Golden Visas: Paper Residency vs Actual Residency
EU Golden Visas
There are only a handful of EU Golden Visas, each offering a unique set of benefits. However, at a macro level, they can be categorized as either a paper residency program or an actual residency program.
Which EU residency by investment program is best for you should begin with the question:Â Do you plan to move to the EU, and if so, when?
The answer to that question can immediately add or delete EU Golden Visa options from your list of residency solutions.
And this is all you need to know about EU Golden Visas to answer that question.
EU Golden Visas - A Snapshot
During the 12 months from the summer of 2023 to the summer of 2024, the investment migration space [Golden Visas and Citizenship by Investment - aka passport programs] endured a paradigm shift like it had never seen before.
And most of the EU residency by investment programs were affected in some way.
Some programs are closing, some are relaunching, and others have changed investment options or increased prices.
As of this publishing, this is the up-to-date basic information about each EU Golden Visa.
Greece residency by investment
The Greek Golden Visa was the reigning king of residency programs until 1 September 2024, when it essentially tripled in price - its most popular real estate option increased from €250,000 to €800,000.
While the program still maintains two €250,000 property investment options, the one could prove to be the worst investment in the industry.
Also, a third option is said to be on the horizon, which would permit investing into Greek startups.
With that said, the primary real estate investment zones now have a required minimum cash investment of:
€800,000 for all developed regions of Greece including: Athens, Crete, Thessaloniki, Santorini, and Mykonos
In addition, to qualify for the Greek Golden Visa, the property must be at least 120 sq.m. in size.
While the 250K option does not have any size or location restrictions, if the property developer fails to complete the project within 5 years of your Golden Visa approval, your residency status will be terminated.
Furthermore, all Golden Visa properties - regardless of investment option - are now prohibited from capitalizing on the short-term rental/vacation market; only long-term rentals are permitted.
Of course, the property can be used as your own primary, secondary, or a vacation home exclusively for your family's use.
Greek Golden Visa holders could become eligible for Greek/EU citizenship after 7 years.
Cyprus residency by investment
Cyprus is an unsung hero of sorts in the EU Golden Visa space.
It's a Mediterranean island and an EU member state in the Eurozone.
The downside is that it has not yet joined the Schengen Zone, which is in the works, with the end of 2025 as the country's target date to finalize the process.
But, Cyprus does offer some tax avoidance and tax optimization benefits.
The Cyprus Non-Dom Tax Program is arguably the best remaining Non-Dom in Europe.
The Cypriot Golden Visa is a real estate-based program and requires a cash purchase of a property that costs at least €300,000.
Unlike Greece, this property can be used for all rental options – short-term, vacation market, or long-term.
Cypriot Golden Visa holders could become eligible for Cypriot/EU citizenship after 8 years.
Hungary residency by investment
The new kid on the EU block, in 2024 Hungary revamped and relaunched its previously very successful Golden Visa program.
Hungry's relaunch of its residency by investment program was strategically timed to match the price increase of the Greece residency program.
When Greece's most popular option was €250,000, it was the most affordable and viable EU Golden Visa. Hungary's €250,000 investment option is now one of the most affordable EU Golden Visa investment routes offering one of the best residency pathways.
The Hungarian Golden Visa offers three investment channels:
€250,000 minimum cash investment in a government-approved real estate fund
€500,000 minimum cash purchase of residential real estate anywhere in the country
€1,000,000 cash donation to a government-approved institution focused on education or culture
Golden Visa holders could be eligible for Hungarian/EU citizenship after 8 years of residency.
Portugal residency by investment
Portugal was one of the EU residency programs on the chopping block in 2023 - only to be saved due to a restructuring of the program.
The most successful and popular investment option - real estate - was removed from the program and replaced with an Equity Fund option.
The current Portugal Golden Visa prohibits all connections to real estate, and no investment, including the Equity Fund, that connects to real estate will be approved.
The Portuguese Golden Visa program's two most popular investment options are:
€250,000 minimum cash donation to a government-approved organization that supports cultural or artistic initiatives
€500,000 minimum cash investment into an approved Equity Fund
Golden Visa holders can become eligible for Portuguese/EU citizenship after 5 years of residency - and this five-year timeframe begins from the date of Golden Visa approval.
