The Concept
A golden visa is residency in exchange for a passive investment: buy an asset of a set size — receive the right to live in the country (more often, the right not to live there while keeping the status). It differs from citizenship by investment fundamentally: you get residence, not a passport; and from ordinary residence permits — in requiring no job, no business activity and no permanent presence.
The class emerged in 2012: Portugal and other peripheral EU economies, emerging from the debt crisis, sought capital inflows and offered residency for property purchases. Within a decade the scheme spread to some fifty countries — from the Caribbean to the Gulf — peaking in the late 2010s. Then the pendulum swung back, under pressure from Brussels, money-laundering scrutiny and the housing question boiling over in the capitals.
The class is shrinking: Spain closed its golden visa in April 2025, Portugal removed real estate, Ireland and the UK closed earlier. The survivors' logic: money into the economy (funds, business) rather than into residential property.
The class in parameters:
| Thresholds | €50–800k in the EU, AED 2m in the UAE, S$10m in Singapore |
|---|---|
| Formats | Real estate, funds, business, government bonds, deposit, contribution |
| Citizenship | Not part of the status: Portugal — 10 years (7 for EU/CPLP); Saudi Arabia — none |
| Tax | Never automatic: the 183-day rule and the centre of life decide |
| Legal frame | A member-state competence; citizenship for money closed by C-181/23 |
| Family | Educational entitlements are not part of the status: equal treatment under Directive 2003/109/EC arrives with long-term resident status at five years |
The Programme Index
What follows is an index: one line per programme, giving what the entry costs and what the money buys. Everything a choice actually turns on — time to status, the days the permit costs, whether it leads to permanent residence or a passport, the tax effect and reform risk — is compared on the three regional maps linked above each block, on a single set of seven axes. The parameters are not repeated here, and where the index and a map disagree the map governs.
Europe: ten jurisdictions
All ten routes, including the AIMA queue and the presence each permit requires, are compared in residence by investment in Europe.
| Programme | Entry from | Format |
|---|---|---|
| Portugal, ARI | €250,000 | Fund €500,000; culture €250,000; research; business with 5 or 10 jobs. Property excluded |
| Greece | €250,000 | Property €800,000 (zone A) or €400,000 (zone B), from 120 m²; €250,000 for conversion; AIF €350,000 |
| Italy | €250,000 | Start-up €250,000; company €500,000; government bonds €2,000,000; philanthropy €1,000,000 |
| Hungary, guest investor | €250,000 | Real-estate fund certificates held 5 years, or €1,000,000 to a state university |
| Cyprus | €300,000 | New-build from a developer, commercial property, units in a Cypriot fund or company shares |
| Malta, MPRP | €99,000 in payments | Administrative fee, contribution and donation, plus purchase from €375,000 or lease from €14,000 a year |
| Latvia | €50,000 | Share capital of a small or large company; the property and deposit routes closed to new applicants when the new Immigration Law took effect on 15 September 2026, and permits already issued on them can be renewed (Imigrācijas likums) |
| Luxembourg | €500,000 | Existing or new company; €3,000,000 into a management structure; €20,000,000 on a five-year deposit |
| Andorra | €1,000,000 | Passive residency; investment in Andorran assets, €50,000 of it paid to the AFA |
| Spain and Ireland | — | No investor route: the Ley 14/2013 entrepreneur visa, the Irish STEP and Stamp 0 remain |
The €250,000 entry in Greece survives only for commercial-to-residential conversions, heritage restorations and startup investments. It is Europe's most in-demand program: a record 8,879 approvals in 2025, +61% applications in Q1 2026; the Italian investor visa +43% in the same quarter. Andorra moved in the opposite direction: article 10 of Llei 2/2026 rewrote article 96 of Llei 9/2012 and raised the investment in Andorran assets to €1,000,000 from 13 February 2026, the day after publication in the BOPA, with €50,000 of that sum paid to the Autoritat Financera Andorrana as a non-refundable receipt of the State rather than a returnable deposit.
The Portuguese fund must hold at least 60% in Portuguese companies and carry no direct or indirect real-estate exposure; since 19 May 2026 the citizenship clock runs from card issuance (Lei Orgânica 1/2026). Malta's GRP and Gibraltar's Category 2 sit alongside on a different basis: what is bought is not an entry threshold but a tax ceiling — a flat 15% on remitted income and a cap on tax for HNWIs.
