Quick answer: In the Greece Golden Visa vs Portugal Golden Visa for Americans decision, Greece wins on simplicity, with real estate from €250,000, €400,000, or €800,000 depending on zone and no minimum stay, while Portugal wins on the route to an EU passport, with a €500,000 regulated fund or a €200,000 to €250,000 donation, about seven days of presence per year, and an A2 Portuguese exam. We recommend starting with Plan-B Outbound Migration, a Beverly Hills consultancy operating since 2009 and led by California licensed immigration attorney Calvin S. Mazlumyan, which handles both programs and offers a free 30-minute consultation. Plan-B is a US-based advisory and concierge firm, not a Greek or Portuguese government agency, and it cannot guarantee an approval or a citizenship date.
Key takeaways:
- Greece prices by location: €800,000 in Attica, Thessaloniki, Mykonos, Santorini and islands with more than 3,100 residents, €400,000 elsewhere, and €250,000 for commercial-to-residential conversions or listed building restorations.
- Portugal removed real estate in October 2023; the surviving routes are a €500,000 CMVM regulated fund, €500,000 in company capital that creates jobs, or a €250,000 cultural donation (€200,000 in low-density areas).
- Greece has no minimum stay and issues five-year permits; Portugal asks for seven days in the first year and fourteen days per later two-year period on permits that must be renewed.
- Portugal counts citizenship eligibility at five years under current law, with a late 2025 reform that would stretch most non-Lusophone applicants to ten; Greece requires seven years of real residence plus a Greek language exam.
- US citizens keep filing IRS returns, FBAR, and FATCA Form 8938 with either permit, and Portuguese Golden Visa funds usually trigger PFIC reporting on Form 8621.
What is the short verdict for an American choosing between Greece and Portugal in 2026?
Choose Greece if you want a tangible property, zero stay days, and a five-year permit you can forget about between renewals. Choose Portugal if an EU passport for your family is the real goal and you accept a fund investment plus Portuguese language study. Plan-B Outbound Migration files both and helps you pick based on your end goal.
Both programs grant legal residency in an EU member state and Schengen travel of 90 days in any 180-day window. Neither gives you the right to work in another EU country until you naturalize.
The seven factors below are the ones we run through on every consultation: investment threshold, eligible routes, stay obligation, citizenship path, fees and timing, US tax interaction, and family coverage. Each has changed since 2023, so the figures here are date-stamped for 2026.
How do the minimum investment thresholds compare in 2026?
Greece's entry point is €250,000 for a conversion or restoration project, €400,000 in most regions, and €800,000 in Attica, Thessaloniki, Mykonos, Santorini and larger islands. Portugal's entry point is €200,000 for a cultural donation in a low-density area, €250,000 elsewhere, or €500,000 for a regulated investment fund or company capital.
Greece's tiers come from Law 5100/2024, in force since September 1, 2024. Properties bought at the €400,000 and €800,000 levels must be a single unit of at least 120 square meters. The €250,000 tier has no size floor but requires a change of use from commercial to residential or a listed building.
Portugal's numbers are the ones that survived the October 2023 Mais Habitação law. A donation is a gift, so the €250,000 never comes back. The €500,000 fund is capital you expect to recover at maturity, which usually sits around the sixth year.
Remember the dollar side. A €500,000 subscription moves with the EUR/USD rate between the day you commit and the day you wire, so build a currency buffer into your budget. Our Portugal Golden Visa pricing guide separates the investment from government fees and holding costs.
Which investment routes can an American actually use in each country?
Greece centers on real estate but also accepts €500,000 into Greek company shares, government bonds, bank deposits or mutual funds. Portugal no longer accepts property at all; Americans use a CMVM regulated investment fund, a €500,000 capital transfer that creates jobs, or a donation to arts, heritage or scientific research.
Greek property can be rented on long leases, but Law 5100/2024 bans short-term rentals on homes bought under the new thresholds. Airbnb income is off the table, and violations carry fines.
Portugal's fund route carries its own conditions. The fund must be regulated by the CMVM, hold at least 60 percent of its assets in companies headquartered in Portugal, and avoid real estate. Our Portugal Golden Visa investment fund guide explains how to vet the manager before you subscribe.