Spain residency by investment
Arguably, the best EU Golden Visa program available - Spain.
However, as of the current state of affairs, the Spanish government has announced its intention to terminate the Spain Golden Visa.
Though a date for program termination has yet to be announced, insiders do not believe the Spain Golden Visa will still exist next summer.
All Golden Visas approved before the termination date will remain valid under the program's rules.
The Spain Golden Visa is a real estate-based program and requires a cash purchase of a property that costs at least €500,000.
The property can be either residential or commercial and located anywhere in Spain.
After 10 years of residency, all legal residents of Spain can become eligible for Spain/EU citizenship.
Malta residency by investment
Officially called the Malta Permanent Residence Programme (MPRP), the MPRP could be the best EU Golden Visa option for certain investors while also being the worst EU Golden Visa option there is.
It is worth noting that the MPRP is also the most difficult to get approved for - which is why the price appears to make it the most affordable EU Golden Visa, but in reality, it is inaccessible to most.
What separates Malta's program from the others is that it permits applicants to rent a house on the Island nation instead of requiring them to purchase one.
So, there is effectively no long-term commitment to the country - the entire process is typically finalized in 1 year.
That said, the MPRP involves:
The most complex investment pathway
Robust due diligence
The most selective approval process
The Malta Golden Visa requires three stages of investment:
Accommodation [pick one]
€300,000 minimum cash purchase of real estate
€50,000 paid in full, minimum total value of a 5-year rental
Government Contribution
€28,000 - if real estate is bought
€58,000 - if rental option is chosen
Donation to an Approved NGO
€2,000 - cash donation
After which, an application fee of €40,000 must be paid to seek Golden Visa approval.
So, all in all, the minimum cost of the MPRP begins at €150,000.
Because Malta offers the EU's only citizenship by investment program [EU passport program], MPRP holders do not become eligible for citizenship.
Paper Residency vs Actual Residency Programs
You may have heard the term paper residency but not fully understood why that differs from residency in general.
Well, it is actually a critically significant difference, and depending upon your current and future intentions, it will be a deciding factor on whether a program is a good investment for you or not.
What is a paper residency program?
Simply stated, a paper residency will allow you to maintain your residency status indefinitely while never physically living in the country.
These programs are typically offered by countries that also provide tax avoidance and optimization programs - which require residency.
Thus, you can effectively move your tax residency to the country of your paper residency while living in other countries.
However, paper residency is not tax residency by default - you must actively make that change.
By default, paper residency is nothing more than legal residency in the country.
Paper residency programs are perfect to use as a real-world Plan B and or as your long-term retirement strategy.
Even though they do not require you to live in the country physically, they provide that option should you want to - the residency status is legitimate.
So, you could gain your paper residency and live the next 10 or so years in your home country until it is time to retire, then move to your new home, where your second residency lies.
What is an actual residency program?
An actual residency program is precisely what it sounds like - the Golden Visa will expire at some point, and if you have not taken up actual physical residency in the country, you will lose your residency status.
These programs are designed to streamline the pathway to permanent residency for those who are actually intending to move to the country.
Before the Golden Visa expires, you must acquire another form of residency permission, or you will completely lose your residency in the country.
However, if you purchased a property for the Golden Visa, you do not lose ownership of your property - the property is legally yours.
You simply lose residency, which can significantly impact your access to the property and how you use it.
Which EU Golden Visas are Paper Residency and Actual Residency Programs?
Here is the list of which EU Golden Visa programs fall into which category.
Greece Golden Visa - Paper Residency
Greece Golden Visa holders acquire a 5-year residency permit in Greece that is renewable for as long as they maintain ownership of the property.
If a paper residency as a Plan B is your ultimate goal, Greece is your best option. You will have a house, EU access, ETIAS & EES exemption status, and tax programs you can leverage whenever the time comes.
You never need to physically relocate and live in Greece unless you want to.
This is genuinely the use when you want to or need to option - even if that time is a decade or so away.
Cyprus Golden Visa - Paper Residency
The Cyprus Golden Visa is one of only two EU Golden Visas that immediately provide permanent residency status.
If tax optimization and avoidance are your ultimate goal, Cyprus is the best paper residency option - Cyprus offers the EU's best Non-Dom Tax Program.
