# Five Ways to Buy In: Contribution, Fund, Property, Business, Deposit > Contribution, fund, property, business and deposit: 2026 thresholds — €250k in Hungary, €500k in Portugal, $800k for EB-5 — and what each model really costs. Author: Alena Dunaeva — Lawyer, Family Office (https://wiki.private.law/en/authors/dunaeva) Last modified: 2026-08-14T13:13:00.000Z Canonical: https://wiki.private.law/en/investment-migration-models Topics: migration Jurisdictions: global, eu, usa, uae, portugal, greece, italy, malta, cyprus Product tags: residence-permit, permanent-residence, relocation, investment Semantic tags: residence-permit, permanent-residence, relocation, investment --- ## 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 six to nine months. A €500,000 subscription to a Portuguese fund is formally refundable, but it sits for five to ten years in an illiquid asset class carrying real fees of 2–4% a year. 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the visa premium baked into the price of a qualifying flat evaporates on the day the threshold rises or the option is withdrawn. ## Model 1: the non-refundable contribution — dearest of all, fastest of all, sturdiest of all A non-refundable contribution to a state fund is the only structure in which applicant and government exchange simple things: money for status, with no asset standing between them. The Caribbean has worked this way since 1984. Under the memorandum of understanding signed on 20 March 2024, Antigua and Barbuda, Dominica, Grenada and St Kitts and Nevis fixed a floor of $200,000 and agreed to measure the threshold by funds actually received rather than by the headline figure before agents' commissions; St Lucia did not sign. The same document announced a common regional regulator — as of August 2026 the least implemented part of the deal. In practice a contribution means six to nine months, no physical presence requirement, and no residual asset. 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](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A62023CJ0181) 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 on 30 July 2025, which sets no minimum investment and guarantees nothing. The detail is in [Maltese citizenship by merit](https://wiki.private.law/en/malta-citizenship-merit). > 💡 The paradox of the contribution model: it costs the most in net losses and is the hardest to disturb. When a government changes the rules it edits thresholds and lists of eligible assets — which is to say, it touches future applicants. A contribution already paid cannot be revalued retroactively, because there is nothing to revalue: the transaction is closed, no asset stands on the other side, and there is no valuation to argue about. ## Model 2: subscription to a regulated fund — refundability in exchange for time 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 as of August 2026. 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 \(NZ$10 million over five years, 105 days of presence, reduced by 14 days for each additional NZ$1 million up to a maximum reduction of 42 days\). By mid-December 2025 Immigration New Zealand had received 491 applications representing roughly NZ$2.91 billion, of which 129 were approved — exceptionally strong demand by the standards of the segment. The detail is in [residence in New Zealand](https://wiki.private.law/en/new-zealand-residence). > ⚠️ The standard error in the fund model is treating the subscription as an investment rather than as the price of a status. Visa funds are almost always illiquid, their life is pinned to the holding period for the status, and entry, management and performance fees eat a visible share of the capital. Tax is a separate layer: New Zealand's pre-approved funds are often structured as limited partnerships, and holding an interest in one can by itself trigger a filing and a tax liability in New Zealand even where the investor never becomes tax resident there. ## Model 3: real estate — the easiest entry and the most fragile status 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 rewrote article 100 of the Immigration Code \(Law 5038/2023\): since 5 April 2024 the thresholds are €800,000 for Attica, Thessaloniki, Mykonos, Santorini and 32 larger islands, €400,000 for the rest of the country, and €250,000 in two narrow cases — conversion of a commercial building into residential use \(the conversion must be completed before filing\) and full restoration of a listed building. A minimum of 120 sq m of principal floor area and a single-property rule were added. The decisive point for yield: a property bought for residence purposes may not be let on a short-term basis, on pain of revocation of the status and a €50,000 fine. An asset whose main revenue channel has been cut off by statute is worth less than a comparable unencumbered one. More in [the Greek golden visa](https://wiki.private.law/en/greece-golden-visa). ### Spain: the option vanished entirely The harshest scenario is not a higher threshold but abolition. Spain [scrapped the investor residence permit through Organic Law 1/2025 of 2 January on efficiency measures for the Public Justice Service, with effect from 3 April 2025](https://one.gob.es/en/contents/abolition-investor-visa-spain-and-its-implications): permits already issued are not revoked early, but no new ones are granted on that ground. For anyone who bought a flat "for the visa" in 2023 or 2024, the visa premium in the price ceased to exist overnight. The episode travels well beyond Spain: it is the clearest available demonstration that in a European democracy a property-linked residence route can be closed by ordinary legislation on a housing-affordability argument, with no