The Gulf and Asia: fourteen jurisdictions
In the Gulf what is bought is a tax profile, in Asia access in exchange for activity; both halves are laid out in premium residencies in the Gulf and Asia.
| Programme | Entry from | Format |
|---|---|---|
| UAE Golden Visa | AED 2m | Property or capital, 10 years; no PR as a category |
| Saudi Premium Residency | SAR 100,000 a year | SAR 800,000 for the unlimited category; property from SAR 4m; investor from SAR 7m |
| Qatar | $200,000 | Property; from $1,000,000 an application for permanent status under Law 10/2018 |
| Bahrain | BHD 130,000 | Property; no permanent residence as a category |
| Kuwait | Not published | Investor residence of up to 15 years |
| Oman | OMR 200,000 | Company shareholding from OMR 200,000, investment from OMR 250,000, property in an ITC |
| Singapore GIP | S$10m | S$10m into a business, S$25m into a fund, or a single family office with AUM from S$200m |
| Hong Kong, New CIES | HK$30m | Net assets of HK$30m, of which HK$3m into the CIES Investment Portfolio |
| Japan, Business Manager | ¥30m | Share capital, one full-time employee and Japanese at B2 since 16 October 2025 |
| Republic of Korea, IISPB | KRW 1bn | Property KRW 1bn; KRW 1.5bn gives F-2, KRW 3bn gives F-5 at once |
| Taiwan | $200,000 | ARC on investment; APRC at NT$15m plus 5 jobs or NT$30m in government bonds |
| Thailand, LTR | ฿650,000 | Privilege Card from ฿650,000; LTR on assets from $1m with $500,000 into Thailand |
| Malaysia MM2H | $150,000 | Three tiers by deposit — $150,000, $500,000, $1m — each with mandatory property; PVIP separately |
| Indonesia, Golden Visa | $350,000 | E28 without a company: $350,000 for 5 years, $700,000 for 10; with a company from $2.5m |
The UAE threshold is measured by the property's full value rather than the amount paid (Article 8, section Second, of the Annex to Cabinet Resolution No. 65 of 2022, in force 3 October 2022), so mortgaged and off-plan purchases qualify; the old AED 1m minimum down payment was an administrative requirement dropped in January 2024.
Saudi Arabia is the only programme in the region that sells an open-ended status outright (Royal Decree No. M/106 of 10/09/1440H, 15 May 2019), and it carries no route to citizenship; the five qualifying categories added in January 2024, from the SAR 7m investor to the gifted applicant on a ministry recommendation, are set out in the Saudi profile. Neither the Emirati nor the Saudi status moves the tax nexus by itself: that is created by presence, a permanent home and a residency certificate.
The Americas and Oceania: twelve routes
The developed economies of the region left the residence trade almost in unison, and what remains divides into status in a specific country and market access; the axes are compared in investor routes in the Americas and Oceania.
| Programme | Entry from | Format |
|---|---|---|
| United States, EB-5 | $800,000 | $800,000 in a TEA, rural area or infrastructure project, otherwise $1,050,000 |
| United States, E-2 | No minimum | A "substantial" investment in an operating business; a treaty-country passport is required |
| United States, Gold Card | $1m | $1m individually or $2m under corporate sponsorship, plus a $15,000 fee; contested in court |
| Canada, Quebec QIIP | CAD 1m | A five-year investment plus a CAD 200,000 contribution; the federal routes are closed |
| Australia, NIV 858 | — | Achievement rather than capital: no monetary threshold since the 2024 closure |
| New Zealand, Active Investor Plus | NZ$5m | Growth NZ$5m or Balanced NZ$10m; relaunched in April 2025 and issuing status |
| Panama, Qualified Investor | $300,000 | Property $300,000, securities $500,000 or a deposit of $750,000 |
| Paraguay, Investor Pass | $70,000 | $70,000 manufacturing, $150,000 tourism, $200,000 securities or commercial property |
| Uruguay | $100,000 a year | The impatriate regime by investment: funds from 625,000 UI a year, or property above 12.5m UI |
| Brazil, VITEM IX | R$150,000 | R$500,000 into a company, R$150,000 for innovation; full worldwide-income taxation |
| Chile | $500,000 | Investor temporary residence into production, with InvestChile sponsorship |
| Mexico | $300,000 | No programme, a solvency test: a company at ~$300,000 or property at ~$598,000 |
Two routes in the region exist only on paper: the Canadian entrepreneur pilot promised after intake was zeroed out on 1 January 2026 has no published parameters, and Argentina's Decreto 524/2025 offers citizenship for a "significant investment" whose sum is unpublished. Residency through property in the zero-tax islands — the Cayman Islands, the Bahamas and Bermuda — and the rentista, inversionista and pensionado routes of Costa Rica run on their own logic and sit outside the regional map. The Costa Rican investor threshold is no longer the low figure usually quoted: article 8 of Law 9996 set $150,000 for the law's five-year term, which ran out on 14 July 2026 along with the customs and tax relief of article 5, leaving the $200,000 of the baseline immigration regulation as the amount a new applicant confirms with the Directorate General of Migration and Immigration. A fund contribution from $200,000 in the five Caribbean states buys something else entirely — a passport, not a permit: that is citizenship by investment.