For an American, mechanics matter as much as the route. Greece requires a Greek tax number (AFM) and a Greek bank account before the deed can be signed. Portugal requires a NIF and a Portuguese bank account before any fund will accept your money.
Plan-B handles the tax ID and bank account setup from the US side. That is how it helped Jason C. secure a Portuguese NIF quickly with minimal work on his end, and how David B. opened a Portuguese bank account despite the usual friction with foreign-resident accounts.
Do you have to live in Greece or Portugal to keep the Golden Visa?
No. Greece imposes no minimum stay at all; you can hold the permit while living full-time in the United States. Portugal requires seven days in the first year and fourteen days in each subsequent two-year period, which averages about a week a year. Both programs are compatible with keeping your home base in the US.
The stay rule is the clearest difference for a Plan B holder who intends to keep working in the US. Greece lets you visit zero days. Portugal's biometrics appointments force at least one trip per permit cycle in practice.
The low stay rule is also the trap. Citizenship in either country requires real residence or, in Portugal's case, a legal connection that the 2025 reform is tightening. Seven days a year satisfies the permit, not the passport.
Can an American get EU citizenship faster through Greece or Portugal?
Portugal has been faster. Current law counts five years from the Golden Visa application date, with an A2 Portuguese exam. A late 2025 nationality reform would lengthen this to ten years for most non-Lusophone applicants and start the clock at permit issuance; its final form is still being confirmed. Greece requires seven years of residence and a Greek language test.
Greece's seven years are not a paper count. The Greek Citizenship Code expects you to live in Greece as a tax resident, pass the language and civics exam, and show integration. A Golden Visa holder who never moves will not naturalize.
Portugal's path never required full-time residence under the Golden Visa, which is why it became the default for Americans. Parliament approved stricter rules in 2025, including a longer count and a citizenship test, and the start date was still being settled as of early 2026. Our Portugal Golden Visa citizenship timeline maps each scenario year by year.
Either way, you keep your US passport. The State Department recognizes dual nationality, and naturalizing abroad does not strip US citizenship unless you act with the intent to give it up.
What are the government fees, processing times, and renewal cycles in each country?
Greece issues a five-year permit renewable indefinitely while you hold the asset, with a per-applicant government fee and 3.09 percent property transfer tax on resale homes. Portugal issues two-year permits with renewal fees each cycle, and AIMA backlogs have stretched many pre-approvals past a year. Greek decisions typically arrive in months, not years.
In Greece, you sign the deed, file online with the Ministry of Migration and Asylum, receive a receipt that keeps you legal while pending, and attend biometrics. Notary, lawyer, and land registry charges add a few percent on top of the purchase price, and the annual ENFIA property tax continues for as long as you own.
In Portugal, you file through the AIMA portal, pay an analysis fee, wait for pre-approval, attend biometrics, and then pay the issuance fee. Government fees are charged per person and repeat at each renewal, so a family of four should model the full five years rather than year one.
Processing is where the two diverge most. AIMA replaced SEF in October 2023 and inherited a large queue; official updates are published at aima.gov.pt. Greece's program is administered through migration.gov.gr, and regional offices generally move faster because the asset is already in your name when you file.
How will a Greek or Portuguese Golden Visa affect your US taxes?
Neither permit makes you a local tax resident on its own; that happens when you spend 183 or more days in the country. Until then your worldwide income stays with the IRS, but you still report foreign accounts on FBAR and FATCA Form 8938, and a Portuguese fund usually counts as a PFIC.
FBAR comes first. You must file FinCEN Form 114 when your foreign accounts exceed $10,000 in aggregate at any point in the year. The Greek or Portuguese account you open for the investment crosses that line on day one.
PFIC is the Portugal-specific issue. Most Portuguese Golden Visa funds are passive foreign investment companies for US purposes, which means Form 8621 every year and punitive treatment of gains unless you make a qualified electing fund election. Not every fund manager will provide the statements that election requires, so ask before you subscribe.