compensation to holders and no transitional window for buyers mid-purchase. ### 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 runs until 15 October 2026, after which it rises to $500,000, with a five-year holding period. Turkey keeps its route to citizenship through property from $400,000 with a three-year ban on resale; see [Turkish citizenship by investment](https://wiki.private.law/en/turkey-citizenship-investment). The UAE issues a ten-year Golden Visa to investors in real estate and in public investments; the [u.ae portal](https://u.ae/en/information-and-services/visa-and-emirates-id/residence-visas/golden-visa) gives AED 2 million as the threshold for the investment category. Latvia remains the only Baltic state with property still on the list — from €250,000 plus a state fee of 5% of the purchase price; the structure should be checked against the current text of the Immigration Law before any transaction. ## Model 4: business and jobs — the longest route and the most substantive The business model asks not for money but for a result: jobs, turnover, tax. 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](https://wiki.private.law/en/eb-5-investor-visa). 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 or financial investments 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](https://wiki.private.law/en/paraguay-residence). > ⚙️ **Procedural benchmark.** The order of operations is the same across all five models and almost never matches the order proposed by whoever is selling the asset. First, source of funds: the file is assembled before the transaction, not after a refusal \(see [source of funds](https://wiki.private.law/en/source-of-funds) and [due diligence in investment migration](https://wiki.private.law/en/investment-migration-due-diligence)\). Second, the tax fork: model the year the status is granted and the year of a possible exit from the asset. Third, the investment itself — and only after written confirmation that the specific instrument is acceptable. Fourth, filing. Paying the contribution or signing the subscription before the applicant has cleared preliminary vetting is the most expensive of the common mistakes. ## Model 5: deposits, government securities and "passive income" The fifth structure is the most conservative: the money is neither spent nor put at risk, it is frozen. Panama accepts a fixed-term deposit from $750,000 with a qualifying bank, or a purchase of securities from $500,000 through a licensed Panamanian broker — both for five years; the country's wider framework is covered in [Panama Friendly Nations](https://wiki.private.law/en/panama-friendly-nations). Turkey keeps its deposit and bond options at $500,000 with a three-year hold. Latvia historically built its regime on subordinated bank capital and government securities; the structure and the fees should be checked against the primary source before filing, because published advisory summaries of the Latvian options contradict one another. 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. ## Axis by axis: what is lost, what comes back, what survives reform | Model | Typical 2026 threshold | Unrecoverable losses | Time to status | Presence | Resilience to reform | Liquidity on exit | | --- | --- | --- | --- | --- | --- | --- | | Contribution to a state fund | $200k \(Caribbean\), €1m \(Hungary, university\) | 100% of the sum | 6–12 months \(citizenship\) | — | High | — | | Fund subscription | €250k \(Hungary\), €500k \(Portugal\), NZ$5m \(New Zealand\) | Fees plus market risk | 6–24 months \(residence\) | 0–21 days a year | Medium | Low until the term ends | | Real estate | €250–800k \(Greece\), $300k \(Panama to 15.10.2026\), $400k \(Turkey\) | Taxes, fees, the visa premium in the price | 2–8 months | 0 \(Greece\) — varies | Low | Medium, discounted in a crowded exit | | Business and jobs | $800k / $1.05m \(EB-5\), $70k \(Paraguay\) | Full project risk | 2–5 years \(EB-5\) | Actual residence | Medium | Depends on the project | | Deposits and government securities | $750k deposit / $500k securities \(Panama\) | Forgone yield | 2–6 months | Minimal | Medium | High once released | ## Why durability runs inverse to the "safety" of the asset The pattern of the past three years reads unambiguously: reform hits the models that involve an asset and passes over the models that do not. Spain abolished the property-linked investor permit. Portugal removed real estate from the ARI. Greece tripled its thresholds and banned short lets. Hungary dropped property from its list on 15 January 2025, keeping the fund and the donation. Panama raises its property threshold on 15 October 2026. Contribution structures, by contrast, have only ever changed in price — the Caribbean floor moved to $200,000, but the model itself was not abolished in any jurisdiction that had it. The reason is political rather than legal. Investment migration through real estate creates a visible domestic conflict — house prices — and it is cheaper for a government to close the option than to defend it to the electorate. A contribution to the budget creates no such conflict. Pressure at EU level deserves separate attention: after Case C-181/23 citizenship by investment is legally closed inside the Union, while residence permits face proposals to tighten the [visa suspension mechanism](https://wiki.private.law/en/eu-visa-suspension-mechanism) and raise transparency. The Caribbean cluster lives under a deadline of its own — see [Caribbean CBI and the 2028 horizon](https://wiki.private.law/en/caribbean-cbi-2028). > ⚠️ A status obtained today does not guarantee the citizenship it was bought for. Portugal is the teaching example: the new nationality law signed by the President on 3 May 2026 raised the general naturalisation period from five years to ten \(seven for citizens of EU and Portuguese-speaking countries\) and moved the start of the clock from the date the application is filed to the date the first residence card is issued. Add AIMA's processing times and the effective horizon for anyone who entered the ARI for the passport has slipped by years. The rule: price the model against the status it delivers immediately, and treat future citizenship as an option rather than a state obligation. ## The tax footprint: a status is a right of entry, not a tax regime The most common substitution in this segment is to treat a residence permit as a tax decision. 