How to Choose
The task first, the program second. If the goal is a backup base without relocating, pick programs with no presence requirement (Greece, the UAE, the Caribbean). If the goal is citizenship, count the naturalisation clock and the actual-residence requirements. If the goal is taxes, a golden visa by itself solves nothing: look at the special tax regimes and the 183-day rule — a residence permit does not make you a tax resident automatically, and conversely, excess days in the country will make you one even without a visa.
A fourth purpose is what the status is worth to a family beyond the right to live in the country. A residence permit obtained by investment does not by itself carry the educational entitlements families assume, and England is the clearest case: the home tuition rate goes only to a person settled in the United Kingdom who has also been ordinarily resident for three years, so an investor permit holder pays the overseas rate — a home cap of £9,790 for 2026/27 against published overseas fees from £17,000 to £62,820. Equal treatment in education and vocational training under Article 11(1)(b) of Directive 2003/109/EC arrives with long-term resident status, which Article 4(1) makes available after five years of legal and continuous residence, while the investor card issues at once. That layer is unpacked in what a status is worth beyond entry.
This map answers the question of which programmes exist. The decisive layer is a different one: which legal structure is actually being bought and what is consumed for good in each — contribution, fund, property, business or deposit: the five models of investment migration. The overall order — from model to region and on to a specific programme — is set out in the investor cluster map.
Regulation and the Cancellation Risk
Brussels presses along two lines. Citizenship for money was held incompatible with the nature of Union citizenship by the EU Court in April 2025 (Commission v Malta, C-181/23) — closing the EU's last CBI program. Residency was untouched by the ruling: golden visas remain a member-state competence. The political pressure is real nonetheless: Spain closed its program from April 2025; Portugal and Greece raised thresholds and narrowed property as the entry route.
The second line is transparency. Source of funds is vetted under AML rules, and new-resident status falls within automatic exchange: CRS sees the account regardless of where the residence permit was issued. Residency is therefore planned together with tax residency and the exchange regime, not as their replacement; a genuine relocation adds the exit tax of the country of departure.
Where It Is All Heading
The trend runs from residential property to investments in the economy: funds, business, government bonds. New entrances appear too: in December 2025 the US opened intake for the "Gold Card" — the route created by Executive Order 14351 of 19 September 2025 (published 24 September 2025, 90 FR 46031). There are two cards, and their terms differ.
| Card | Contribution | What it gives |
|---|---|---|
| Gold Card | $1m by an individual or $2m under a corporate scheme, plus a $15,000 fee (announced as $5m) | Lawful permanent resident status as an EB-1 or EB-2 holder; the holder is a U.S. person taxed on worldwide income |
| Platinum Card | $5m | Promised: up to 270 days a year without tax on non-U.S. income; not created by the executive order, not open for applications |
The Gold Card carries no tax break: the official programme site states that holders will be subject to U.S. tax, including on non-U.S. income. The Commerce Secretary has said that implementing the Platinum Card requires action by Congress. Demand and legal footing are both thin. Intake opened in December 2025; one approval had been confirmed by the end of April 2026 against what the administration described as hundreds of applications in the queue; and a suit filed in the federal district court for the District of Columbia on 3 February 2026 argues that a payment displaces the requirements Congress set for the EB-1 and EB-2 categories. Until that is decided the Gold Card is a product with unresolved legal risk rather than an alternative to EB-5, which has a statutory basis and protection for petitions already filed.
In parallel, the Gulf's fast zero-tax hubs and the Caribbean hold their ground, and the perpetual-traveler scenario is back in fashion among those who need the status without the move.
Q/A
How does a golden visa differ from citizenship by investment?
A residence permit gives the right to live and (in the EU) move around Schengen, but not a passport. Citizenship by investment is a separate class of programs (the Caribbean, Türkiye) with different thresholds and risks: see the "Second citizenship" hub.
Can you hold a golden visa without becoming a tax resident?
Yes — that is the standard configuration: the status is maintained with minimal presence (in Greece, zero), while tax residency stays in another country. It breaks when the actual centre of life moves: formal day counts stop helping, and the treaty tie-breaker decides.
Can the state cancel the program after I buy?
Programs are cancelled regularly, but existing statuses are usually preserved (grandfathering): Spanish visas issued before April 2025 keep renewing. The risk is not losing the status, but the impossibility of upgrading terms — and the politics of the next government.