🇵🇹Five Ways to Buy In: Contribution, Fund, Property, Business, Deposit

The concept: five entry structures and what each one consumes for good

Investment migration is usually compared country by country. That is convenient for a catalogue and useless for a decision. The meaningful differences do not run along borders; they run along the legal structure of what is actually being bought. There are five such structures: a non-refundable contribution to a government fund, a subscription to a regulated investment fund with an exit horizon, the purchase of real estate, an investment in a business that creates jobs, and money parked in a deposit or in government securities. Each answers five questions differently: how much money disappears for good, when the status arrives, how many days a year must be spent in the country, whether the arrangement survives the next amendment, and what is left of the asset on the way out.

The "how much is lost" axis matters more than the "how much is paid in" axis. A $200,000 contribution to a Caribbean fund is gone in full, yet it buys a passport in five to eighteen months on measured Q4 2025 timelines — 5.1 in St Kitts, 18 in Saint Lucia. A €500,000 subscription to a Portuguese fund is formally refundable, but it sits for five to ten years in an illiquid asset class, and the manager is paid three times over — on entry, on management and on performance; the actual rates sit in the regulation of the individual fund registered with the CMVM, and routes can only be compared through that document rather than through a distributor's verbal summary. Property looks like the most protective of the five — and it is precisely the one that most often loses value when the rules move, because the visa premium baked into the price of a qualifying flat evaporates on the day the threshold rises or the option is withdrawn.

The frame of the choice in parameters:

Model 1: non-refundable contribution

A non-refundable contribution to a state fund is a structure with no residual asset: money is exchanged for status, not for property. All five Eastern Caribbean programmes participate in the 2024 memorandum — Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and Saint Lucia; the OECS named all five as signatories in June 2024 and confirmed the common USD 200,000 floor from 1 July 2024. The memorandum contemplated independent regional supervision, but the memorandum by itself does not prove that the new regulator has commenced and is producing regulatory practice: ratification, commencement and published decisions must be checked before relying on ECCIRA. The resilience of a status already granted is different from the survival of the programme: revocation rules govern the former, while pricing, eligibility or the programme itself may change for future applicants. See citizenship by investment and the EU visa suspension mechanism.

The European version of the same idea looks different. Hungary's Guest Investor Programme, relaunched on 1 July 2024, includes a €1 million donation to a higher education institution in support of research or creative work — the money does not come back, and the residence permit runs for ten years with a single renewal. Malta left the model altogether after the Court of Justice ruled against it: on 29 April 2025 the Grand Chamber held in European Commission v Malta (Case C-181/23) that naturalisation granted in exchange for predetermined payments breaches Article 20 TFEU and the duty of sincere cooperation in Article 4(3) TEU. The MEIN scheme was repealed; what remains is discretionary naturalisation under article 10(9) of the Maltese Citizenship Act, refreshed by Legal Notice 159 of 2025 of 29 July 2025, which sets no minimum investment and guarantees nothing. The detail is in Maltese citizenship by merit.

Model 2: subscription to a regulated fund

The fund model was the regulators' answer to the complaints about property: capital is routed into a supervised wrapper, the manager is licensed, and the money in theory comes back. Portugal was pushed into it. Law 56/2023 (Mais Habitação) removed real estate from the ARI residence permit for investment activity in October 2023, leaving a subscription of €500,000 or more into a qualifying fund, incorporation of a company with ten jobs, €500,000 into an existing business with five jobs held for three years, a cultural donation from €250,000 (€200,000 in low-density areas) and €500,000 into scientific research. The presence requirement remains token — an average of seven days a year.

Hungary's fund option is €250,000 held for at least five years in a specifically accredited instrument, the lowest fund threshold in the EU. New Zealand has built an entire regime on subscriptions: Active Investor Plus, relaunched in April 2025, splits into a Growth category (NZ$5 million over three years, a minimum of 21 days in the country across the period, pre-approved funds and direct investments only) and a Balanced category (NZ$10 million over five years, 105 days of presence, reduced by 14 days for each additional NZ$1 million up to a maximum reduction of 42 days). The detail is in residence in New Zealand.

Model 3: real estate

Property is still the best-selling model and the most exposed. Three episodes from the past two years show why.

Greece: zoned thresholds and a ban on short lets

Law 5100/2024 (Government Gazette ΦΕΚ Α' 49/05.04.2024, art. 64) introduced new zoned thresholds, generally applying from 1 September 2024 after the transition. EUR 800,000 applies in Attica, the Thessaloniki regional unit, Mykonos and Santorini, and on islands with a population above 3,100; EUR 400,000 applies elsewhere. The EUR 250,000 route remains for three special structures: converting principal-use premises to residential use, acquiring an industrial building or part where industrial activity has ceased for at least five years and converting it to residential use, and acquiring a listed building subject to full restoration. Transitional deals depended on meeting the preliminary conditions by 31 August 2024 and completing by 31 December 2024; where the property was substituted, completion could run to 30 April 2025. The main zoned route carries a single-property rule and a 120 sq m minimum, and short-term letting of a qualifying property is prohibited. More in the Greek golden visa.

