Table of Contents
- Portugal D3 Visa vs. Spains Investment Law: What Entrepreneurs Need to Know
- Portugal D3 Visa Minimum Amounts and Requirements: The Complete Guide
- Spains Ley de Inversión Extranjera: Investment Options and Criteria in Detail
- Tax Implications: Portugal vs. Spain for International Entrepreneurs
- Residency Pathways: From Temporary Visas to Permanent Residency
- Practical Decision Helper: Which Program Fits Your Profile?
- Common Mistakes and How to Avoid Them
- Frequently Asked Questions about Portugal D3 Visa and Spains Investment Law
A few weeks ago, I received this message from an entrepreneur in Munich:
Richard, Im hearing everywhere about the end of the Golden Visa in Portugal. Now supposedly the D3 visa is the alternative. At the same time, everyone is talking about Spains new investment laws. Which route makes more sense for me as a digital entrepreneur?
And heres the issue:
Most information on these two Iberian investment programs is superficial or outdated. Worse: Many advisors mix up the programs or explain them so complicatedly that in the end, no one knows what’s really going on.
That annoys me.
Thats why today Ill clear up the most important misunderstandings. I’ll explain both programs so clearly that you’ll be able to make a well-informed decision.
Why am I the right person for this conversation? Because for years I have been structuring international tax setups and have taken a close look at both countries. Plus, I experience every day the practical challenges that arise when theory meets reality.
Ready for an honest comparison without sales talk?
Then let’s go through which program really suits your life and your goals.
Yours, RMS
Portugal D3 Visa vs. Spains Investment Law: What Entrepreneurs Need to Know
Before we dive into the details, we first need to clarify what were actually comparing here. This is more important than it might seem at first glance.
Portugal D3 Visa: Key Facts at a Glance
The Portugal D3 Visa is a temporary residence visa for entrepreneurs and freelancers. It allows you to live and work in Portugal for up to one year, with the possibility of renewal.
Here are the main points:
- Target group: Entrepreneurs, freelancers, and skilled self-employed
- Duration of stay: 12 months, renewable for another 12 months
- Investment focus: Business operations or qualified work in Portugal
- Family members: Can be included
- EU access: Travel within the EU, but work only in Portugal
The most important thing: Unlike the former Golden Visa, this is not primarily about passive investments. You must actively run a business.
Spains Ley de Inversión Extranjera: Key Points of the New Law
Spains Ley de Inversión Extranjera (Law for Foreign Investments) is a different animal. It essentially regulates all foreign investments in Spain and has been revised multiple times in recent years.
The relevant points for entrepreneurs:
- Types of investment: Real estate, shareholdings, government bonds
- Minimum amounts: Vary by investment type (more on this shortly)
- Residence permits: Various categories depending on the investment size
- Business activity: Not strictly required
- Tax status: Depends on duration of stay
The crucial difference: Here you can obtain residence status purely through capital investment, without needing to work actively.
Why These Two Programs Are Especially Relevant Now
You might ask: Why focus on exactly these two programs?
The answer is pragmatic:
After the end of Portugal’s Golden Visa for real estate, many entrepreneurs are looking for alternatives on the Iberian Peninsula. Portugal and Spain are natural points of comparison thanks to their geographical proximity, EU status, and similar living conditions.
Additionally, both countries have reformed their programs in recent years. This means: Current information is rare, but all the more crucial for your decision.
Here’s an initial orientation in table form:
Criterion | Portugal D3 Visa | Spains Investment Law |
---|---|---|
Minimum investment | No fixed amount | From €500,000 (real estate) |
Activity required | Yes, business operations | No, passive investment possible |
Duration of stay | 1+1 year | Indefinitely renewable |
EU citizenship possible | After 5 years | After 10 years |
This first overview already shows: The programs are designed very differently. Thats why it’s so important to analyze them in detail.
Portugal D3 Visa Minimum Amounts and Requirements: The Complete Guide
Now let’s get concrete. Let’s go through 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 amount. Instead, you must show that you’re financially able to carry out your business plan.
