The 2026 Position
Four of the six jurisdictions commonly presented as European or Gulf residency by investment options still operate a defined investor route for new applicants. The UAE, Portugal, Greece and Malta remain open, but their qualifying conditions differ materially. Spain closed its Law 14/2013 investor route to new applications on 3 April 2025. Switzerland has no uniform federal residency by investment programme or statutory CHF 400,000 entry threshold.
The distinction that matters most is not the headline capital amount. It is the legal result. An investor residence permit grants immigration status. It does not automatically establish tax residence, treaty residence, domicile or access to a preferential tax regime.
This guide reflects official sources checked on 25 August 2026. It excludes unofficial processing estimates, promoter data and investment costs that the issuing authorities do not publish.
Current Route Map
| Jurisdiction | Position for new applicants | Current qualifying route | Separate tax question |
|---|---|---|---|
| United Arab Emirates | Open | AED 2 million public investment or real estate routes, alongside other Golden Residency categories | Golden Residency does not itself prove UAE tax residence |
| Portugal | Open, with no new property acquisition route | Jobs, research, cultural support, qualifying non property funds or company capitalisation | ARI does not itself confer IFICI or Portuguese tax residence |
| Greece | Open | EUR 800,000 or EUR 400,000 property routes, with EUR 250,000 reserved for specified conversion or restoration cases | The investor permit does not itself create Greek tax residence |
| Spain | Closed to new Law 14/2013 investor applications from 3 April 2025 | Transitional protection applies to qualifying earlier applications, valid permits and renewals | Immigration status and Spanish tax residence remain separate |
| Malta | Open | Qualifying rented or purchased property, contribution, donation, fees and financial standing requirements | MPRP does not itself confer a special tax status |
| Switzerland | No uniform federal investment programme | A discretionary residence permit and expenditure based taxation may coexist in a qualifying case | Lump sum taxation is a tax assessment method, not an investment asset |
United Arab Emirates: AED 2 Million Is a Route Threshold
The Federal Authority for Identity, Citizenship, Customs and Port Security publishes AED 2 million as the minimum capital threshold for public investment and real estate investor categories. Public investment evidence may include a qualifying fund deposit, company capital or an establishment meeting the published annual tax condition. Real estate is a separate route. It is not compulsory for every Golden Residency applicant.
The federal guidance currently describes ten year residence for public investment and five year residence for real estate investment. Other categories cover entrepreneurs, exceptional talent, students and specified humanitarian applicants under their own conditions.
Golden Residency is not a tax residence certificate. UAE domestic tax residence is determined separately under Cabinet Decision No. 85 of 2022 and Ministerial Decision No. 27 of 2023. Those rules include principal residence and personal and financial interests tests, a 183 day test, and a narrower 90 day route for specified UAE residents, citizens and GCC nationals who satisfy an additional connection condition.
The UAE Economic Substance Regulations should no longer be presented as a current filing requirement. The Ministry of Finance confirms that notifications and reports were cancelled for financial years ending after 31 December 2022. Historical obligations for earlier periods remain relevant.
Portugal: ARI Remains Open Without a New Property Route
Portugal did not abolish its investor residence framework. Lei n.º 56/2023 removed new property acquisition, property rehabilitation and unrestricted capital transfer routes while preserving a narrower set of investment activities.
AIMA currently lists five routes:
- Creation of at least ten jobs.
- At least EUR 500,000 for qualifying scientific research.
- At least EUR 250,000 for qualifying artistic production or national cultural heritage.
- At least EUR 500,000 in units of qualifying non property collective investment undertakings, subject to maturity and Portuguese company allocation conditions.
- At least EUR 500,000 for company capitalisation. A new company must create five permanent jobs. An existing company must create at least five permanent jobs or maintain at least ten jobs, including five permanent roles, for at least three years.
Lei n.º 56/2023 contains transitional protection for qualifying earlier applications and renewals. Its renewal framework includes conversion to an entrepreneurial residence authorisation and verification of the corresponding entrepreneurial project. A legacy file therefore requires individual review. The transition neither promises that every ARI renews unchanged nor reopens property acquisition to a fresh 2026 applicant.
Portugal's former Non Habitual Resident regime and the current Incentive for Scientific Research and Innovation are separate regimes. The tax authority's IFICI guidance describes an activity based incentive for people who satisfy the five year non residence test, perform a listed activity through a qualifying entity and meet the other statutory conditions. Its outer period is ten consecutive years, but entitlement must continue to be established during that period. Holding an ARI does not establish IFICI eligibility.
Greece: The General Floor Is EUR 400,000
Article 64 of Law 5100/2024 established the current property thresholds from 1 September 2024.
The EUR 800,000 threshold applies across the Region of Attica, the Regional Unit of Thessaloniki, Mykonos, Thera and islands with a population above 3,100. The general threshold elsewhere is EUR 400,000. Both routes require one property. Where the acquisition concerns built property or property with a building permit, its main use space must cover at least 120 square metres.
EUR 250,000 is not the general threshold for secondary or rural locations. It is reserved for specified single property conversion or restoration cases. The conversion route covers main use space converted to residential use after the new rules took effect. A qualifying industrial building must have had no industrial operation for at least five years. The conversion must be complete before the permit application.
The separate EUR 250,000 listed building route covers property acquired for restoration or reconstruction. The property cannot be transferred before the required works are complete, and the works must be completed before the first renewal.
The resulting investor residence permit is renewable while the statutory conditions remain satisfied. The legislation does not require continuous presence in Greece for renewal. That immigration treatment does not determine Greek tax residence.
