The 60 second matrix verdict
One line per program, in plain English.
EUR 500,000 fund route, 14 day per 2 year presence, 10 year passport track (post April 2026 reform). IFICI tax overlay narrowly available. Best for buyers who want recoverable capital, light presence, and patience for a passport.
EUR 250,000 to EUR 800,000 real estate, 7 year live passport track (with B1 Greek), Non-Dom EUR 100,000 flat. Best for buyers who want a tangible Mediterranean asset and the fastest live EU passport.
EUR 250,000 (startup) to EUR 2,000,000 (bonds), 10 year passport track, EUR 200,000 flat tax for new residents. Best for UHNW with high foreign income, or for buyers who want non-real-estate flexibility.
~EUR 169,000 over 5 years (rental route) for EU permanent residency in 4 to 6 months. No defined passport track. Wide family eligibility including grandparents. Best for buyers who want EU PR cheaply and quickly without a citizenship ambition.
AED 2,000,000 (~USD 545,000) for 10 year residence visa with 0% personal income tax. No passport. Best for buyers prioritising tax efficiency and operational simplicity outside the EU.
The biggest decision is direction: do you want EU rights, or do you want a tax base outside the EU. The second decision is what you are buying with your capital: real estate, fund principal, government bonds, startup equity, or a Dubai property. The third decision is whether you actually want a passport in seven to ten years and are willing to do the work for it.
The grand matrix
The full grid in one place.
| Metric | 🇵🇹 Portugal | 🇬🇷 Greece | 🇮🇹 Italy | 🇲🇹 Malta MPRP | 🇦🇪 UAE |
|---|---|---|---|---|---|
| Lowest entry | EUR 250,000 cultural donation, EUR 500,000 fund | EUR 250,000 conversion route | EUR 250,000 innovative startup | ~EUR 169,000 over 5 years (rental + fees) | AED 2,000,000 (~USD 545,000) |
| Real estate available | No (closed October 2023) | Yes, primary route | No | Optional (rent EUR 14k/year, or buy EUR 375k) | Yes, primary route |
| Recoverable capital | Fund principal (subject to performance) | Real estate (subject to market) | Bonds yes, startup at risk | Property yes; admin/contribution fees no | Property yes (real Dubai asset) |
| Initial card validity | 2 years | 5 years | 2 years, then 3 year renewals | Permanent residency from issuance | 10 years |
| Path to citizenship | 10 years (post April 2026 reform), 7 EU/CPLP, A2 Portuguese | 7 years legal + actual residence + B1 Greek + history exam | 10 years legal + actual residence + B1 Italian + integration test | 5 years ordinary residency (with tax residence) + integration. MEIN separate, EU pressure | None for almost all applicants |
| Tax overlay (new residents) | IFICI: 20% flat on qualifying PT employment income, foreign exemption (narrow eligibility) | Non-Dom: EUR 100,000/year flat on foreign income (+ EUR 20k/family member) | Flat tax: EUR 200,000/year on foreign income (+ EUR 25k/family member) | Remittance basis: foreign income taxed only when remitted, EUR 5,000 minimum | 0% personal income tax (no overlay needed) |
| Physical presence to maintain | 14 days per 2 year cycle | None for visa | None for visa | None for status | None for status |
| Processing time | 18-24 months (AIMA backlog) | 3-6 months | 3-6 months | 4-6 months (or 1 year temp permit faster) | 2-4 weeks |
| Family covered | Spouse, children <26 students, parents >65 (or younger dependent), minor siblings | Spouse, children <24 students, parents both sides no age threshold | Spouse, dependent children, dependent parents | Spouse, dependent children, parents AND grandparents both sides | Spouse, sons <25, unmarried daughters any age, parents, domestic staff |
| Asset/income test | None beyond investment | None beyond investment | None beyond investment | EUR 500k (EUR 150k financial) OR EUR 650k (EUR 75k financial) | None beyond investment |
| Russian/Belarusian applicants | Allowed with enhanced DD | Allowed with enhanced DD | Suspended (since 2023) | Allowed with enhanced DD | Allowed |
| Passport strength at end | ~190 countries (top tier) | ~185 countries (strong) | ~190 countries (top tier) | (no passport via MPRP) | (no passport via Golden Visa) |
| Critical near-term deadlines | April 2026 nationality amendment (10 year horizon, awaiting promulgation) | None | None | MEIN under EU pressure (does not affect MPRP directly) | None |
5 year cost matrix
Family of 4, lowest qualifying route, all-in.
