Portugal’s D3 Visa for Investors vs. Spain’s Foreign Investment Law: Comparing Iberian Investment Programs – Minimum Amounts and Requirements

Portugal D3 Visa vs. Spain Investment Law: What Entrepreneurs Need to Know

Before we dive into the details, we need to clarify exactly what we’re comparing here. That’s more important than it might seem at first.

Portugal D3 Visa: Key Facts at a Glance

The Portugal D3 Visa is a temporary residence visa for entrepreneurs and self-employed professionals. It allows you to live and work in Portugal for up to one year, with an option to extend.

Here are the main points:

• Target group: Entrepreneurs, freelancers, and qualified self-employed professionals
• Duration of stay: 12 months, extendable for another 12 months
• Investment focus: Business activity or qualified employment in Portugal
• Family members: Can be included
• EU access: Travel within the EU, but work authorization only in Portugal

The key point: Unlike the former Golden Visa, this is not primarily about passive investments. You must actively pursue entrepreneurial activity.

Spain’s Ley de Inversión Extranjera: Main Points of the New Regulation

Spain’s Ley de Inversión Extranjera (Foreign Investment Law) is a different animal. It governs all foreign investments in Spain and has been revised several times in recent years.

Key aspects for entrepreneurs:

• Types of investment: Real estate, company shares, government bonds
• Minimum amounts: Vary depending on investment type (details below)
• Residence permit: Different categories based on investment amount
• Business activity: Not mandatory
• Tax status: Depends on time spent in Spain

The crucial difference: Here, you can gain residency by pure capital investment without having to work actively.

Why These Two Programs Matter Right Now

You might be wondering: Why focus on these two programs in particular?

The answer is pragmatic:

After the end of Portugal’s Golden Visa for real estate, many entrepreneurs are searching for alternatives on the Iberian Peninsula. Portugal and Spain provide a natural basis for comparison thanks to their geographic proximity, EU status, and similar lifestyle.

Plus, both countries have recently revised their programs. This means up-to-date information is rare, but all the more crucial for your decision.

Here’s an initial overview in table form:

This first overview already shows: these programs are designed with completely different goals in mind. That’s why it’s important we examine them closely.

Portugal D3 Visa Minimum Amounts and Requirements: The Complete Guide

Now let’s get specific. Let’s break down the Portugal D3 Visa step by step.

Financial Minimum Requirements for the D3 Visa

Here’s the first surprise: there’s no fixed minimum investment. Instead, you must prove you are financially able to carry out your proposed business activity.

In practice, this means:

• Living expenses: Proof of at least €760 per month for the main applicant
• Family members: Additional 50% for spouse, 30% per child
• Business capital: Sufficient funds for your planned business (project-dependent)
• Reserves: 6–12 months additional reserves are recommended

A practical example: You plan to start an online marketing business. With a spouse and one child, you’ll need around €1,368 per month for living costs. Add your business expenses—let’s say €2,000 monthly for office, software, and marketing. Plus six months’ reserve.

That totals: (€1,368 + €2,000) × 18 months = €60,624 as a safe ballpark figure.

Documentation and Proof Requirements

Heres where the pretenders are filtered out. Portuguese authorities are especially rigorous in documentation.

These documents are mandatory:

1. Business plan: Detailed description of your proposed activity
2. Proof of funds: Bank statements from the past 3–6 months
3. Qualification proof: Diplomas, certificates, work experience
4. Health insurance: Valid in Portugal or internationally
5. Police clearance certificate: From all countries of residence in the past 5 years
6. Proof of address: Rental contract or property deed in Portugal

The business plan is especially critical. It must show your project is realistic and beneficial to Portugal. That means: creating jobs, generating tax revenues, or promoting innovation.

Processing Times and Practical Steps

Here’s what you should budget timewise:

• Preparation: 2–3 months for gathering documents
• Initial application: 60–90 days processing time
• Requests for more info: Often another 30–60 days for clarifications
• Total timeline: Realistically 4–6 months from start to visa approval

My practical advice: Start at least 6 months before you plan to move. The authorities are thorough but not known for speed.

Another important point: the application must be submitted from abroad. In other words, you cannot already be living in Portugal and then apply for this visa later.

Spain’s Ley de Inversión Extranjera: Investment Options and Criteria in Detail

Now let’s switch gears. Spain’s approach is structured very differently.

Real Estate Investments Under the New Law

Real estate remains the classic route for foreign investors in Spain. But beware: the rules have changed.

