Portugal Golden Visa Funds

CMVM is the Comissão do Mercado de Valores Mobiliários, Portugal’s securities regulator (the equivalent of the SEC in the US, the FCA in the UK, or BaFin in Germany). A CMVM regulated fund is supervised by an independent state authority that oversees fund management, valuations, reporting, and investor protections. It is a credibility floor, not a guarantee against losses.

To qualify for the Golden Visa, a fund must hold at least 60% of its assets in Portuguese investments (companies headquartered in Portugal, Portuguese real assets, etc.). The remaining 40% can be deployed internationally. Funds that fall below the 60% threshold may lose Golden Visa eligibility for new subscribers.

It depends on the fund. Closed end funds (most fund route options) require you to maintain the full subscription for the five year qualifying period; exiting early forfeits your Golden Visa status. Open ended funds technically allow earlier redemption per their terms, but redeeming before you reach the five year mark, or before you have received your residence card and renewed it at year two, will also forfeit your Golden Visa. The qualifying investment must be maintained for the full five years to preserve eligibility for permanent residency.

It depends entirely on the fund. Conservative bond and ESG funds target 3% to 6% per annum. Mixed and hospitality funds target 6% to 12%. Tech and venture funds target 10% to 20%, with substantially higher risk. Holborn exclusive Atlantic Premium pays a €101k upfront return at signing, which functions as a yield enhancement on the €500k subscription. Past performance is not indicative of future results, and target IRR figures are not guarantees.

Both structures were engineered with our partners and are not available through retail channels. The Atlantic Premium Fund pays subscribers a €101,000 upfront return at signing in exchange for a six year hold, with a contractual buyback at year six. The Navigator Collection (a share capital plus job creation route, separate from the fund route) pays €175,000 upfront. Neither structure exists outside the Holborn distribution network.

If you are not a Portuguese tax resident (which is the case for almost all Golden Visa holders, given the seven day per year stay rule), Portugal does not tax your worldwide income. Capital gains and distributions from a Portuguese fund may still be subject to Portuguese withholding under specific rules, and they may also be taxable in your country of tax residence. The upfront returns paid by Atlantic Premium and Navigator Collection are paid offshore at signing and are not subject to Portuguese withholding for non residents.

For a closed end fund, the manager liquidates the underlying assets and returns capital plus realised gains to investors at the end of the lifecycle (typically year 7 to 10). For an open ended fund, you can request redemption per the fund’s terms. For Atlantic Premium, the year six buyback at €500,000 is contractual; you can also choose to retain an apartment in the hotel as the exit, depending on availability and the contract terms.

Yes. The €500,000 threshold is a total subscription requirement, not a per fund minimum. Many investors split across two or three funds for diversification, especially when individual fund minimums fall below €500k. We can model the diversification trade off against the operational simplicity of a single subscription during your strategy call.