Golden Residence de Portugal vs. Visado de Inversor en Spanish: La comparación honesta para inversores alemanes en 2025

Let me start with an uncomfortable truth:

Most German investors who approach me about Iberian residency programs have completely misguided expectations. They’re mainly focused on low taxes. That misses the point.

Why?

Because both Portugal’s Golden Residence and Spain’s investor visas are primarily residency programs—not tax optimization tools. In other words: they solve different problems than you might expect.

In recent years, I’ve accompanied dozens of cases. I keep encountering the same misconceptions. Thats why today Im taking you on a realistic journey through both programs.

No sales talk. No false promises.

Instead, you get the unfiltered truth about minimum investments, hidden costs, and tax realities. Plus: a clear assessment of which program fits which investor type.

Ready for straight talk?

Portugal Golden Residence: The Facts Laid Bare

Let’s start with Portugal, as this is where the biggest myths circulate.

The official name is Programa de Autorização de Residência para Atividade de Investimento (ARI). This program was fundamentally changed in 2023. Many advisors conveniently ignore these changes.

Minimum Investments and Options after the 2023 Reform

Here are the latest minimum investments that actually work:

Most important first: Direct real estate investments have been stopped since October 2023. Period.

If someone is still offering you apartments in Lisbon or Porto for the Golden Visa, they are either misinformed or untrustworthy. Most of my clients therefore choose real estate funds.

But proceed with caution:

These funds are often non-transparent in structure. You as an investor also have much less control than with direct real estate. Expect annual management fees between 1.5% and 2.5%.

Requirements and Application Procedure: What Nobody Mentions

The formal hurdles are manageable. Yet applications regularly fail due to details:

• Clean criminal record: From Germany AND every country you’ve lived in for over a year
• Health insurance: Must be valid in Portugal—German public health insurance doesn’t suffice
• Proof of available funds: In addition to your investment, at least 50,000 EUR in liquid assets
• Proof of stay: At least 7 days per year physically present in Portugal—strictly monitored

The application process currently takes 12–18 months due to staff shortages at Portuguese immigration authority SEF. Plan accordingly.

A common stumbling block: translations and apostilles. Every German document must be officially translated into Portuguese. Cost: about 3,000–5,000 EUR extra.

Tax Aspects for Germans: The Unvarnished Truth

This is where it gets interesting—and complicated.

Portugal offers the Non-Habitual Resident (NHR) regime. This means a 20% flat tax for up to 10 years on certain types of income. Sounds tempting, right?

The reality is different:

As a German taxpayer, you initially remain tax-resident in Germany. This only changes with real emigration—giving up your German residence and center of life.

Additionally: The double taxation treaty between Germany and Portugal prevents double taxation, but also creates complexity around income attribution.

My honest assessment?

The Portuguese Golden Visa is primarily a residence program with the option of EU citizenship after five years. The tax benefits only take effect if you truly relocate your primary residence.

Spain’s Investor Visa: What You Really Need to Know

Spain makes things more complicated. Why?

Because there’s not just one investor visa, but several different programs. Each with its own rules, minimum investments, and pitfalls.

The Different Visa Categories at a Glance

Let me bring some structure to the chaos:

The reality: 95% of my clients choose the real estate investor visa. Simply because its the most transparent.

But be careful:

Unlike the Portuguese program, you actually have to buy and keep the property. If you sell before receiving permanent residency, you lose the status.

Investment Conditions in Detail: The Hidden Pitfalls

The Spanish real estate investor visa contains traps even experienced lawyers overlook:

• No mortgage allowed: The 500,000 EUR must be fully paid up front—no loans allowed
• New properties preferred: Resale properties are allowed, but for new builds the process is simpler
• No rental at first: In the first two years, you cannot commercially rent out the property
• Regional differences: Madrid and Barcelona have tougher review procedures than other regions

One practical tip from my experience:

Many buy in Valencia or Alicante. Value for money is better there and the authorities are more cooperative than in metropolitan areas.

Don’t underestimate the ancillary costs. Expect 10–15% extra on top of the purchase price for notary fees, property transfer taxes, and lawyers fees.

Legal Framework: What Changed in 2024

Spain tightened the requirements in 2024. The German media barely covered it:

First: stricter due diligence regarding the source of funds. You must prove exactly where your investment capital comes from. Money laundering controls are serious.

Second: higher residency requirements. You must enter Spain at least once a year and have this documented.

Third: stricter health insurance requirements. Insurance must be comprehensive and recognized in Spain. German international health insurance is not enough.

The application process is much faster than in Portugal. On average, 4–6 months from application to decision.

Direct Comparison: Portugal vs. Spain for German Investors

Now we’re getting concrete.

After three years of closely accompanying both programs, I can tell you: The differences are bigger than most advisors admit.

Investment Amounts Compared: It’s More Than Just Numbers

At first glance, Portugal seems cheaper. 500,000 EUR for real estate funds versus 500,000 EUR for Spanish property. True?

Not really.

On closer inspection, total costs are higher in Portugal:

So: Both programs are virtually equal financially.

The crucial difference?

In Spain, you own an actual property. In Portugal, you own fund units, whose value can fluctuate and which you do not control directly.

Time Commitment and Bureaucratic Burden: A Critical Factor

Here the differences are clear:

Portugal:

• Application process: 12–18 months
• Stay requirement: 7 days per year
• Renewals: Every 2 years, relatively straightforward
• Permanent residence: Possible after 5 years

Spain:

• Application process: 4–6 months
• Stay requirement: Entry at least once per year
• Renewals: Annually at first, then every 2 years
• Permanent residence: After 5 years, with language certificate

For busy entrepreneurs, the Spanish system is often more practical. Faster processing, lower stay requirements in the early years.

