Portugal and Spain list no investment ground for newcomer tax breaks

Portugal, Italy, Greece and Spain each offer a special income-tax regime to people who move their tax residence there. Of the four, only Italy and Greece do not tie theirs to a job or a role: a fixed annual sum on foreign income, €300,000 in Italy and €100,000 in Greece, where a €500,000 investment is also required.

Portugal and Spain list no investment among their grounds. This indicates that a golden-visa investment alone does not qualify.

What the four regimes have in common

Each regime starts from tax residence after a period of non-residence, and tax residence follows each country’s own tests. This means a golden visa or investor visa gives the right to live in a country but does not by itself make anyone tax resident there. How tax residence is decided is covered in a separate article.

Two other European regimes for wealthy newcomers are covered separately: Malta’s special tax status tied to a property threshold and Switzerland’s lump-sum taxation.

Portugal: 20% for listed activities

Portugal’s incentive for scientific research and innovation (IFICI), set out in Article 58-A of the Tax Benefits Statute, has applied since 1 January 2024 and has not been amended since, according to the official consolidated text. Portuguese and foreign citizens qualify if they become tax resident, were not resident in any of the five previous years and carry out a listed activity.

The list covers higher-education teaching and research; highly qualified professions in certain companies; qualified jobs or board seats in companies with contractual investment incentives or recognised as relevant to the economy; research and development staff; jobs and board seats in certified start-ups; and jobs or other activities carried out by tax residents of the Azores and Madeira.

Income from that activity, whether employment or self-employment, is taxed at 20% for ten consecutive years from the year the person registers as resident, provided they remain tax resident and keep earning income from a listed activity each year.

Foreign income in five categories of the Personal Income Tax Code is exempt, although it still counts when setting the rate on other income. The Tax and Customs Authority’s 2025 circular summarises the rule as exemption except for category H, which the code defines as pensions.

The circular adds that income paid by entities in listed jurisdictions with a clearly more favourable tax regime is taxed at 35%; its own example is dividends from a company in Dubai.

The regime can be used once and is closed to anyone who has ever benefited from the former non-habitual resident (NHR) regime. Registration, only through the tax portal since February 2025, is due by 15 January of the year after the person becomes resident; a late registration starts the regime in the registration year and runs only for what remains of the ten years.

Article 58-A says nothing about family members or about the investment residence permit known as the golden visa. This indicates that each family member must qualify through their own activity, and that neither an investment nor a golden visa qualifies anyone by itself.

A board seat in a qualifying company is on the list (in one case a company with a contractual investment benefit), but it is the seat, not the newcomer’s capital, that the text names.

The transitional route into the former NHR regime, which accepted among other elements a residence visa or permit valid by 31 December 2023, required tax residence by 31 December 2024. A family becoming resident now therefore falls outside it.

Italy: €300,000 a year, whatever the income

Under Article 24-bis of the Income Tax Code, a person who moves residence to Italy after at least nine of ten tax periods as a non-resident may opt to pay a fixed substitute tax on income produced abroad, whatever its amount.

The 2026 Budget Law raised the sum to €300,000 a year for people moving from 1 January 2026, and the amount for each family member included from €25,000 to €50,000. People who moved after 10 August 2024 and before 2026 pay €200,000 under Decree-Law 113/2024, which replaced the original €100,000.

The option lasts at most 15 years. Its effects end if the tax is not paid in full, and revocation or forfeiture bars a new option.

Gains on qualified shareholdings realised in the first five years stay under ordinary rules. The option can be extended to family members listed in Article 433 of the Civil Code who meet the same nine-of-ten test. The lump sum covers only income produced abroad, which means that income arising in Italy stays under ordinary rules.

The statute says the option must be exercised after a favourable ruling from the Revenue Agency; the agency’s information page, updated in January 2026, says a taxpayer “may also” ask for one. The difference was not resolved for this article.

From 1 January 2027 a new consolidated income-tax code, Legislative Decree 117/2026, replaces Article 24-bis with Article 246 at the same €300,000 and €50,000.