Spain: the option vanished entirely

The harshest scenario is not a higher threshold but abolition. Spain left Articles 63–67 of Ley 14/2013 without content from 3 April 2025. Permits already issued and applications filed before the repeal took effect are covered by the transitional rules; a purchase without a filed application does not create that protection. The visa premium in a property therefore depends not on ownership alone but on whether the migration process was locked in on time.

Panama, Turkey and the UAE: where property still works

Panama's Qualified Investor Visa grants permanent residence on the purchase of unencumbered real estate; the $300,000 threshold, set by Executive Decree No. 193 of 15 October 2024, carries no expiry date, with a five-year holding period (art. 5 of Executive Decree No. 722 of 2020). Turkey keeps its route to citizenship through property from $400,000 with a three-year ban on resale; see Turkish citizenship by investment. The UAE issues a ten-year Golden Visa to investors in public investments and in real estate; the u.ae portal gives AED 2 million as the minimum capital for public investments, and the federal ICP service for real estate investors grants a ten-year Golden Residency on property worth at least AED 2 million.

Latvia remains the only Baltic state with property still on the list: under section 23(1)(29) of the Immigration Law the property must cost at least €250,000 and carry a cadastral value of at least €80,000 at the time of purchase, payment must be non-cash, and on the issue of the first permit 5% of the purchase price (according to the Latvian migration authority) is paid into the state budget. In Riga, Jūrmala and a number of adjoining municipalities a single functionally connected property qualifies; outside them, up to two properties of €250,000 each. The permit runs for up to five years.

Model 4: business and jobs

The business model asks not for money but for a result: jobs, turnover, tax.

The United States: EB-5 and ten jobs

The United States sets the template. The EB-5 Reform and Integrity Act of 2022 set the minimum at $800,000 for targeted employment areas, rural projects and infrastructure and $1,050,000 for standard projects, reserved 20% of the annual quota for rural projects, 10% for high-unemployment areas and 2% for infrastructure, and provided for CPI indexation starting on 1 January 2027 and every five years thereafter. The core requirement is unchanged: ten full-time jobs per investor. The regional centre programme is authorised to 30 September 2027, and the grandfathering provision lapses on 30 September 2026: petitions filed before that date must still be adjudicated by USCIS even if the programme later expires. The marketing claim that filing before 30 September 2026 also "locks in" the investment amount has no express basis in the statute and should be treated as unconfirmed until USCIS says otherwise. More in the EB-5 investor visa.

Paraguay: permanent residence without the temporary stage

Paraguay rebuilt its entry route along exactly these lines in 2026. Resolution No. 0283/2026 of the Ministry of Industry and Commerce introduced the Constancia de Inversionista Extranjero, the foreign investor certificate: a productive investment from $70,000 with a business plan for five formal jobs, tourism from $150,000, and real estate for economic use (not a personal or family home) or financial instruments held for at least two years, each from $200,000. The significant change is not the sum but the status: permanent residence is granted directly, without the two-year temporary stage, and SUACE issues the certificate within five working days. See residence in Paraguay.

Italy: start-up, shares or donation

Italy packages the same logic more compactly: the investor visa runs for two years and is renewable for three on an investment of €250,000 in an innovative start-up or €500,000 in the shares of an Italian limited company; a fourth option under the same regime is a €1 million philanthropic donation. Applications from Russian and Belarusian nationals are suspended on this route under Commission Recommendation C(2022) 2028.

Model 5: deposits and government securities

The fifth structure is the most conservative: the money is neither spent nor put at risk, it is frozen for a fixed term.

Panama: deposit and exchange-traded securities

Panama runs two such options inside the qualified investor sub-category (Executive Decree No. 722 of 15 October 2020, as amended by Decree No. 109 of 2022 and Decree No. 193 of 15 October 2024). The first is a fixed-term deposit of $750,000 or more, free of encumbrances, with a bank holding a general licence to operate in the country, for a minimum term of five years. The second is a purchase of $500,000 or more in securities through the Panama Stock Exchange and a casa de valores licensed by the Superintendence of the Securities Market (SMV), with an undertaking to hold them for the same five years. Both require proof that the funds came from abroad, and the investment must be evidenced to the immigration service every year for the full five; the country's wider framework is covered in Panama Friendly Nations.