Cyprus Golden Visa holders receive permanent residency, but the residency card needs to be renewed every ten years.
Golden Visa holders never have to relocate or permanently live in Cyprus physically, but they must maintain ownership of the property to keep their residency status.
However, to become eligible for Cyprus citizenship, physically residing in the country is required - a minimum of 8 years in the 10 years immediately before applying for citizenship.
Hungary Golden Visa - Actual Residency
Hungary is considered an actual residency program because the Golden Visa is only renewable once and then will permanently expire.
If at the time it expires, you are not eligible to apply for another residency option - such as permanent residency - you lose your residency status completely.
With that said, to maintain the Golden Visa residency status requires no physical residency at all - you do not need to live in Hungary to keep the Golden Visa.
But, you must maintain ownership of the property to keep and renew your residency permit.
The Golden Visa is a 10-year residency permit that is renewable for 10 additional years - so a total of 20 years before you have to find another option.
If you don't find another option, you will completely lose your residency status.
In order to be eligible for Hungarian permanent residency and citizenship, you must have relocated to Hungary and been physically living there during your Golden Visa years - 3 years for permanent residency and 8 years for citizenship.
Portugal Golden Visa - Paper Residency
Portugal is the best paper residency option if your ultimate goal is citizenship and an EU passport.
While the Portugal Golden Visa is only renewable twice and then permanently expires, you will be eligible for permanent residency or citizenship even if you have never relocated and lived in Portugal.
The countdown for eligibility status for both permanent residency and citizenship begins from the date your Golden Visa is approved - 5 years for both options.
The Portugal Golden Visa will be initially valid for 1 year and then permits you to renew it twice, each gaining an additional 2 years of residency status.
At the five-year mark, the Golden Visa will expire, but you will be eligible to apply for permanent residency or citizenship seamlessly without ever having been required to live in Portugal physically.
Spain Golden Visa - Actual Residency
If you are actually intending to move to the EU, then the Spain Golden Visa is hands down your best option.
You will have a home, ETIAS & EES exemption status, access to the EU, and a streamlined pathway to Spanish permanent residency.
Thus, if retiring in Spain in the next year is your dream, the Spain Golden Visa is the best way to make it your reality.
The Spain Golden Visa will initially be valid for 1 year and allows a one-time renewal for five additional years.
However, you must maintain ownership of the property to keep and renew the Golden Visa.
The Spain Golden Visa does not require you to live in Spain, but at the end of those 6 years, you will need to apply for another Spanish residency option or lose residency completely.
If you do not physically relocate and live in Spain during your Golden Visa years, you will not be eligible for Spanish permanent residency.
Spanish permanent residency requires being a legal resident for 5 years immediately preceding the residency application - 4 of those 5 years, you must have physically resided in the country as a tax resident.
Furthermore, if you do not intend to relocate physically to Spain at all, no other residency option is possible.
The Spain Golden Visa is the only option that does not require physically living in the country to maintain residency status.
I guess you could, of course, buy another house and start the Golden Visa process all over again for another 6 years - well, that is if the program wasn't terminating.
Malta Golden Visa - Paper Residency
The MPRP is the other permanent residency option in the EU.
For those who do not want any real long-term connection to the country other than the residency, the MPRP would be the best option - again, providing they select you.
The MPRP is permanent residency, but, like Cyprus, the residency card needs to be renewed every 10 years.
There are no requirements to reside or live in the country at any time.
Malta does offer some interesting tax avoidance and tax optimization programs that Golden Visa holders can leverage - should they choose to.
Which EU Golden Visa Is Best?
As explained, the answer to that question depends upon the investor.
In reality, if you are actually intending to move to the EU in the next year, then you cannot go wrong with any of them.
Pick the one that best fits your budget, lifestyle, and relocation needs.
If you are not planning to move to the EU, choose wisely, as only paper residency programs may effectively serve to satisfy your goals.
With that said, if you were to lose your residency, which you acquired via property investment, you would be free to sell the property or rent it out and use it as a passive revenue stream - as well as keep it as a lucrative tangible asset in your overall portfolio.
EU Golden Visas are the most effective Plan B and retirement strategies you can leverage when you know how to leverage them effectively.