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 creates no tax residence; New Zealand's Growth category with 21 days does not either, though holding an interest in a local fund partnership generates a filing obligation of its own. Turkey has been discussing a preferential regime for new residents on foreign income since 2026, but relying on it before the implementing rules are published is premature. The opposite mistake costs just as much: taking the status, spending more than 183 days in the country, and discovering full tax residence with everything that follows — worldwide income, controlled foreign company reporting, the lot. The fork is worked through in [golden visas and tax residence](https://wiki.private.law/en/golden-visa-tax-residency) and [the basics of tax residence](https://wiki.private.law/en/tax-residency-basics). ## The sixth model: entry without capital Beyond the five monetary structures there is a sixth, which for many applicants is cheaper and faster: status for qualification rather than for money. Talent visas \(O-1, EB-1A, the UK Global Talent route, France's Passeport Talent, the Italian and Portuguese highly qualified channels\) demand a documented record of achievement, not a payment; entrepreneur routes ask the applicant to move a working business rather than buy into somebody else's. The economics are of a different order — tens of thousands spent on preparing a file rather than hundreds of thousands on an asset — but the entry requirement sits in a biography, and a biography cannot be bought. Both branches are covered separately: [talent routes](https://wiki.private.law/en/talent-routes-models) and [routes for business owners](https://wiki.private.law/en/business-owner-routes). Holders of a Russian passport face an additional layer of restrictions, set out in [Russian applicants in investment migration](https://wiki.private.law/en/russian-applicants-investment-migration). > 🍓 The short answer. Choose the model not by country but by what you are prepared to lose. The non-refundable contribution \(from $200,000 in the Caribbean, €1 million to a Hungarian university\) is the most expensive in net losses, the fastest, and the only one that is never rewritten after the fact. A fund \(€250,000 in Hungary, €500,000 in Portugal, NZ$5 million in New Zealand\) returns the capital but locks it for three to ten years and charges fees for the privilege. Property looks safe and is abolished first: Spain closed the option on 3 April 2025, Portugal excluded it in October 2023, Greece raised the bar to €800,000 in high-demand zones, Panama lifts its threshold on 15 October 2026. The business model \(EB-5 at $800,000 or $1.05 million, indexed from 1 January 2027\) gives the sturdiest status at the price of full project risk and genuine residence. A deposit is the most liquid and the weakest in the status it produces. And none of the five is a tax solution. ## Questions and answers ### **Why is the non-refundable contribution called the most durable model when the money is lost in full** Because durability is measured by the risk to a status already granted, not by the survival of the money. In a contribution structure the transaction closes on payment: there is no asset on the other side, nothing to revalue, no question of continuing compliance with a threshold. Reform in that segment has only ever changed the price for future applicants. In asset-based models the government edits the requirements attached to the asset — zone, floor area, permitted use — and that reaches existing holders: Greece's short-let ban wipes out the yield on a property already bought. ### **What does 30 September 2026 actually mean for EB-5** The grandfathering provision of the Reform and Integrity Act lapses: petitions filed before that date must still be adjudicated by USCIS even if the regional centre programme, authorised to 30 September 2027, later expires. Petitions filed afterwards have no such protection. A separate and firmer date is 1 January 2027, when CPI indexation of the minimum amounts begins, repeating every five years. The claim that filing before September 2026 also fixes the investment amount is not supported by any express provision. ### **Is there still citizenship by investment anywhere in the European Union** No. Following the Grand Chamber judgment of 29 April 2025 in Case C-181/23, naturalisation in exchange for predetermined payments breaches Article 20 TFEU and Article 4\(3\) TEU. Malta repealed the MEIN scheme; what remains is discretionary naturalisation for exceptional services, with no minimum investment and no guaranteed outcome. Residence by investment survives in the EU, but it is a fundamentally different product: a right to live somewhere, not citizenship of the Union. ### **Which model delivers a status fastest** A contribution to a Caribbean fund: six to nine months to a passport with no presence requirement. Among residence structures, deposit and property routes move quickest — Panama's Qualified