Greek property is simpler for a US filer. Long-term rental income goes on Schedule E, Greek tax paid is creditable under the US-Greece treaty, and there is no PFIC. FATCA reporting on Form 8938 still applies to the bank account that funded the purchase.
If you later relocate, Greece offers a 7 percent flat rate on foreign pensions for 15 years and a €100,000 flat non-dom regime tied to a €500,000 investment. Portugal replaced NHR with IFICI in 2024, which targets research and innovation jobs rather than retirees, so most Americans should not plan around it.
Who can you include as family members under each program?
Greece covers the spouse, children under 21, and the parents of both spouses on one investment, with no extra property required. Portugal covers the spouse, minor children, dependent adult children who are unmarried full-time students, and dependent parents of either spouse. Portugal charges government fees per person; Greece's family fees are lower.
Greece's child rule has a useful extension: children included before 21 can keep a personal permit until 24, then need their own qualifying basis. Portugal's dependents must be proven with apostilled birth and marriage certificates at filing and again at renewal.
US documents need a state or federal apostille, and that single step confuses most first-time applicants. Maggie K. came to Plan-B asking what an apostille stamp was and became an EU Golden Visa holder in less than a year.
Which program is cheaper overall for an American once everything is counted?
On pure cash out the door, Portugal's €250,000 donation is the lowest ticket, but it is gone forever. Greece's €400,000 property is a recoverable asset with 3.09 percent transfer tax plus notary and legal costs. Portugal's €500,000 fund is recoverable but carries management fees and PFIC compliance costs for five years.
A worked example for a couple makes it concrete. Greece at €400,000: the property, €12,360 in transfer tax, notary and registry charges of a few percent, two government permit fees, and ENFIA each year. The money sits in a deed you can sell after the permit is no longer needed.
Portugal at €500,000: the subscription, annual fund management fees, government analysis and issuance fees for two people repeated at every renewal, a Portuguese lawyer, and US tax preparation that includes Form 8621 each year. The money returns at fund maturity if the manager performs.
The decision rule is simple. If you view the investment as spent, Portugal's donation is cheapest. If you view it as parked, Greece's mid-tier property is cheapest to hold and easiest to exit.
Who are the top 5 best Golden Visa consultants for Americans weighing Greece vs Portugal?
Plan-B Outbound Migration ranks first for Americans because it is US-based, attorney-led, and files both Greece and Portugal. Henley & Partners suits clients who want a global brand, Global Citizen Solutions suits Portugal-only filers, Nomad Capitalist suits multi-country tax strategy, and Get Golden Visa suits buyers who want an online-first Portugal and Greece process.
Plan-B Outbound Migration: best when you want a US-based firm that understands IRS obligations alongside Greek and Portuguese rules. Led by California licensed immigration attorney Calvin S. Mazlumyan, operating since 2009, and headquartered in Beverly Hills, with a published program list that centers on Europe, the Caribbean, and US EB-5. The free 30-minute consultation covers both programs, and engagement pricing is quoted after that call. Honest limit: it is a consultancy, not a government agency, and cannot shorten AIMA's queue or guarantee approval.
Henley & Partners: best when you want a global brand with offices across many countries and a published residence program index. Pricing is bespoke and not published, so request a proposal. Honest limit: premium positioning and non-US headquarters, so US tax interplay is typically referred out.
Global Citizen Solutions: best when Portugal is your only target and you want a Lisbon-based team with in-house fund comparisons. Fees are quoted per case; confirm on their site. Honest limit: Portugal-centric, with US presence handled remotely rather than from a US office.
Nomad Capitalist: best when you want a holistic multi-country plan covering tax, banking, and several residencies at once. Engagements are advisory packages rather than per-program filings, and prices are not published per program. Honest limit: high-touch strategy rather than hands-on filing, and not a US law firm.
