Planning the Exit from a Golden Visa Programme: Selling the Investment, Citizenship, and Tax

A generation of investors who acquired European golden visas from 2015 onwards — many of them UK nationals seeking an EU base before or after Brexit, Chinese and Middle Eastern investors seeking European residency, and wealth managers building diversified real estate portfolios — are now approaching the five- to seven-year horizon at which citizenship eligibility arises, or at which the investment requirement changes.

The questions these investors are now asking are consistent:

• Can I sell the investment now? Or must I hold it until citizenship is granted?
• Once I have citizenship, can I sell freely?
• Is the citizenship secure if I sell — or does selling create a risk that citizenship could be challenged?
• What are the tax consequences of the sale, and in which jurisdiction?

This guide addresses these questions for the two principal remaining European golden visa programmes: Portugal and Greece.

Portugal: The Fund Route

Portugal closed its property investment route for new applicants in October 2023, replacing it with fund and venture capital investment routes. Existing property-route investors (those who had committed before the closure) were grandfathered under the prior rules.

When Can You Exit the Investment?

Property route (legacy investors): the property investment must be maintained until the application for permanent residency (PR) or citizenship is approved. There is no fixed "hold then sell" date — the requirement is that the investment is maintained throughout the residency permit validity, which runs in five-year cycles. If the property is sold before PR or citizenship is obtained, the basis for the golden visa is removed, the permit lapses, and the residency pathway ends.

Once PR is obtained, the investment requirement no longer applies to the PR status itself. Similarly, once citizenship is granted, the citizenship is independent of the investment — the investment can be sold freely.

Fund route (new investors): fund investments typically have their own minimum holding periods specified in the fund documentation, usually five to seven years — by design aligning with the golden visa qualifying period. The fund structure generally does not allow early exit; investors should review the fund's liquidity and redemption terms carefully before committing.

The practical timeline:

• Years 1 onward: investment must be maintained; minimum presence in Portugal (currently around 7 days per year for the renewal)
• Year 5: eligibility for permanent residency application (PR requires 5 years of valid residency permits — this 5-year PR threshold was not changed by the 2026 Nationality Law); investment must still be maintained when PR application is made
• PR granted: investment can theoretically be released; consult legal advice on timing relative to the citizenship application
• Citizenship: under Portugal's 2026 Nationality Law (in force from May 2026), naturalisation now requires 10 years of legal residency for most non-EU applicants (7 years for EU/CPLP nationals), up from the previous 5 years; the application requires passing a Portuguese language test (A2 level) and demonstrating ties to Portugal. Investors already in the pipeline should confirm with Portuguese counsel whether any transitional provision preserves a shorter period for them
• Citizenship granted: fully independent of any investment holding

The Language Test

Portugal's citizenship by naturalisation requires passing a basic Portuguese language test at A2 level (elementary). For investors who have held a golden visa primarily as a travel and planning asset without spending significant time in Portugal, this can be an overlooked obstacle. Language preparation should begin well before the citizenship application — not in the weeks before the test.

After Citizenship: The Investment Is Free

Once Portuguese citizenship is granted, it is constitutionally protected. The Portuguese state cannot revoke citizenship because the investment was subsequently sold. The citizenship was earned by meeting the programme requirements during the qualifying period; it does not remain conditional on investment maintenance after the fact.

Greece: Property Investment and the Citizenship Pathway

Greece's golden visa programme has been one of the highest-volume in Europe, driven by accessible investment thresholds (€250,000 in most areas, though raised to €800,000 in prime areas from July 2023 with transitional provisions).

When Can You Exit the Greek Investment?

Unlike Portugal, Greece is more explicit: the qualifying property investment must be maintained throughout the period during which the golden visa residency status is relied upon. If the property is sold while the golden visa is active and the individual is relying on it for their right of residence, that right of residence ends.

The practical implication: a golden visa holder who sells the qualifying property before citizenship is granted loses the residency basis — and with it the pathway to citizenship.

After citizenship: Greek citizenship, once granted, is not conditional on any investment holding. Greece does not revoke citizenship because the property was subsequently sold. The citizenship is entirely independent post-grant.

The citizenship timeline in Greece is longer than Portugal's:

• Year 1-5: golden visa residency; investment must be maintained
• Year 7: first citizenship eligibility (Greece requires 7 years of legal residency, including sufficient actual residence — the "minimum presence" requirement has historically been relatively flexible for golden visa holders but requires time actually spent in Greece to satisfy the naturalization requirements)
• Language: Greek language is required at B1 level for naturalization — a more demanding standard than Portugal's A2 requirement

Refinancing: A Useful Intermediate Option

An investor who wants to release equity from the Greek golden visa property before citizenship can, in many cases, refinance the property (take a mortgage against it) without selling it. The refinancing does not break the golden visa requirement — the property is still owned by the investor. This allows the equity release the investor wants while maintaining the investment and the residency basis.