That article states that the option cannot be combined with the regimes in Article 225 and the first five paragraphs of Article 226, the first being Italy’s regime for highly qualified workers who move there, which brings only half of the first €600,000 a year of Italian work income into taxable income.

The statute sets no work or investment condition and does not mention investor visas. The government’s Investor Visa portal presents the regime as particularly relevant to investor-visa applicants and quotes the earlier €100,000 lump sum and €25,000 per family member, as does the Revenue Agency’s English page.

Greece: €100,000 a year, after a €500,000 investment

Greece added the regime in 2019 as Article 5A of its Income Tax Code, through Law 4646/2019. The entry conditions below come from that text, which the 2025 amendments did not restate.

A person who was not Greek tax resident in seven of the previous eight years pays €100,000 for each tax year on foreign income, whatever its amount, and €20,000 for each relative included. The person, a relative or an entity in which they hold the majority must invest at least €500,000 in Greek real estate, businesses, securities or shares, completed within three years of the application.

Under the 2019 text, Greek-source income is taxed under the general rules. The regime ends after 15 tax years and cannot be extended.

Law 5222/2025, in force since its publication on 28 July 2025, allows relatives to be added later for the remaining years.

Applications are due by 31 March and must come with proof that the minimum investment was transferred to an account at a financial institution in Greece; the tax administration decides by the last working day of June. Under the 2025 text, the exemption from inheritance and gift tax covers movable property located abroad.

As enacted in 2019, the law waived the investment condition for holders of a residence permit for investment activity under Article 16 of Law 4251/2014. It was not established whether that permit is the one usually called Greece’s golden visa, or whether the waiver survives in the current code. The 2025 law does not say how the proof-of-transfer rule applies to permit holders.

Spain: four grounds, none of them an investment

Spain’s regime under Article 93 of the Personal Income Tax Law, often called the Beckham regime, lets people who become tax resident as a result of moving to Spain, after five tax periods as non-residents, be taxed under non-resident rules for the year of the move and the following five.

It applies only to those who do not earn income through a permanent establishment in Spain, except on the entrepreneurial and highly qualified grounds.

The move must result from an employment contract, including remote work and the international telework visa; from becoming a director of a company; from an entrepreneurial activity certified under Law 14/2013; or from highly qualified work for start-ups or in training, research, development and innovation, that pay being over 40% of their work and business income.

General income is taxed at 24% up to €600,000 and 47% above, and savings income at 19% to 30%. All work and entrepreneurial income counts as Spanish.

This indicates that other foreign income falls outside the Spanish charge, since the tax applies to income obtained in Spain. Wealth tax applies only to assets in Spain.

A spouse, children under 25 (any age if disabled) or, for an unmarried couple, the other parent may opt in if they move with the main taxpayer or before the end of the main taxpayer’s first tax period under the regime.

They must also become tax resident, meet the same five-year and permanent-establishment conditions, and keep their combined taxable income below the main taxpayer’s. Each opts separately, the main taxpayer first.

Article 93’s own heading names “investors”, but none of its four grounds is an investment. This means a family that invests can reach the regime only through one of them, for example a member appointed director of a company.

Where the company is an asset-holding entity as Spanish corporate tax law defines it, the director may not hold a stake that would make it a related entity.

Spain’s investor visa ended on 3 April 2025 under Organic Law 1/2025; permits already issued keep their validity for the period granted. The closure of the programme is covered in a separate article.

What this article has not established

Greece’s current consolidated Income Tax Code was not obtained, so the entry conditions and the 2019 waiver are cited from the enacting text. No official guidance on the regime was found; amendments after July 2025 were not searched for, and what the reference to Article 16 of Law 4251/2014 now points to was not checked.

It was not established how Italy’s 2027 code treats people already paying €100,000 or €200,000, nor which residence test, civil or tax, fixes the 1 January 2026 date.

No official text of a Constitutional Court ruling reported in April 2026 on the former Portuguese regime was found. No official guidance was found on whether any investor profile fits Spain’s four grounds.

The article does not cover tax treaties, social security, or how Vietnamese tax residence interacts with these regimes.