The current minimum thresholds:

• Single property: At least €500,000 purchase price
• Multiple properties: Combined value of at least €500,000
• Commercial properties: Same minimum, but more flexible usage
• Renovation projects: Purchase price plus renovation must total €500,000

Here’s the interesting part: Unlike before, you can now mix properties. For example, you could buy three apartments at €170,000 each and still reach the minimum threshold.

This offers more flexibility for risk diversification.

Business Formation and Investment as a Route

The entrepreneurial route is often overlooked, even though it offers appealing options.

Your options:

1. New company: Spanish company with at least €500,000 capital
2. Shareholding: Acquisition of shares in existing Spanish companies
3. Job creation: Businesses creating at least 5 new jobs
4. Innovation: Projects of general interest (subject to discretion)

The job creation option is especially attractive. If you start or take over a company that creates at least five new jobs, you may be allowed to invest less than €500,000.

This is particularly relevant for IT entrepreneurs who want to set up a team in Spain.

Alternative Investment Forms in Spain

Less well known, but still interesting are these alternatives:

My honest assessment: The real estate route remains the most practical for most entrepreneurs. It’s transparent, predictable, and offers real value.

The others are more interesting for very wealthy investors who primarily want residency and aren’t focused on return on investment.

Tax Implications: Portugal vs. Spain for International Entrepreneurs

Now we get to the heart of the matter: What do these programs mean for your tax burden?

NHR Program Portugal and D3 Visa Combination

This is where things get really interesting. Portugal offers the NHR scheme (Non-Habitual Resident), which you can use alongside the D3 Visa.

The advantages at a glance:

• Foreign income: Often 0% tax in Portugal
• Certain professions: Only 20% tax on Portuguese-sourced income
• Pensions: Foreign pensions taxed at 10%
• Validity: 10 years

What this means in practice: If you mostly work with clients outside Portugal, you can often remain completely tax-free. The requirement is that these incomes are not taxable in Portugal, or have already been taxed in the source country.

A practical example: You run an online marketing business with clients in Germany and Switzerland. As long as this income doesn’t originate in Portugal, under the NHR programme, you pay 0% Portuguese tax.

Spanish Tax Advantages for Foreign Investors

Spain takes a different approach. There’s the so-called Beckham Regime for new tax residents.

The key facts:

• Applicability: Up to 6 years for new residents
• Tax rate: 24% flat rate on Spanish income up to €600,000
• Foreign income: Not taxable in Spain
• Condition: Not a Spanish tax resident in the past 10 years

This can be attractive if you’re generating significant income in Spain. On €600,000, you pay only €144,000 in tax instead of the higher standard progressive rates.

Double Taxation Agreements and EU Benefits

Both countries are EU members, which brings significant benefits:

1. Freedom of movement: Residence and business activities possible throughout the EU
2. Double taxation agreements: Extensive treaties with other EU countries
3. EU directives: Parent–subsidiary directive, interest–royalty directive
4. Planning certainty: EU law offers protection against arbitrary changes

Particularly relevant for internationally active entrepreneurs: you can, for example, set up a Portuguese holding company and use EU directives for tax-optimized dividends from other EU countries.

My tax-side assessment:

Portugal wins for international online businesses with its NHR program. Spain is more attractive if you generate high local income and want to benefit from the 24% flat tax.

Residency Pathways: From Temporary Visas to Permanent Residence Permits

Let’s take a look at what happens after the first few years—since most entrepreneurs are in it for the long term.

Portugal: From the D3 Visa to Permanent Residence

The Portuguese path is clearly structured:

1. Years 1–2: D3 Visa (1 year + 1-year extension)
2. Years 3–4: Temporary residence permit (2 years each)
3. From year 5: Eligible for permanent residency
4. From year 6: Application for Portuguese citizenship

Important requirements for the transition:

• Language skills: Basic Portuguese (level A2)
• Integration: Proof of societal integration
• Income: Continued financial means
• Time in country: At least 16 months in Portugal over 2 years

The standout point: Portugal allows citizenship after just 5 years of residence. That’s much faster than most other EU countries.

Spain: Long-Term Outlook Under the Investment Law

Spain has a different timeline:

1. Year 1: Investor visa (1 year, renewable)
2. Years 2–5: Renewals in 2-year increments
3. From year 5: Long-term residence permit
4. From year 10: Eligible for Spanish citizenship

Interesting: Spain’s required physical presence is more flexible. You need only enter the country once a year to keep your status. Perfect for frequent travelers.