| Metric | 🇵🇹 Portugal | 🇬🇷 Greece | 🇮🇹 Italy | 🇲🇹 Malta | 🇦🇪 UAE |
|---|---|---|---|---|---|
| Capital deployed (recoverable basis) | EUR 500,000 (fund, recoverable subject to performance) | EUR 250,000 (real estate, recoverable subject to market) | EUR 250,000 (startup, high risk) to EUR 2,000,000 (bonds, low risk) | EUR 0 to EUR 375,000 (rent vs buy) | USD 545,000 (real estate or qualifying asset) |
| Non-refundable fees (5 year) | ~EUR 55k to EUR 95k | ~EUR 40k to EUR 70k | ~EUR 25k to EUR 75k | ~EUR 130k to EUR 150k (govt-side EUR 99k + agent + insurance) | ~USD 80k to USD 120k (transfer fees + service charges) |
| Total all-in 5 year cost (lowest route) | ~EUR 555k to EUR 595k (with the EUR 500k principal expected to recover) | ~EUR 290k to EUR 320k (conversion route, with property as asset) | ~EUR 275k to EUR 325k (startup) or EUR 2,025k+ (bonds) | ~EUR 200k to EUR 220k (rental route) | ~USD 640k to USD 700k |
| Capital risk profile | Diversified fund risk | Property cycle risk | Equity/credit risk by route | Property cycle risk (purchase) or sunk cost (rent) | Dubai property cycle risk |
Citizenship matrix
If a passport is the goal, the live tracks are Portugal, Greece, and Italy. Malta and UAE are off the table for almost all applicants.
| Metric | 🇵🇹 Portugal | 🇬🇷 Greece | 🇮🇹 Italy | 🇲🇹 Malta | 🇦🇪 UAE |
|---|---|---|---|---|---|
| Years to citizenship eligibility | 10 (post April 2026, awaiting promulgation), 7 EU/CPLP | 7 | 10 | 5 ordinary residency (requires tax residence and integration) | By Cabinet nomination only |
| Language requirement | A2 Portuguese | B1 Greek | B1 Italian | None formally; English is official | n/a |
| Integration/civics test | Yes | Yes (history/culture exam) | Yes | Integration assessment | n/a |
| Actual residence required for clock | Yes (clock advances on legal residence; physical presence and integration tested at naturalisation) | Yes (must reside, not just hold the visa) | Yes (must reside, not just hold the visa) | Yes (5 year ordinary residency requires real presence) | n/a |
| Dual citizenship allowed | Yes | Yes | Yes | Yes | UAE generally requires renunciation of original citizenship |
| Passport mobility (visa-free destinations) | ~190 countries | ~185 countries | ~190 countries | ~185 countries | ~180 countries |
Tax overlay matrix
Each program offers a different relationship to global income.
| Metric | 🇵🇹 Portugal | 🇬🇷 Greece | 🇮🇹 Italy | 🇲🇹 Malta | 🇦🇪 UAE |
|---|---|---|---|---|---|
| Personal income tax (standard) | 14.5% to 53% progressive | 9% to 44% progressive | 23% to 43% national + regional/municipal | Up to 35% on Maltese-source and remitted | 0% |
| Capital gains | 28% | 15% | 26% | Worldwide CGT only on Malta-source or remitted | 0% |
| Inheritance tax | None for direct family | Yes, with significant family exemptions | 4% to 8% (low by EU standards) | None | None |
| Special regime for new residents | IFICI: 20% on qualifying PT employment income, foreign exemption (narrow) | Non-Dom: EUR 100,000 flat on foreign income, 15 year max | Flat tax: EUR 200,000 on foreign income, 15 year max | Remittance basis (default for non-domiciled), EUR 5,000 min | n/a (no personal income tax to begin with) |
| Family member add-on (under special regime) | n/a (IFICI is per-person) | EUR 20,000 per member | EUR 25,000 per member | n/a | n/a |
| Worldwide income reporting | Yes if PT tax resident | Yes if Greek tax resident | Yes if Italian tax resident (flat tax caps liability) | Limited under remittance basis (only income brought in) | None |
| Best for foreign income above | Hard to reach favourable math without IFICI eligibility | EUR 350k to EUR 1M sweet spot | Above EUR 1M, structurally strongest | Any level, if foreign income can be managed offshore | Any level (zero tax) |
Family rules matrix
Most generous for extended family: Malta. Most generous for adult dependents: UAE. Greece is strong on parents specifically.