In practice, this means:
- Living costs: 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-based)
- Reserves: 6–12 months of extra reserves recommended
A practical example: You’re planning to set up an online marketing company. With a spouse and one child, you’ll need about €1,368 per month for living costs. Add your business costs—let’s say €2,000 a month for office, software, and marketing. Plus six months of reserves.
That’s: (1,368 + 2,000) × 18 months = €60,624 as a safe target value.
Documentation and Proof Obligations
This is where things get serious. The Portuguese authorities are meticulous with documentation.
You will definitely need these documents:
- Business plan: Detailed description of your planned activity
- Proof of funds: Bank statements from the last 3–6 months
- Proof of qualifications: Diplomas, certificates, work experience
- Health insurance: Valid in Portugal or international
- Criminal record certificate: From every country of the last 5 years
- Proof of address: Rental contract or ownership proof in Portugal
The business plan is especially critical. It must show that your venture is realistic and beneficial for Portugal. That means: Creating jobs, generating taxes, or fostering innovation.
Processing Times and Practical Procedures
Plan for the following timeline:
- Preparation: 2–3 months to gather documents
- Initial application: 60–90 days processing time
- Follow-up: Often another 30–60 days for additional questions
- Total duration: Realistically 4–6 months from start to visa
My practical tip: Start at least 6 months before your planned move. The authorities are thorough, but not fast.
One more important point: You must apply from abroad. That means you cannot already live in Portugal and then apply for the visa retroactively.
Spains Ley de Inversión Extranjera: Investment Options and Criteria in Detail
Let’s look at the other side. Spain’s approach is structured completely differently.
Real Estate Investments under the New Law
Real estate is still the classic route for foreign investors in Spain. But watch out: The rules have changed.
The current minimum amounts:
- Single property: At least €500,000 purchase price
- Multiple properties: Combined value at least €500,000
- Commercial property: Same minimum threshold, but more flexible use
- Renovation projects: Purchase price plus renovation costs must reach €500,000
This gets interesting: Unlike before, it is now possible to combine properties. You could buy three apartments for €170,000 each and still reach the minimum.
This offers more flexibility in diversifying risk.
Company Formation and Shareholding as an Investment Route
The entrepreneurial route is often overlooked, although it offers attractive opportunities.
Your options:
- New formation: Spanish company with at least €500,000 capital
- Acquisition of shares: Buying into existing Spanish companies
- Job creation: Company with at least 5 new jobs
- Innovation: Projects of general interest (subject to approval)
The job creation option is particularly interesting: If you found or take over a company that creates at least five new jobs, you can go below the €500,000 minimum investment.
This is especially relevant for IT entrepreneurs looking to build a team in Spain.
Alternative Investment Forms in Spain
Less well known but interesting alternatives include:
Type of investment | Minimum amount | Special features |
---|---|---|
Government bonds | €2,000,000 | Very secure, but high amount |
Bank deposits | €1,000,000 | 3-year holding period required |
Investment funds | €1,000,000 | In Spanish or EU funds |
Startup investments | €500,000 | Riskier, but flexible |
My honest opinion: For most entrepreneurs, real estate remains the most practical route. It is transparent, predictable, and offers real value.
The other options are mostly of interest to very wealthy investors seeking residency status and less concerned with returns.
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 gets really interesting. Portugal offers the NHR (Non-Habitual Resident) program, 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 rate on Portuguese income
- Pensions: Foreign pensions taxed at 10%
- Validity: For 10 years
Practically speaking: If you work mainly with clients outside Portugal, you can often remain completely tax-free. The prerequisite is that this income cannot be taxed in Portugal, or is already taxed at source.
A practical example: You run an online marketing company with clients in Germany and Switzerland. As long as this income doesn’t arise in Portugal, you pay 0% Portuguese tax under the NHR program.
Spanish Tax Benefits for Foreign Investors
Spain takes a different approach. Here theres the so-called Beckham regime for new tax residents.
Key points:
- Application: Up to 6 years for new residents
- Tax rate: 24% flat tax on Spanish income up to €600,000
- Foreign income: Not taxable in Spain
- Precondition: Not taxable in Spain in the past 10 years
This can be attractive if you have high Spanish income. With €600,000 earnings, you pay only €144,000 in tax instead of much higher normal rates.
