Greece vs Portugal Golden Visa 2026 — Real Estate Route Verdict
Portugal closed property Golden Visa · Greece's €250k commercial-to-residential channel remains open
Verdict
Portugal abolished the real-estate investment route for its Golden Visa in October 2023, retaining only fund (≥€500k), scientific, and cultural heritage donation routes; simultaneously, Portugal's NHR tax regime ended in 2024. Greece Golden Visa (Law 5038/2023) maintains the three-tier real estate investment route (€250k / €400k / €800k) with zero residency requirement, three-generation family inclusion, and 4-month approval. For Chinese families targeting "real estate + permanent residence," Greece in 2026 is the more practical and value-driven choice.
1. Program Background & Legal Basis
The Portuguese Golden Visa (ARI) was once the benchmark European real-estate investment migration program. However, the Mais Habitação Act passed in October 2023 closed the real-estate investment route, retaining only fund, scientific research, and artistic donation channels. Concurrently, Portugal's NHR tax preferential regime ended in 2024. The Greek Golden Visa continued maintaining the real-estate investment route after the 2024 reform (Law 5038/2023), introducing the new "commercial-to-residential €250k" exemption that is particularly favorable for Chinese families. This article provides a point-by-point comparison based on the official legal frameworks of both countries to support your decision.
2. Side-by-Side Comparison
Based on official legal/policy documents of both countries, comparing 10 key dimensions.
Minimum Investment
Real Estate Investment Supported
Residency Requirement
Processing Time
Family Coverage
Schengen Access
Citizenship Path
Permanent Residence Validity
Tax Preferences
Legal Basis
| Dimension | 🇬🇷 Greece | 🇵🇹 Portugal |
|---|---|---|
| 01Minimum Investment | €250,000 (commercial-to-residential / protected heritage restoration) | €500,000 (fund) / €250,000 (artistic donation) / real estate route closed |
| 02Real Estate Investment Supported | ✅ Supported (primary route) | ❌ Closed since October 2023 |
| 03Residency Requirement | 0 days/year (no minimum stay) | 14 days first 2 years + 14 days every 2 years thereafter |
| 04Processing Time | 3–6 months (compressed to 3–4 months by OULANG direct operation) | 8–14 months (severe backlog) |
| 05Family Coverage | Principal + spouse + unmarried children under 21 + parents of both spouses (three generations) | Principal + spouse + children (parent conditions strict) |
| 06Schengen Access | ✅ 29 countries | ✅ 29 countries |
| 07Citizenship Path | 7 years (subject to tax residency conditions) | 5 years (language exam + residency requirement) |
| 08Permanent Residence Validity | 5-year renewable indefinitely; convertible to EU LTR after 5 years | 2 years initial + 2-year renewals |
| 09Tax Preferences | Non-Dom application available (€100,000 annual flat tax) | NHR ended 2024 |
| 10Legal Basis | Law 5038/2023 | Law 23/2007 (frozen by 2023 amendments) |
Gold-highlighted rows show dimensions where Greece is significantly advantaged. Data based on public legal texts as of May 2026; OULANG INTERNATIONAL does not assume responsibility for data currency. Confirm with current regulations before formal application.
🇬🇷 Greek Advantages
- ✓Real-estate investment route still open (Portugal closed)
- ✓€250k commercial-to-residential threshold — lowest active Golden Visa in Europe
- ✓Zero residency requirement — Portugal still requires 14 days every 2 years
- ✓Three-generation coverage — Portugal's parent eligibility is stricter
- ✓3–6 months processing vs Portugal's 8–14 month backlog
- ✓Non-Dom tax preferences (€100k/year flat tax) still active — NHR ended
🇵🇹 Portugal Limitations / Restrictions
- ✗Real-estate investment Golden Visa route completely closed since October 2023
- ✗NHR tax preferences ended 2024 — significantly reduced appeal for wealthy clients
- ✗Fund route threshold ≥€500k + 5-year lockup, poor liquidity
- ✗Severe processing backlog: new applications 8–14+ months
- ✗Residency requirement low but still requires annual entry
3. Which Audience Fits Which Program
Chinese families seeking real-estate-based migration, high value-for-money, three-generation simultaneous permanent residence, and Huaqiao Sheng Gaokao pathway for children
High-net-worth individuals with existing Portuguese business / research / cultural connections willing to pursue fund or donation routes
4. Real Client Scenario (OULANG 2024–2026 Records)
Scenario: Shanghai-based Ms. Lin and her husband originally planned to apply for the Portuguese Golden Visa. After the October 2023 closure, they pivoted to Greece. They selected a €250k Athens commercial-to-residential property and obtained Greek permanent residence in 4 months. The entire family (3 generations) was approved simultaneously, with free Schengen 29-country travel and zero residency burden.
5. Frequently Asked Questions
Can the Portuguese Golden Visa still be obtained after closure?+
Yes, but only via fund (≥€500k), artistic donation (≥€250k), scientific donation (≥€500k), or business investment (creating 10 jobs) routes. The real-estate investment route closed completely in October 2023. For most Chinese families targeting real-estate-based migration, Greece's €250k commercial-to-residential has become the more realistic choice.
Greek Golden Visa vs Portuguese Golden Visa — which is better for Chinese applicants?+
For the vast majority of Chinese families, Greece is more suitable: 1) maintains real-estate route — tangible visible assets; 2) €250k commercial-to-residential threshold far below Portuguese fund's €500k; 3) zero residency requirement vs Portugal's every 2 years 14 days; 4) faster processing 3–4 months vs Portugal's 8–14 months; 5) three-generation coverage vs Portugal's strict parent conditions; 6) Non-Dom tax preferences remain applicable while Portugal's NHR ended.
Is the Portuguese fund Golden Visa still worthwhile?+
Suitable for specific groups: investors with existing Portuguese business networks, those preferring fund-based diversified investment, or those whose ultimate goal is Portuguese citizenship after 5 years (subject to language exam requirements). However, for "real estate + permanent residence + three generations" goals, Greece is more direct.
Will Greece's real-estate Golden Visa also close in the future?+
The Greek government has explicitly maintained the real-estate route through Law 5038/2023 in 2024, raising thresholds rather than closing. Policy trajectory shows Greece prefers "price adjustment" over "closure," though the €250k commercial-to-residential channel may tighten in the future. We recommend applying within the 2026–2027 window.
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