no minimum stay, Italy for those whose descent claim closed and who want to invest in an Italian business.

Brazil's own position on dual nationality matters too.

Questions we hear most

How long until a Brazilian gets Portuguese citizenship?

Seven years of legal residence under the law in force since 19 May 2026, against ten for most other nationalities.

Can I still get Italian citizenship through my grandparents?

Only if you fall within one of the exceptions in Decree-Law 36/2025, such as an application filed by 27 March 2025.

Do Brazilians need a Schengen visa?

No, for visits of up to 90 days in any 180 day period.

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Türkiye

Turkish citizens need a Schengen visa for every short trip, so a residence permit in Portugal, Greece or Italy is as much about freedom to travel as about living there. Greece, a short flight away and still offering a property route, is where most Turkish readers start. Turkish law allows residents to buy foreign currency and send it abroad through banks, and allows you to hold a second citizenship once it is registered.

Schengen access without a visa every trip

Turkey is on the EU list of countries whose nationals need a visa for short stays, and a residence permit from a Schengen country removes that need for the issuing country.

The European Commission notes residence permit holders can travel in the Schengen area.

Moving funds out of Turkey

Under the communiqué on Decree No. 32, residents of Turkey can freely buy foreign currency and transfer it abroad, provided transfers go through banks or PTT; banks report non trade transfers above USD 50,000 to the Central Bank within 30 days.

If you carry Turkish lira in cash when traveling, amounts above TL 185,000 must be declared (amended 28 March 2025).

Dual citizenship

Turkish Citizenship Law No. 5901 provides that a person who acquires another citizenship has it recorded in the civil registry once they submit the documents, so naturalizing in Europe later does not by itself end Turkish citizenship.

Naturalization takes seven years of lawful and permanent residence in Greece, and ten years in Portugal and Italy.

Documents from Turkey

The criminal record certificate (adli sicil kaydı) is issued through e-Devlet, which needs your e-Devlet login.

Which country fits

Greece for a home close to Turkey with no minimum stay, Portugal for a fund investment, Italy for an Italian business stake.

Greece's €800,000 tier covers islands with more than 3,100 inhabitants, so check the tier for the exact island before you choose. See the Greece guide.

Questions we hear most

Do Turkish citizens need a Schengen visa?

Yes, for short stays. A golden visa residence permit removes that need for the country that issues it.

Can I keep Turkish citizenship if I become Greek or Portuguese?

Law 5901 provides for registering a foreign citizenship you acquire. Confirm your own case with a Turkish lawyer.

Can I send money abroad from Turkey to invest?

The Decree No. 32 communiqué allows residents to transfer foreign currency abroad through banks or PTT, with reporting above USD 50,000.

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