Investor Visa produces permanent residence in a matter of months, and Paraguay's Investor Pass under MIC Resolution No. 0283/2026 grants permanent residence directly, skipping the two-year temporary stage. The business model is the slowest: a full EB-5 cycle from filing to removal of conditions takes years and depends on the queue for the country of birth. ### **Is property worth buying if it is needed to live in anyway** If the property is chosen on ordinary consumer criteria and priced at market, yes — no visa premium is being overpaid. The problem starts when the property is selected to fit a threshold: in Greece that means at least 120 sq m of principal floor area, a single property, and no short lets on pain of revocation and a €50,000 fine. That bundle of restrictions creates a separate, less liquid market segment where exits happen at a discount, especially once the rules change and the visa buyers disappear. ### **Does any of these programmes deliver tax advantages automatically** No. A status confers the right to enter and to live somewhere; tax residence is determined by separate rules — days of presence, centre of vital interests, the provisions of double tax treaties. Portugal's ARI with seven days a year creates no residence. The other side: relocating on such a status and actually spending more than 183 days in the country switches on full residence with everything that follows. Preferential regimes do exist, but they sit in separate legislation and require an application of their own. --- ## FAQ ### Why is the non-refundable contribution called the most durable model when the money is lost in full Because durability is measured by the risk to a status already granted, not by the survival of the money. In a contribution structure the transaction closes on payment: there is no asset on the other side, nothing to revalue, no question of continuing compliance with a threshold. Reform in that segment has only ever changed the price for future applicants. In asset-based models the government edits the requirements attached to the asset — zone, floor area, permitted use — and that reaches existing holders: Greece's short-let ban wipes out the yield on a property already bought. ### What does 30 September 2026 actually mean for EB-5 The grandfathering provision of the Reform and Integrity Act lapses: petitions filed before that date must still be adjudicated by USCIS even if the regional centre programme, authorised to 30 September 2027, later expires. Petitions filed afterwards have no such protection. A separate and firmer date is 1 January 2027, when CPI indexation of the minimum amounts begins, repeating every five years. The claim that filing before September 2026 also fixes the investment amount is not supported by any express provision. ### Is there still citizenship by investment anywhere in the European Union No. Following the Grand Chamber judgment of 29 April 2025 in Case C-181/23, naturalisation in exchange for predetermined payments breaches Article 20 TFEU and Article 4(3) TEU. Malta repealed the MEIN scheme; what remains is discretionary naturalisation for exceptional services, with no minimum investment and no guaranteed outcome. Residence by investment survives in the EU, but it is a fundamentally different product: a right to live somewhere, not citizenship of the Union. ### Which model delivers a status fastest A contribution to a Caribbean fund: six to nine months to a passport with no presence requirement. Among residence structures, deposit and property routes move quickest — Panama's Qualified Investor Visa produces permanent residence in a matter of months, and Paraguay's Investor Pass under MIC Resolution No. 0283/2026 grants permanent residence directly, skipping the two-year temporary stage. The business model is the slowest: a full EB-5 cycle from filing to removal of conditions takes years and depends on the queue for the country of birth. ### Is property worth buying if it is needed to live in anyway If the property is chosen on ordinary consumer criteria and priced at market, yes — no visa premium is being overpaid. The problem starts when the property is selected to fit a threshold: in Greece that means at least 120 sq m of principal floor area, a single property, and no short lets on pain of revocation and a €50,000 fine. That bundle of restrictions creates a separate, less liquid market segment where exits happen at a discount, especially once the rules change and the visa buyers disappear. ### Does any of these programmes deliver tax advantages automatically No. A status confers the right to enter and to live somewhere; tax residence is determined by separate rules — days of presence, centre of vital interests, the provisions of double tax treaties. Portugal's ARI with seven days a year creates no residence. The other side: relocating on such a status and actually spending more than 183 days in the country switches on full residence with everything that follows. Preferential regimes do exist, but they sit in separate legislation and require an application of their own. --- ## Factual claims - 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 as of August 2026. - Panama's Qualified Investor Visa grants permanent residence on the purchase of unencumbered real estate; the $300,000 threshold runs until 15 October 2026, after which it rises to $500,000, with a five-year holding period. - Paraguay rebuilt its entry route along exactly these lines in 2026. - The opposite mistake costs just as much: taking the status, spending more than 183 days in the country, and discovering full tax residence with everything that follows — worldwide income, controlled foreign company reporting, the lot.