Spain: Closed for New Investor Applications
Spain's position is settled. Final provision twenty one of Organic Law 1/2025 left Articles 63 to 67 of Law 14/2013 without content. The change took effect on 3 April 2025. The consolidated Law 14/2013 now records that closure.
The transition is material. Investor and family applications submitted before 3 April 2025 may still be decided under the rules in force when filed. Visas and authorisations valid on that date remain valid for their issued term. Renewals are processed under the rules that applied when the initial authorisation was granted.
An investment made before the cutoff is not, by itself, the statutory test for protection. The relevant application must have been submitted in time. Existing holders should also not be told that their status was cancelled automatically.
Spanish tax residence remains a separate analysis under Article 9 of Law 35/2006, including the day count, economic interests and family presumption rules. A grandfathered investor permit does not create an automatic tax exemption.
Malta: Property Is a Required Part of MPRP
The Malta Permanent Residence Programme is open to eligible nationals outside the EU, EEA and Switzerland. It requires a combination of property, contribution, donation, administrative fees and evidence of financial standing. It should not be reduced to a single EUR 1 million investment figure.
Current published conditions include a non refundable EUR 60,000 administrative fee, a EUR 37,000 government contribution and a EUR 2,000 donation to a qualifying local organisation. The applicant must either rent qualifying residential property for at least EUR 14,000 a year or buy qualifying residential property for at least EUR 375,000. The property must be retained for at least five years, after which the holder must continue to maintain residential property in Malta.
Applicants must also demonstrate either at least EUR 500,000 of capital assets, including EUR 150,000 of financial assets, or at least EUR 650,000 of capital assets, including EUR 75,000 of financial assets. These are financial standing requirements, not additional amounts paid to the government.
MPRP is an immigration status. Malta's tax authority guidance says tax residence is a question of fact and distinguishes residence, ordinary residence, domicile and the basis on which income is taxed. MPRP does not create a Portuguese style non habitual tax status.
Switzerland: Not a Federal Residency by Investment Programme
Switzerland should not appear in a table as if CHF 400,000 buys a federal residence permit. The Federal Department of Finance describes expenditure based taxation as a simplified assessment method for qualifying foreign nationals who become domiciled in Switzerland and do not work there. It is implemented differently by each participating canton, and several cantons have abolished it.
The tax calculation uses living expenditure and statutory minimum calculations. It is not an investment. Residence permission remains a separate and discretionary immigration question under the Federal Act on Foreign Nationals and Integration, with cantonal and federal requirements applying to the facts of the case.
No national processing time or capital threshold should be inferred from a private cantonal negotiation. A named canton, current cantonal authority and complete applicant facts are required before a Swiss route can be assessed.
A Decision Framework That Survives Legal Change
- Confirm that the route is open. Spain is no longer a new applicant option under Articles 63 to 67. Portugal remains open, but property is no longer a fresh ARI route.
- Identify the exact qualifying transaction. Greece's EUR 250,000 threshold applies only to defined conversion and restoration cases. Malta requires property even though it also imposes contributions and fees.
- Separate immigration from taxation. A residence card does not decide domestic tax residence, treaty residence or the tax treatment of foreign income.
- Check transition rules before relying on historic rights. Spain protects specified earlier applications and existing statuses. Portugal protects qualifying legacy files through a separate renewal and conversion framework. Neither jurisdiction protects every investment made before reform.
- Use the authority responsible for the route. Published statutes and government guidance take priority over promoter estimates and unofficial processing medians.
Primary Sources
- UAE Golden Residency, Federal Authority for Identity, Citizenship, Customs and Port Security
- UAE tax residence, Cabinet Decision No. 85 of 2022
- UAE tax residence, Ministerial Decision No. 27 of 2023
- UAE Economic Substance Regulations announcement, Ministry of Finance
- Portugal ARI, AIMA
- Portugal Lei n.º 56/2023
- Portugal IFICI, Autoridade Tributária e Aduaneira
- Greece Law 5100/2024, Ministry of Migration and Asylum
- Spain Organic Law 1/2025
- Spain Law 14/2013, consolidated
- Spain tax residence, Article 9 of Law 35/2006
- Malta Permanent Residence Programme, Residency Malta Agency
- Malta tax residence, Malta Tax and Customs Administration
- Switzerland expenditure based taxation, Federal Department of Finance
- Swiss Federal Act on Foreign Nationals and Integration
This article is general information, not immigration, tax or legal advice. Programme rules, administrative practice and individual tax residence can change. Obtain advice from qualified professionals in each relevant jurisdiction before applying or committing capital.
Frequently Asked Questions
Is Spain's Golden Visa open to new applicants in 2026?
No. Spain left Articles 63 to 67 of Law 14/2013 without content from 3 April 2025. Statutory transition rules protect specified earlier applications, valid authorisations and renewals.
Can a new Portugal Golden Visa applicant qualify by buying property?
No. Portugal's ARI remains open through specified non property routes, but Lei n.º 56/2023 removed property acquisition and rehabilitation as new application routes.
Is EUR 250,000 the general Greek Golden Visa threshold?
No. The general property threshold is EUR 400,000, rising to EUR 800,000 in specified locations. EUR 250,000 is reserved for defined conversion or listed building restoration cases.
Does investor residence automatically make someone tax resident?
No. Immigration residence and tax residence are separate legal determinations. Domestic day count, home, economic interest and family tests, together with any applicable treaty, require a separate analysis.