Türkiye: deposit and government debt

Türkiye uses the same structure to sell citizenship rather than residence, under article 12 of Citizenship Law No. 5901 and article 20 of the implementing regulation: a deposit of $500,000 or more with a Turkish bank held for three years, with the certificate of conformity issued by the banking regulator BDDK, or $500,000 or more in government debt instruments held for the same three years, certified by the Ministry of Treasury and Finance.

Latvia and Italy: subordinated capital and bonds

Latvia works under section 23(1) of the Immigration Law and offers two entries that involve no asset purchase. A financial investment in a Latvian credit institution — subordinated capital of €280,000 or more held for at least five years, plus a payment of €25,000 into the state budget on the issue of the first permit. Interest-free government securities — a nominal value of €250,000 plus a budget payment of €38,000; the securities are bought after the application is approved, not before it is filed. Italy adds the highest threshold of this type in the EU — €2 million in Italian government bonds, for a two-year visa renewable for three.

The holding term and the annual evidence

The characteristic risk here is procedural rather than market: what is lost is not the money but the ground for the status. The holding period is applied literally — releasing the deposit early, selling the securities before the term ends or failing to file the annual evidence removes the basis for the permit and leads to its cancellation, while payments and fees already made to the budget are not refunded and the capital has by then spent several years doing nothing.

A separate branch is the Latin American rentista regimes, where entry is granted not for capital but for verified recurring income. The economics are fundamentally different: the applicant freezes nothing, but the status is weaker — usually temporary, with a real presence requirement and no direct path to citizenship.

The procedure: the point at which the money stops being refundable

The order of operations is the same across all five models and almost never matches the order proposed by whoever is selling the asset. The first non-refundable payment falls due before the investment: due diligence and application-processing fees are paid on filing and are not returned on refusal — in the Caribbean programmes that means $7,500–10,000 for the main applicant and $4,000–7,500 for each dependant aged 16 or over. The second non-refundable layer is the tax and duty on acquiring the asset: in Greece 7–11% of the price, none of which comes back on a later sale. The rules for the whole budget are set out below.

Hence the sequence: the source-of-funds file is assembled before the transaction, not after a refusal. The vetting mechanics are covered in source of funds and due diligence in investment migration; holders of a Russian passport face an additional layer of restrictions, set out in Russian applicants in investment migration.

Three written confirmations before any money moves

Before any money moves, three written confirmations are worth having — from the authority or a licensed intermediary, not from the seller of the asset. First, that the specific instrument qualifies under the programme: this fund, this property, this bank, rather than instruments of that general kind. Second, that the declared family composition qualifies by age and degree of relationship, both at the filing date and at the date of every subsequent step — a child turning 16 or 18 inside the procedure changes both the fees and the composition of the case. Third, which version of the rules applies and to which legal fact it is pinned: filing, payment or issue of the card. Paying the contribution or signing the subscription before the applicant has cleared preliminary vetting is the most expensive of the common mistakes: on a refusal the fee and the time are gone, while the money sits locked in an instrument bought for a ground that no longer exists.

How to calculate the full cost of a route

The headline threshold answers only how much capital must be paid or locked up. A decision requires a budget for the whole family and for the chosen time horizon. It has five distinct layers:

The four models show where the main non-headline cost sits:

Portugal illustrates why one tariff cannot be multiplied by the number of people at every stage. The reception and analysis charge is paid once per application, covering the family members' requests, and is due again on each renewal; issue and renewal are charged for each person. Portaria n.º 307/2023 provides for annual indexation from 1 March; the current AIMA table sets €842.80 for analysis of the file, €8,418.90 for issue and €4,210.30 for renewal per person. Filing through the online portal attracts a 25% discount: €632.10, €6,314.20 and €3,157.80 respectively. A fixed “programme price” without the family composition and the number of renewals is therefore misleading.

Nor is the EB-5 threshold permanent: the current $800,000 / $1,050,000 amounts and five-yearly indexation from 1 January 2027 come from the 2022 RIA; the mechanism is summarised by the Congressional Research Service. Private fees charged by a fund, regional centre, broker or lawyer are market markers rather than government tariffs: read them from the agreement and keep them separate from official charges.

Four worked calculations for a family of four

The same four routes, costed for one family — two adults and two children under 16 — over a five-year horizon. The state layer is taken from published schedules; the contractual layer is what a fund, a regional centre or a broker charges under an agreement, and it is marked as market practice rather than tariff. The final column is the mark-up: how much the route costs above its own headline number.