Double Taxation Agreements and EU Advantages
Both countries are EU members, which brings significant benefits:
- Free movement: Residence and business activity possible throughout the EU
- Double taxation agreements: Extensive network with other EU countries
- EU directives: Parent-Subsidiary Directive, Interest and Royalties Directive
- Planning security: EU law protects against arbitrary changes
This is especially relevant for internationally active entrepreneurs. For example, you can set up a Portuguese holding company and receive optimized dividends from other EU countries thanks to EU directives.
My view on the tax side:
Portugal wins for international online businesses thanks to the NHR program. Spain is more attractive if you generate high local income and can benefit from the 24% flat tax.
Residency Pathways: From Temporary Visas to Permanent Residency
Lets see what happens after the early years. Most entrepreneurs are thinking long term.
Portugal: From D3 Visa to Permanent Residency
The Portuguese route is clearly structured:
- Years 1–2: D3 Visa (1+1 year renewal)
- Years 3–4: Temporary residence permit (each 2 years)
- From year 5: Permanent residency possible
- From year 6: Application for Portuguese citizenship
Important prerequisites for the transition:
- Language skills: Basic Portuguese (A2 level)
- Integration: Proof of social integration
- Income: Still sufficient financial means
- Time spent in country: At least 16 months in Portugal within 2 years
The key detail: Portugal allows citizenship after just 5 years of residency. That’s much quicker than in most other EU countries.
Spain: Long-Term Perspectives under the Ley de Inversión
Spain follows a different timeline:
- Year 1: Investor visa (1 year, renewable)
- Years 2–5: Renewals every 2 years
- From year 5: Long-term residence permit
- From year 10: Spanish citizenship possible
Interesting: The required residency periods are more flexible. You only need to enter Spain once per year to maintain your status. That’s handy for frequent travelers.
EU Citizenship: Which Path Is Faster?
Portugal is clearly ahead here:
Country | Minimum stay | Language requirement | Other criteria |
---|---|---|---|
Portugal | 5 years | A2 Portuguese | Integration, clean criminal record |
Spain | 10 years | A2 Spanish + DELE/CCSE | Integration, constitution test |
If EU citizenship is your long-term goal, Portugal is the clear choice. Five fewer years waiting can be crucial—especially if youre scaling your business internationally.
But: Spanish is a global language and much more widely useful than Portuguese. You should factor that into your decision.
Practical Decision Helper: Which Program Fits Your Profile?
Time to get practical. Let me give you a straightforward helper.
Who Is the Portugal D3 Visa Especially Suited For?
The Portugal D3 Visa is ideal if you:
- Are actively entrepreneurial and have a specific business plan
- Work internationally online and can benefit from the NHR program
- Seek quick EU citizenship (5 years instead of 10)
- Prefer manageable investments (no €500,000 minimum)
- Value 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 lets me live in Lisbon while my income remains tax free under NHR.
Michael, 41, Software Developer: My SaaS business is fully remote. Portugal gives me the perfect mix of low taxes, EU access and a great lifestyle.
When Is Spains Investment Law the Better Choice?
Spain’s program fits you better if you:
- Have capital to invest and prefer a passive investment route
- Prefer real estate as an asset (more liquid market than Portugal)
- Travel frequently and need flexible residency periods
- Speak or want to learn Spanish (larger market)
- Already have business links with Latin America
Typical profiles:
Thomas, 48, Management Consultant: I consult multinational corporations and travel 200 days a year. Spain’s flexible residency rules are a perfect fit for my lifestyle.
Elena, 52, Investor: I was looking for a solid real estate investment plus residency. Barcelona offers both: good returns and access to the EU market.
Combination Strategies: Using Both Programs in Parallel
Here’s where it gets interesting: In theory, you can pursue both routes in parallel.
Possible scenarios:
- Test phase: Portugal D3 Visa for 2 years, then switch to Spain investment
- Diversification: Business in Portugal, property in Spain
- Family strategy: Spouse in Portugal (NHR), you in Spain (Beckham regime)
- Tax optimization: Switching between countries as your business develops
But beware: This can quickly get complex, especially around tax residency. Don’t get caught between two stools.
My recommendation: Focus on one country first and only switch if your circumstances fundamentally change.