| Family member | 🇵🇹 Portugal | 🇬🇷 Greece | 🇮🇹 Italy | 🇲🇹 Malta | 🇦🇪 UAE |
|---|---|---|---|---|---|
| Spouse (incl same-sex) | Yes | Yes (since Feb 2024) | Yes | Yes | Yes |
| Minor children | Yes | Yes (under 21) | Yes | Yes | Yes |
| Adult dependent children | Up to 26 if studying, dependent, single | Up to 24 if studying, dependent | Yes if economically dependent | Yes if dependent (EUR 7,500 fee) | Sons up to 25, unmarried daughters any age |
| Parents | Over 65 or younger dependent | Both sets, no age threshold | Dependent only | Both sets if dependent | Both sets |
| Grandparents | Not included | Not included | Not included | Both sets if dependent | Generally not included |
| Siblings | Minor siblings under guardianship | Not included | Not included | Not included | Not included |
| Domestic staff | Not included | Not included | Not included | Not included | Unlimited domestic helpers can be sponsored |
Decision tree by goal
The shortest path from "what do I actually want" to "which program".
- 01
Do you need US residency specifically?
If: YesNone of these five. EB-5 is the only investment-based US residency. Run a comparison against EB-5 instead. The five-way matrix here covers buyers who are not US-bound.
- 02
Do you want a passport at the end of the road?
If: Yes, on the fastest live trackGreece. 7 year live track is fastest among major programs. Real Mediterranean asset, B1 Greek required.
- 03
Do you want a passport, with a powerful tax overlay during the wait?
If: Yes, willing to wait 10 yearsItaly. EUR 200,000 flat tax for new residents on foreign income makes the wait financially efficient for high foreign income. EUR 250k startup to EUR 2M bond routes available.
- 04
Do you want a passport, with light physical presence and recoverable fund capital?
If: Yes, OK with 10 year horizonPortugal. 14 day per 2 year presence is lowest in EU. Fund route preserves principal subject to fund performance. IFICI tax overlay only if you qualify (research, tech, innovation, qualified industrial, certified startup).
- 05
Do you want EU rights but no passport ambition?
If: YesMalta MPRP. Fastest, cheapest legitimate route to EU permanent residency. Wide family eligibility. No passport track via MPRP.
- 06
Do you prioritise tax efficiency over EU rights?
If: Yes, non-US personUAE Golden Visa. 0% personal income tax, 10 year residence, fast issuance. No EU rights, no passport.
- 07
Do you want to optimise both tax and EU access?
If: Yes, willing to deploy capital in both jurisdictionsUAE Golden Visa as tax base + Malta MPRP as EU door for the family. Tax residency goes to UAE (more than 183 days), MPRP gives the family Schengen and EU rights without triggering Maltese tax residency.
- 08
Do you have multi-generational family (parents and grandparents)?
If: Yes, three generationsMalta MPRP for the family scope. Greece if a passport is the goal and parents are the key generation. Run the dependent fees calculation; Malta's EUR 7,500 per adult adds up.
Reader profiles
The most common real cases we see, mapped to the program that fits.
Indian tech family passport
Indian tech family of four, want EU passport for the children, EUR 400,000 deployable, willing to learn the language and relocate. — Greece, Zone B at EUR 400,000. Fastest live passport track, real estate is a real asset, family can grow into the country over 7 years.
Non us trader
Non-US passport, USD 3M+ per year of trading and capital gains income, wants tax efficiency and operational autonomy, no EU-specific need. — UAE Golden Visa. Zero personal income tax, fast issuance, real Dubai property as the asset. Add Malta MPRP later if EU access becomes important for the family.
Uhnw italy flat tax
UHNW family, USD 5M+ foreign income, willing to relocate to Italy for the lifestyle and the flat tax. — Italy. EUR 200,000 flat tax on unlimited foreign income is the EU's most powerful overlay above EUR 1M income. EUR 2M bond route for capital preservation, or EUR 500k limited company for buyers comfortable with equity exposure.
Ifici tech founder
Tech founder relocating to Lisbon, qualifies for IFICI as senior employee of a certified startup. — Portugal. IFICI is uniquely designed for this profile: 20% flat on qualifying Portuguese employment income for 10 years, foreign source exemption. Fund route at EUR 500k preserves capital. Most powerful single-country structure for IFICI-qualifying buyers.
Grandparents included
HNW family wanting to bring elderly parents and grandparents under one residency, three generations, EUR 200k+ acceptable in non-refundable spend. — Malta MPRP. Grandparent eligibility is the structural advantage. Run the EUR 7,500 per adult dependent math but the family scope is unmatched in the EU programs.