Read the second and third columns as different kinds of number. The Dominican figure is close to exact: the contribution covers a family of four as a single sum, and about $16,500 of filing and due-diligence charges on top produces a total near $266,500 and a mark-up of roughly 6.6% — the lowest in the segment, and the reason the contribution model looks expensive in headline and cheap in overhead. The Portuguese figure is exact on the state side and open on the other: €842.80 on the grant and again on the renewal, €8,418.90 per person to issue and €4,210.30 per person to renew give €52,202 for a family of four across one renewal, or €39,152 with the 25% online discount — between 7.8% and 10.4% of the subscription before the fund has charged anything. ARI funds commonly run a subscription fee of up to 3% and management of 1–2% a year, which on a six-year hold is another 7–15% of the capital; that is market practice, not a tariff, and the real figures are in the fund's CMVM-registered regulation. Added together the realistic total sits between about 14% and 27% over the €500,000, and the upper half of that range is a choice of fund rather than an act of the state.

Greece and EB-5 both hide their mark-up in one dominant line. In Greece it is the acquisition tax and completion costs at 7–11% of the price — on €400,000 that is €28,000 to €44,000 — and nothing in that layer comes back when the flat is sold; the recurring ENFIA, utilities and management sit outside the entry budget and run for as long as the status does. In EB-5 it is the regional centre's administrative fee, which is contractual and, at the rates the market has settled on, runs into the tens of thousands per investor; with the petition and adjustment fees for four people, the statutory $1,000 Integrity Fund payment that accompanies each petition and the legal work on both the immigration and the securities side, the layer above the $800,000 comes to roughly 11–16%. Two of those percentages are therefore government arithmetic and two are negotiated — which is the practical reason to demand the fee schedule of the fund or the regional centre in writing before the money moves.

For a holder of a Russian passport a fifth layer sits on top of these four rows, and it appears in no tariff: the payment route. Article 5b of Regulation (EU) No 833/2014 bars EU credit institutions from accepting deposits above €100,000 per institution from Russian nationals or residents of Russia, unless they are EU nationals or hold a temporary or permanent residence permit in a member state, so a European transit account without such a permit cannot carry a payment of this size. The account the money will leave from is therefore opened before the fund or the property is chosen, not after: details in investment migration for Russian applicants.

The budget should separate four columns: what burns on refusal, what remains a recoverable asset, what remains an asset but stays illiquid until exit, and what tax duties arise from an actual move. Calculate for the particular family and to the chosen objective — first card, renewal, permanent residence or citizenship.

The Hungarian GIP: the lowest fund threshold in the EU and the longest initial status

Hungary's Guest Investor Programme tends to be mentioned inside three different lists at once, although structurally it is a unit of its own. Since its relaunch on 1 July 2024 it grants a residence permit for ten years at once, renewable once for a further ten — the longest initial status among European investment programmes.

The fund entry is €250,000 into a fund accredited by the Hungarian National Bank and held for at least five years; that is the lowest fund threshold in the EU. The contribution entry is a non-refundable donation of €1 million to a higher education institution in support of research or creative work. The third option, buying residential property from €500,000, was due to open on 1 January 2025 and was struck out by an amendment published in Magyar Közlöny on 20 December 2024 — it never ran for a single day.

The lesson is the same as across the rest of the segment: the programme with the longest status in the Union rests on two structures that involve no asset, and it was the asset option that failed to survive its own start.

Model comparison

The price of entry first — what goes in, how much of it never comes back, and how quickly the status arrives:

Then the cost of holding it and the way out — days in the country, what can change, and what is left of the asset:

Separating the different rule-change risks

Resilience cannot be reduced to one “high–medium–low” score. Three questions are distinct: protection of a status already granted and its revocation grounds; continuing obligations of an existing holder; and availability and price for future applicants. A sunk contribution does not guarantee programme survival — Malta’s MEIN was repealed — while ownership of an asset does not automatically undo an existing permit.

Property is particularly exposed to changes in thresholds, zones and permitted use. Contribution and donation routes more often change through price and eligibility. Funds, businesses and deposits add asset or project risk to the separate risk of the migration ground. The chronology of closures and transitional rules is set out in changes to investment-migration programmes.

Tax consequences

None of the five models by itself makes the holder tax resident, and none releases them from existing obligations. Portugal's ARI with seven days a year and New Zealand's Growth category with 21 days across the period fall short of every national test. Holding an interest in New Zealand's pre-approved funds, which are usually structured as limited partnerships, nonetheless triggers a filing and a tax liability in New Zealand regardless of whether the investor ever becomes resident there. The full mechanics are worked through in golden visas and tax residence and the basics of tax residence.

Beyond the monetary structures sits entry by qualification — talent routes and routes for business owners — where the spend is measured in tens of thousands on preparing a file rather than hundreds of thousands on an asset, but the entry requirement sits in a biography that cannot be bought.