Golden Visas, Residency by Investment and Tax Residency: What Changed Across Key Jurisdictions in 2025-2026

Why Residency by Investment Has Become a Strategic Tool

Residency by investment programs, commonly referred to as golden visas, have existed for decades. But their strategic relevance has shifted dramatically. What was once primarily a mobility tool, offering visa-free travel or a backup residency for difficult passport holders, has become central to international tax planning and personal wealth structuring for high-net-worth individuals and entrepreneurs. The 2025 and 2026 updates across key jurisdictions have changed the landscape in ways that require a careful reassessment of any residency-based tax strategy.

Key Changes Across Major Jurisdictions in 2025-2026

Portugal, which was one of the most popular golden visa destinations for European and non-European investors, effectively ended its residential real estate pathway in 2024. The program was restructured to focus on fund investments and other qualifying categories. The non-habitual resident tax regime, which offered flat-rate tax treatment on certain income categories for new residents, was also reformed. New applicants entering after a specific cutoff date face materially different tax treatment than those who entered under the original NHR regime. For individuals who had planned their move to Portugal around these benefits, the restructuring has required a review of the entire strategy.

The UAE Golden Visa program has continued to expand. The eligibility criteria were broadened in prior years, and in 2025 and 2026, the program has maintained its appeal for investors, entrepreneurs, and skilled professionals. The UAE Golden Visa provides a 10-year renewable residency, which is a significant improvement over the previous two-year visa structure. Importantly, UAE residency does not automatically confer UAE tax residency, a distinction that is frequently misunderstood and that has significant consequences for individuals still holding tax residency in high-tax jurisdictions.

Greece's golden visa program has undergone threshold increases in high-demand areas, making entry more expensive for investors seeking residential real estate in Athens, Thessaloniki, and the islands. Malta's residency and citizenship programs continue to operate but face increasing EU scrutiny. Spain announced further adjustments to its non-dom tax regime, which interacts with its residency by investment program in complex ways for new applicants.

The Distinction Between Physical Residency and Tax Residency

This is the most critical conceptual point for anyone using a golden visa as part of a tax strategy. Holding a golden visa in a given country means you have the legal right to live there. It does not mean you are tax-resident there. Tax residency is determined by each country's domestic law, typically through a combination of days spent in the country, the location of your habitual residence, your center of vital interests, and in some cases your domicile or nationality.

An investor who obtains a UAE Golden Visa but spends only a few weeks per year in Dubai, maintains their primary home in France, and has their family, business interests, and professional connections in France will almost certainly remain French tax-resident under French domestic law and under the tie-breaker provisions of the France-UAE tax treaty. The golden visa is irrelevant to the tax residency analysis. What matters is the facts on the ground.

Conversely, an individual who genuinely relocates to the UAE, establishes a primary residence there, spends the majority of their time in Dubai, and severs or substantially reduces their ties with their origin country can establish a credible claim to UAE tax residency. The golden visa supports that claim but does not create it independently.

The Role of Substance in Tax Residency Claims

Tax authorities in France, Germany, Italy, and other high-tax jurisdictions have become increasingly sophisticated at challenging claimed non-residency. They use financial data obtained through CRS reporting, social media presence, mobile phone location data obtained through mutual assistance, and detailed analysis of where an individual's family life and economic interests are actually centered. A tax residency claim that is not backed by genuine substance will face challenge, and the penalties for non-disclosure are substantial in most jurisdictions.

Substance, in this context, means physical days in the claimed jurisdiction, a genuine primary residence, local banking and economic activity, and a documented severance of the prior residency. For entrepreneurs, it also means that the management and control of their business interests must demonstrably shift to the new jurisdiction.

Common Traps and How to Avoid Them

The most common trap is the assumption that a golden visa combined with a local bank account and a rented apartment is sufficient to establish tax residency. It is not. The second most common trap is failing to formally exit tax residency in the origin country. France, for example, has an exit tax on unrealized capital gains that applies at the time of departure. Germany has similar provisions. Leaving without properly filing a departure declaration and addressing exit tax obligations creates long-term exposure.

A third trap involves individuals who have multiple residencies and attempt to claim non-residency everywhere. Tax authorities share information and cross-reference claims. An individual who is not tax-resident anywhere becomes a significant compliance risk in every jurisdiction where they have financial interests.

How Bolster Group Can Support You

Bolster Group advises individuals and families on residency by investment programs and their intersection with tax residency planning. We conduct substance assessments, advise on exit procedures from high-tax jurisdictions, and help clients build defensible tax residency positions in their target jurisdictions. If you are evaluating a residency move or reviewing an existing structure, contact us at contact@bolster-group.com.