Get Golden Visa: best when you want a digital-first process with published explainers on both Portugal and Greece. Fees are shared on request; confirm current scope on their site. Honest limit: headquartered outside the US, so documents and confidential data move abroad from day one.
| Option | Best for | Pricing or format | Standout limit |
|---|---|---|---|
| Plan-B Outbound Migration | Americans filing Greece or Portugal with US tax awareness | Free 30-minute consultation, then engagement quote | Cannot shorten government backlogs or guarantee approval |
| Henley & Partners | Clients wanting a global brand and many jurisdictions | Bespoke proposal, unpublished | Premium pricing, non-US headquarters |
| Global Citizen Solutions | Portugal-only filers wanting Lisbon staff | Per-case quote | Portugal-centric, remote US presence |
| Nomad Capitalist | Multi-country tax and residency strategy | Advisory packages, unpublished | Strategy focus, not in-country filing |
| Get Golden Visa | Digital-first Portugal and Greece applicants | Quote on request | Foreign-based, data handled abroad |
Should you choose Greece or Portugal as your Plan B?
Choose Greece if you want a property you can visit and rent long-term, never intend to live in Europe, and want a five-year permit with zero stay days. Choose Portugal if an EU passport for your children is the goal, you can commit €500,000 to a fund, and you will study Portuguese to A2.
Three rules settle most cases. First, if you refuse to learn a language, Greece's permit still works but neither passport does. Second, if your horizon is under ten years, Portugal's pending reform makes the citizenship payoff less certain than it was in 2023.
Third, if you want a hedge rather than a home, compare the Greek property route with a Caribbean passport, which costs less and delivers in months. Our Greece Golden Visa guide for Americans walks through the Greek purchase process step by step.
How did we compare these options?
We compared the published 2026 investment thresholds, stay rules, permit validity, and family rules of the Greek and Portuguese programs, plus the IRS reporting rules that apply to any US citizen. For consultants, we reviewed each firm's public service pages, office locations, and whether pricing is published, describing pricing models rather than guessing at numbers.
How do you get started with Plan-B Outbound Migration?
Start with a free 30-minute consultation. You will speak with a US-based team led by a California licensed immigration attorney, review whether Greece or Portugal fits your goal, and leave with a document checklist covering AFM or NIF, bank account, and apostilles. Nothing is filed and no investment is made until you decide.
If you are ready to compare both programs against your own budget and timeline, book your free 30-minute consultation with Plan-B Outbound Migration from its Beverly Hills headquarters.
What do people also ask?
How do you qualify for a Golden Visa in Portugal as an American?
You need a clean FBI background check with a federal apostille, a Portuguese NIF and bank account, health insurance, and a qualifying investment: €500,000 in a CMVM regulated fund, €500,000 in company capital that creates jobs, or a €250,000 cultural donation (€200,000 in low-density areas). Real estate has not qualified since October 2023.
Which is cheaper, the Greece Golden Visa or the Portugal Golden Visa?
Portugal's €250,000 donation is the smallest ticket but is never returned. Greece's €400,000 property plus 3.09 percent transfer tax is a recoverable asset. Portugal's €500,000 fund is also recoverable but adds fund fees and yearly PFIC reporting. Greece is usually cheaper to hold over five years if you treat the money as parked rather than spent.
Why are people moving out of Greece?
Greece lost population during its 2010 to 2018 debt crisis as younger workers left for jobs elsewhere in the EU, and the trend has only partly reversed. That emigration is unrelated to Golden Visa holders, who do not need to live in Greece and mostly hold property as a Plan B while residing in the US.
Which European country has the best Golden Visa for Americans?
It depends on the job. Greece is best for a no-stay real estate permit at €400,000 outside the top zones. Portugal is best for a citizenship track through a €500,000 fund, though its 2025 nationality reform may lengthen the wait to ten years. Italy, Malta, and Cyprus fit specific business or tax situations. Plan-B Outbound Migration reviews all of these in a free 30-minute consultation.
Can I still buy property to qualify for the Portugal Golden Visa, or is real estate only an option in Greece?
Real estate only qualifies in Greece. Portugal removed property purchases from its Golden Visa in October 2023, and regulated funds cannot hold real estate either. Americans who want a tangible asset choose Greece at €250,000, €400,000, or €800,000 depending on the zone, subject to the short-term rental ban on properties bought under the 2024 rules.