Lifestyle passport not priority
Couple, 50s, want a Mediterranean property they will actually use, EU residency for mobility, no urgent passport timeline. — Greece. The property is the real purchase, the visa is the bonus. Conversion or Zone B route depending on location preference.
Dual base uae malta
Family wanting tax efficiency for the principal and EU access for the children, willing to operate dual residency structures. — UAE for tax base (principal), Malta MPRP for the wider family for EU access. Tax residency goes to UAE; MPRP held without triggering Maltese tax residency. Coordinate carefully on banking, schooling location, and where the spouse spends time.
FAQ
Can I hold residency in multiple of these programs?
Yes, legally. The constraint is tax residency: you can only be tax resident in one country at a time (or sometimes none, with careful structuring). Holding residency permits in multiple jurisdictions is permitted; tax residency follows the country where you spend the most time, have your permanent home and centre of vital interests. Common dual structures: UAE + Malta, UAE + Portugal, Greece + Italy.
Which program has the highest rejection rate?
Malta MPRP runs roughly 10% rejection rate on due diligence, mostly source of funds and adverse media checks. UAE has very low rejection rates if documentation is clean. Portugal, Greece and Italy have low rejection rates but Italy's Nulla Osta stage rejects materially incomplete files. Source of funds documentation is the universal point of failure across all programs.
Did Spain really close its Golden Visa?
Yes. Organic Law 1/2025 took effect 3 April 2025. No new applications. Existing holders are grandfathered and can renew under previous rules. If you were considering Spain as a sixth option, your live alternatives are these five.
Which has the strongest tax overlay?
For high foreign income (EUR 1M+), Italy's flat tax structurally wins via cap (EUR 200,000 covers unlimited foreign income). For mid-tier income (EUR 350k to EUR 1M), Greek Non-Dom often wins on flat fee plus low family add-on. For income that can be managed offshore cleanly, Malta remittance basis is the most flexible. UAE is structurally zero tax (no overlay needed) for non-US persons. Portugal IFICI is narrowly drawn and only applies to specific qualifying professions.
Which has the lightest physical presence requirement?
Portugal at 14 days per 2 year cycle for the visa itself is the lowest in Europe. Greece, Italy, Malta, and UAE have no minimum stay for status. All EU programs require actual residence for citizenship; UAE and Malta MPRP do not have a citizenship track via the program.
If I had to pick just one, where do I start?
Three questions: (1) Do you want an EU passport? If no, MPRP or UAE. If yes, Portugal, Greece or Italy. (2) Do you want real estate as the asset? If yes, Greece. If no, Portugal (fund) or Italy (startup, company, bonds). (3) What is your foreign income level? If above EUR 1M and you want a flat-tax overlay, Italy. If between EUR 350k and EUR 1M, Greek Non-Dom often wins. If you can stay offshore and have light EU presence, Malta remittance or UAE.
Are these programs going to survive the EU pressure?
Mixed picture. The EU has pushed against citizenship by investment (CBI) more aggressively than residency by investment (RBI). The 2025 ECJ ruling against Malta's MEIN scheme is the strongest signal yet that CBI is on borrowed time. RBI programs (Portugal, Greece, Italy, Malta MPRP) face general pressure but are not under the same imminent threat. Spain closed in 2025; Portugal eliminated its real estate route in 2023 and extended citizenship in April 2026. Direction is toward tighter, not abolition. Buy on the assumption that further reforms are likely over the holding period.
Sources
- — Portugal: Law 23/2007 (Foreigners Act); Law 56/2023 (Mais Habitação); Decreto-Lei 352/2024 (IFICI); Lei da Nacionalidade amendment April 2026.
- — Greece: Law 5100/2024 (zone-based Golden Visa pricing); Income Tax Code Article 5A (Non-Dom); Greek Citizenship Code (Law 3284/2004) as amended.
- — Italy: Decree-Law 161/2017 (Investor Visa); Articles 26-bis and 26-ter, Decree-Law 50/2017 (flat tax); Budget Law 2025 (Law 207/2024).
- — Malta: Subsidiary Legislation 217.26 (MPRP regulations); Legal Notice 146 of 2025; Income Tax Act remittance basis; Citizenship Act; ECJ judgment on Malta MEIN, 2025.
- — UAE: Federal Decree-Law No. 29 of 2021 on Entry and Residence; Federal Decree-Law No. 47 of 2022 on Corporate Tax; Cabinet Decision on Golden Visa property rules, February 2026.
- — EU: Recommendation C(2022) 2028 on residence by investment programmes; Organic Law 1/2025 closing Spain's Golden Visa.