The refinancing approach requires Greek bank financing (or international private banking with Greek real estate security), which is more complex than simply selling, but it is a useful intermediate step for investors with high-value properties and liquidity needs.

Tax on Exit: The Disposal

Selling Portuguese Property

Portuguese CGT for residents: residents of Portugal include 50% of the gain in their taxable income, subject to progressive income tax rates (which reach 48% at the top rate). Indexation relief applies for properties held over two years, reducing the taxable gain.

Portuguese CGT for non-residents: since January 2023, the former flat 28% non-resident rate on property gains no longer applies. Non-residents are now taxed on the same basis as residents — only 50% of the net gain (consideration less acquisition cost, less qualifying improvements, less transaction costs) is brought into charge, with progressive income tax rates (reaching 48%, plus a solidarity surcharge at the highest income levels) applied by reference to the seller's worldwide income. The exact rate therefore depends on the individual's overall income for the year.

VAT reclaim considerations: if VAT was reclaimed on the original property purchase (possible for certain commercial or investment properties), a partial recapture may arise on sale within the capital goods adjustment period (typically 20 years for immovable property under Portuguese law).

Timing for tax optimisation: if the investor has become non-resident in Portugal post-citizenship and has established tax residency in a zero-tax jurisdiction (UAE, Monaco), selling the property at that point results in Portuguese CGT only (on 50% of the gain at the applicable progressive rate) — with no additional tax in the zero-tax jurisdiction. Because the non-resident rate is now determined by reference to worldwide income, the precise charge should be modelled in advance. For investors who remain Portuguese tax-resident, selling in a year with otherwise low income (minimising the progressive rate impact) or using any available tax reliefs is preferable.

Selling Greek Property

Greek land appreciation tax: Greece imposes a tax on the appreciation of real property value. Rates can be significant and the calculation methodology has been updated periodically. Independent Greek tax advice is essential before selling.

Greek income tax on gains: rental income and capital gains on Greek property are subject to Greek income tax for both residents and non-residents. The specific rates depend on the nature of the property and the seller's tax status.

Transfer tax: Greek property transfers are subject to transfer taxes at acquisition; on sale, the seller pays a specific notarial and registration charge structure.

Who Should Own the Investment: Individual vs Corporate Structure

One decision that affects the exit strategy significantly is the ownership structure at the time of acquisition. Some investors hold golden visa properties through a company or trust structure for estate planning, privacy, or financing reasons.

For individuals: the tax treatment described above applies directly.

For companies or trusts: the tax consequences of the exit depend on the nature of the structure, the jurisdiction in which it is established, and the applicable tax treaties. In some cases, selling the shares in the company that holds the property (rather than selling the property directly) may provide a more favourable tax treatment — particularly if the company is held in a jurisdiction without a tax treaty obligation to tax the gain. This is a planning question requiring specialist tax advice in both the property jurisdiction and the holding jurisdiction.

Citizenship Security: A Summary

The core reassurance: European citizenship, once legally granted, is not conditional on maintaining the investment that qualified the holder for residency. This applies to Portugal and Greece (and would apply to any programme where citizenship is granted through the naturalization route rather than a "purchase" model). The citizenship is granted for having met the residency and other naturalization requirements during the qualifying period; it is not leased.

The caveat: if the investment is sold before citizenship is granted, the residency basis is lost and citizenship cannot be obtained through the golden visa pathway (though alternative naturalization routes may remain open, depending on the history of actual presence in the country).

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The rules described in this guide reflect the position for Portugal and Greece golden visa programmes as understood at the date of publication. Both programmes have undergone significant changes in recent years and continue to evolve. Tax rates, property regulations, and citizenship requirements change. Nothing in this guide is legal or tax advice. All investors in golden visa programmes should take specific legal advice in the relevant jurisdiction at each decision point — acquisition, maintenance, exit, and citizenship application.

How Global Investments Can Help

Global Investments advises golden visa investors throughout the full programme lifecycle — from initial investment selection and programme compliance through to citizenship applications and investment exit planning. We coordinate with Portuguese and Greek real estate lawyers, tax advisers, and naturalization specialists to ensure that each stage of the programme is managed to the investor's best advantage. Contact our team for a review of your golden visa position.