EU Citizenship: Which Path Is Faster?

Portugal is the clear winner here:

If an EU passport is your long-term goal, Portugal clearly comes out ahead. Shaving five years off your wait time can be crucial, especially if you want to grow your business internationally.

But don’t forget: Spanish is a much more widely spoken global language than Portuguese. That’s worth factoring in as well.

Practical Decision Aid: Which Program Fits Your Profile?

Now let’s get hands-on. Here’s an honest decision aid from me.

Who Is the Portugal D3 Visa Especially Suitable For?

The Portugal D3 Visa is ideal if you:

• Are actively engaged in business and have a concrete business plan
• Work internationally online and can benefit from the NHR program
• Want to gain EU citizenship quickly (5 rather than 10 years)
• Prefer manageable investment amounts (no €500,000 minimum)
• Appreciate a relaxed lifestyle (Portugal is known for work–life balance)

Typical profiles:

Sarah, 34, online marketing consultant: “I consult mainly German SMEs remotely. The D3 Visa allows me to live in Lisbon while my income is tax-free under NHR.”

Michael, 41, software developer: “My SaaS business is fully online. Portugal offers me a great mix of low taxes, EU access, and an amazing lifestyle.”

When Is Spain’s Investment Law the Better Choice?

Spain’s program is a better fit if you:

• Have capital to invest and prefer a passive investment route
• See property as an asset class (more liquid market than Portugal)
• Travel frequently and need flexible residency rules
• Speak or want to learn Spanish (bigger market)
• Already have business connections in Latin America

Typical profiles:

Thomas, 48, management consultant: “I advise multinational corporations and travel 200 days a year. Spain’s flexible residency rules work perfectly for my lifestyle.”

Elena, 52, investor: “I wanted a solid property investment with residency rights. Barcelona offers both: good returns and access to the EU market.”

Combination Strategies: Using Both Programs in Parallel

This is where things get interesting: In theory, you can pursue both routes in parallel.

Possible scenarios:

1. Test phase: D3 Visa Portugal for 2 years, then switch to Spain’s investment program
2. Diversification: Business in Portugal, property in Spain
3. Family strategy: Spouse in Portugal (NHR), you in Spain (Beckham Regime)
4. Tax optimization: Switch between countries depending on business developments

But caution: This can get complicated quickly. Especially with tax residence, you risk falling between the cracks.

My recommendation: Focus on one country first and only switch if your circumstances drastically change.

Common Mistakes and How to Avoid Them

Let me show you the most expensive mistakes I see repeatedly in practice.

Typical Pitfalls with the Portugal D3 Visa

Mistake 1: Vague Business Plan

Many applicants underestimate the importance of a detailed business plan. “I do online marketing” isn’t enough. You need to clearly set out:

• What services do you offer?
• Who are your target clients?
• How will you generate revenue?
• What benefit does Portugal get?

Mistake 2: Incorrect Financial Planning

Living expenses are often underestimated. Lisbon has become much more expensive in recent years. Budget a minimum of €1,500 per month for a single person—up to €2,500 in premium areas.

Mistake 3: Ignoring Language Requirements

Even if English suffices initially, you’ll need Portuguese skills for renewal at the latest. Start learning early.

Spain Investment Traps from Real Experience

Mistake 1: Buying Property Without Due Diligence

The most common error: Buying a property just to meet the €500,000 threshold without checking location, condition, or yield. That’s an expensive lesson.

Always check:

• Legal status (building permits, mortgages)
• Market value and growth potential
• Possible rental yield
• Exit possibilities

Mistake 2: Overlooking Tax Pitfalls

Many forget that property income in Spain is taxed at standard rates. Without the Beckham regime, this can quickly be 20–25%. Factor this into your return calculations.

Mistake 3: Miscalculating Residency Periods

Spain’s rules are flexible, but don’t neglect your status. A single year without entering the country can lead to loss of residence rights.

My Tips for a Smooth Process

Having seen it all, here are my most important recommendations:

1. Start early: Plan at least 8–12 months for the entire process
2. Involve local experts: Lawyers and tax advisors on the ground are invaluable
3. Do a trial run: Spend a few months in the country before committing
4. Get early tax advice: Clarify tax issues before you move—not after
5. Have a Plan B: Both programs can change—be flexible

The most important thing: Dont rush. Both programs have existed for years and will likely be available in 2025. A well-considered decision is far more important than a fast one.

Frequently Asked Questions about Portugal D3 Visa and Spain’s Investment Law