However: The language certificate for permanent residence is a serious hurdle. Minimum requirement is A2, B1 is recommended.

Long-Term Perspective: EU Citizenship and Exit Strategies

This is the biggest strategic difference:

Portugal offers:

• EU citizenship after 5 years
• Basic knowledge of Portuguese is enough (A2 level)
• Dual citizenship possible
• No minimum stay needed for citizenship

Spain requires:

• EU citizenship only after 10 years
• Advanced Spanish knowledge (B2 level)
• Dual citizenship only with a few countries
• Proof of integration and regular residence required

For German investors seeking a second EU citizenship in the long term, Portugal is much more attractive.

Tax Implications: What Your Previous Advisor Didn’t Tell You

Now we get to the heart of the matter.

Most tax advisers don’t understand these programs. Why? Because they primarily know German tax law but overlook the international connections.

Double Taxation Treaties: The Key to Understanding

Germany has double taxation agreements (DTAs) with both countries. These determine where which income is taxed.

The basic rule is:

As long as you remain tax resident in Germany, nothing changes. The investor visa alone does not make you a tax resident in Portugal or Spain.

In practice:

• German income: Remains taxable in Germany
• International income: Is taxed according to German rules
• Capital gains: Still subject to Germany’s capital gains tax
• Real estate income: Taxed in the property’s location (Portugal/Spain)

Only if you really move your center of life does this change.

German Exit Tax: The 10-Million-Euro Trap

This can get very expensive if you’re not careful.

When relocating from Germany with shareholdings over 1%, exit tax applies. This means: hidden reserves are taxed as if you had sold everything.

A real-world example:

A client owned GmbH shares with a book value of 500,000 EUR but a market value of 3 million EUR. Upon moving to Portugal, 2.5 million EUR would be deemed taxable profit—about 650,000 EUR in taxes owed.

The solution: Apply for deferred payment and smart structuring before relocating.

But caution with Spain:

Spain is particularly aggressive in auditing newcomers with significant wealth. The so-called “Beckham Law” can help—but is time-limited and subject to strict conditions.

Optimal Structuring: The Path to Legal Tax Optimization

Here’s the practical part.

If you want to use one of these programs for genuine tax optimization, you need an integrated strategy:

1. Plan your timing: Move at the beginning of the year for a full tax period in the new country
2. Consider holding structures: Often, a Cypriot or Maltese holding company is tax-advantaged
3. Property timing: Sell German properties ideally after you’ve relocated
4. Liquidity planning: Ensure enough liquidity for the investment and living expenses

My recommendation: Start your structuring at least two years before your planned move. Waiting longer can make it expensive or impossible.

My Honest Recommendation: Which Program Fits Whom?

After all we’ve discussed, let’s get to the crucial question: Which program is right for you?

The answer depends on your goals. And that’s where most advice remains superficial.

Who Should Choose Portugal

The Portuguese Golden Visa suits you if you:

• Value flexibility: Minimal stay requirements (7 days/year)
• Seek EU citizenship: Possible after just 5 years
• Don’t want direct real estate investment: Prefer a fund structure
• Plan tax optimization: NHR regime is attractive upon true emigration
• Language is not an issue: Portuguese is manageable for Germans

Typical profile: digital nomad or location-independent entrepreneur looking to secure options for themselves and their family, without being geographically tied down.

A concrete example:

Thomas (38), a software entrepreneur from Munich, already spends 6 months a year between Bali and Dubai. The Portuguese Golden Visa gives him EU flexibility and a clear path to a second citizenship—without giving up his nomadic lifestyle.

When Spain Makes Sense

The Spanish investor visa is your choice if you:

• Prefer real property ownership: Direct control over your investment
• Appreciate fast processing: 4–6 months instead of 12–18 in Portugal
• Want to live (sometimes) in Spain: The country and culture appeal to you
• Expect rental yield: Commercial rentals allowed after two years
• No rush for citizenship: 10 years is acceptable to you

Typical profile: established entrepreneur or investor viewing foreign property as part of their portfolio and willing to spend time regularly in Spain.

A practical example:

Elena (45), a management consultant from Hamburg, buys a villa in Valencia for 600,000 EUR. She uses it for 6 weeks a year, rents it out the rest, and earns a 4–5% yield. Plus: A path to EU residence for her teenage children.

Avoiding the Most Common Mistakes: My Conclusion

To wrap up, my key learnings from three years of intensive consulting:

Mistake #1: Considering programs in isolation
Both Portugal and Spain are part of a broader strategy. Think at least 10 years ahead.

Mistake #2: Overestimating tax benefits
An investor visa alone doesn’t save you taxes. Tax advantages only apply after real emigration.

Mistake #3: Underestimating additional costs
Budget 15–20% more on top of the minimum investment for additional costs, lawyers, and ongoing fees.

Mistake #4: Ignoring language requirements
Without basic knowledge of the local language, any long-term plan becomes difficult.

Mistake #5: Neglecting exit strategy
What happens when you want to end the investment after 5–7 years? Plan this from the outset.

My honest advice?

Don’t choose between Portugal and Spain. Choose between “staying as you are” and “creating international options.”

Both programs are tools for more flexibility, security, and long-term options. But they are not a cure-all for high German taxes.

If youve understood that, we can talk about concrete structuring.

Your RMS

FAQ: Portugal vs Spain Investor Programs