Common Mistakes and How to Avoid Them
Let me show you the costliest mistakes I see again and again in practice.
Typical Pitfalls with the Portugal D3 Visa
Mistake 1: Unclear business plan
Many applicants underestimate the importance of a detailed business plan. I do online marketing is not enough. You must clearly explain:
- What services do you offer?
- Who are your target customers?
- How do you generate revenue?
- What benefit does Portugal receive?
Mistake 2: Incorrect financial planning
Living costs are often underestimated. Lisbon has become noticeably more expensive in recent years. Plan at least €1,500 a month for one person—€2,500 in better areas.
Mistake 3: Ignoring language requirements
Even though English is enough at first, you’ll need Portuguese for renewals. Start learning early.
Spain Investment Pitfalls from Practice
Mistake 1: Buying real estate without due diligence
The most common error: Buying property just to meet the €500,000 threshold, without checking location, condition, or returns. That’s expensive tuition.
Always review:
- Legal situation (building rights, mortgages)
- Market value and development potential
- Possible rental income
- Exit strategies
Mistake 2: Overlooking tax traps
Many forget that real estate income is taxed normally in Spain. Without the Beckham regime, that can quickly be 20–25%. Factor this into your return expectations.
Mistake 3: Miscalculating residency requirements
Despite Spain’s flexible rules, don’t neglect your status. A year without an entry can mean losing your residence permit.
My Recommendations for a Smooth Process
Based on what I’ve seen, here are my key tips:
- Start early: Allow at least 8–12 months for the whole process
- Involve local experts: On-the-ground lawyers and tax advisors are invaluable
- Do a trial run: Spend a few months in the country before deciding
- Get tax advice early stage: Clarify tax issues before moving, not after
- Have a Plan B: Both programs can change—be flexible
The most important thing: Don’t rush. Both programs have been available for years and will also be available in 2025. A well-thought-out decision is more important than a quick one.
Frequently Asked Questions about Portugal D3 Visa and Spains Investment Law
Can I apply for the Portugal D3 Visa if I already live in Portugal?
No, the D3 visa must be applied for from abroad. You cannot already be in Portugal as a tourist and then apply for the visa retroactively. The application is made at the Portuguese consulate in your country of residence.
How much does the Spanish investment program cost in addition to the minimum investment?
In addition to the €500,000 investment, expect an extra 3–5% in costs: legal fees (€5,000–15,000), property purchase taxes (6–11% depending on the region), visa fees (around €5,000), and ongoing administration costs of about €2,000 per year.
What are the residency requirements for Portugal NHR?
For the NHR program, you must spend more than 183 days a year in Portugal or have your main residence there. The D3 visa requires similar residency—at least 16 months in two years for renewals.
Can I sell the Spanish property after receiving the residence permit?
In principle yes, but you must maintain the investment for as long as your residency status depends on it. An early sale can result in the loss of your permit. Only with permanent residence after 5 years are you more flexible.
What language tests are required for both programs?
Portugal requires A2 Portuguese for renewals after the third year. Spain requires A2 Spanish plus DELE and CCSE exams for citizenship after 10 years. For the initial visas, no language knowledge is required.
Are family members included in both programs?
Yes, both programs allow inclusion of spouses and minor children. In Portugal, this increases the minimum financial requirements by 50% for a partner and 30% per child. In Spain, additional costs are minimal.
How do the tax advantages differ between NHR and the Beckham regime?
Portugal NHR is better for international online income (often 0% tax) while Spain’s Beckham regime is attractive for high local earnings (24% flat tax up to €600,000). Which is better depends on your business model.
Can I switch between the programs?
A switch is theoretically possible but complex. You would need to give up your status in one country and apply from scratch in the other. Tax transition rules also must be considered. A carefully considered first decision is more important than flexibility.
Which industries are particularly suitable for the Portugal D3 Visa?
Especially successful are IT services, online marketing, consulting, e-commerce, and creative services. What matters is that you bring innovation to Portugal or serve international clients—the authorities see this positively.
What happens if the laws change?
Both countries grant grandfathering for already issued residency permits. Changes usually only affect new applicants. Still, remain flexible and keep alternative scenarios in mind. EU law provides further protection against arbitrary changes.