Spain vs Portugal: Comparing Residence Permit Programs 2026

Spain vs Portugal residence permits explained. Compare visas, investment routes, tax regimes, stay requirements, and EU residency options.

If you’re considering living, working, studying, retiring, or investing in Europe, Spain and Portugal are two of the most popular destinations for non-EU citizens. Both countries offer structured residence permit programs, but their requirements, benefits, tax implications, and long-term outcomes can differ significantly. Understanding these differences is essential to making the best decision for your personal or business goals.

This comparison guide by INLIS Consulting breaks down the key differences between residence permits in Spain vs Portugal, covering visas, investment routes, tax regimes, physical requirements, and citizenship pathways — helping you choose the option that fits you best.

1. Types of Residence Permits in Spain and Portugal

Both Spain and Portugal have multiple pathways to legal residency. Below is a high-level overview:

Feature	Spain	Portugal
Standard Work/Employment Visa	Yes	Yes
Entrepreneur/Self-Employment Visa	Yes	Yes
Passive Income / Retirement Visa	Non-Lucrative Visa	D7 Visa
Investment / Golden Visa	Discontinued for new applications	Active with updated routes
Remote / Digital Nomad Visa	Yes	Yes
Family Reunification	Yes	Yes

Key Notes:

• Spain’s Golden Visa investment program has ended for new applicants as of April 2025.

• Portugal’s Golden Visa remains active in 2026 with productive investment options (funds, research, culture, job creation), but real estate is no longer a qualifying route.

2. Residency by Investment (Golden Visa)

Even though Spain’s classic Golden Visa program is no longer open to new applications, it’s still useful to compare how the two countries structured investment-based residency:

Feature	Spain (Legacy Golden Visa)	Portugal Golden Visa
Program Status (2026)	Closed to new applicants	Active (reformed options)
Minimum Investment	Historically a €500,000 property	Starts ~€250,000 donation options; other routes
Real Estate Option	Yes (historic)	No for new applicants
Stay Requirement	Minimal for permit holding	7 days in the first year; 14 days every 2 years
Citizenship Timeline	10 years	5+ years (though nationality law updates may extend to 10 years)
Family Inclusion	Yes	Yes

Insights:

• Spain’s investor program historically focused on property investment. Due to policy changes, this route ended in 2025.

• Portugal’s approach now emphasizes productive investment, such as cultural support or job creation with relatively low stay requirements, making it flexible for investors seeking EU residency.

3. Physical Presence and Flexibility

The physical presence (how many days you must stay in the country) can significantly impact your lifestyle and tax status:

Requirement	Spain	Portugal
Minimum Stay for Residency Permit	Varies by visa type; Spain historically required a minimal stay for Golden Visa holders only	7 days in year 1; 14 days per 2 years for Golden Visa
Tax Residency Threshold	183+ days per year (standard rule)	183+ days per year (standard rule)

• Spain generally considers you a tax resident after spending 183 days or more in the country.

• Portugal applies the same 183-day rule for tax residency, but physical presence for residency visas like the Golden Visa is minimal. However, D-type visas like D7 require more regular presence if you want to be considered a tax resident.

4. Financial and Income Requirements (Non-Investment Visas)

Beyond investment routes, Spain and Portugal have other key programs:

Portugal D7 vs Spain Non-Lucrative Visa

Feature	Spain Non-Lucrative Visa	Portugal D7 Visa
Main Purpose	Residency for individuals with stable means	Passive income, retirees, remote residents
Work Allowed	Not permitted (officially no work)	Permitted (after residency)
Income Requirement	Higher minimum threshold (approx €30,000+ plus dependents)	Lower threshold based on Portuguese minimum wage levels (e.g., ~€10,000–12,000+/yr)
Healthcare Requirement	Full private insurance	Must show adequate coverage (public systems after residency)

Portugal’s D7 route is generally seen as more accessible for remote workers and retirees due to lower income requirements and the ability to work after residency is granted.

5. Pathway to Permanent Residency & Citizenship

Obtaining citizenship can be a central goal for many expats. Here’s how Spain and Portugal differ:

Outcome	Spain	Portugal
Permanent Residency	After 5 years of legal residence	After 5 years of legal residence
Citizenship Eligibility	Typically, after 10 years of residence	Historically, after 5 years (subject to nationality law updates increasing to 10 years)

Important Update: Recent political reforms in Portugal propose increasing the citizenship residency requirement from 5 to 10 years, aligning with broader immigration policy changes. This reform has not yet fully entered law, but it signals future shifts.

6. Tax Regimes and Fiscal Benefits

Tax considerations often play a major role in choosing between Spain and Portugal.

Spain

• Spain does not offer a broad, specialized tax regime like Portugal’s former NHR for new residents under the Golden Visa program era.

• The Beckham Law historically provided favorable conditions for certain foreign workers (flat tax for a period), but benefits differ significantly from structural programs like Portugal’s.

Portugal

• Portugal’s IFICI/NHR 2.0 regime offers tax incentives to qualified professionals, like a 20% flat tax on eligible Portuguese-sourced income and exemptions on many foreign income types for a ten-year period.

7. Quality of Life, Language & Costs

Factor	Spain	Portugal
Language	Spanish widely used	Portuguese, increasing English use in urban areas
Cost of Living	Generally higher than in Portugal in major cities	Slightly lower overall living costs
Culture & Lifestyle	Rich culture, large international communities	Safe, relaxed lifestyle with strong expat presence

Spain generally offers a larger urban, cosmopolitan experience, while Portugal is known for a quieter pace, affordability, and community-oriented living.

8. Which One Is Right For You?

Goal	Best Fit	Notes
Investor requiring residency-by-investment	Portugal	Spain’s program closed for new Golden Visa applicants
Retiree or passive income resident	Portugal (D7)	Lower income thresholds and work flexibility
Entrepreneur or self-employed	Depends on the business plan	Both countries offer self-employed visas
Path to EU citizenship (faster)	Portugal	Historically, 5 years vs Spain’s 10 years
Short-term residency & travel flexibility	Portugal	Minimal stay requirements

Conclusion

Both Spain and Portugal offer strong options for foreign residents, but Portugal currently provides more active and flexible pathways, especially with its residency-by-investment and passive/residency visas like the Golden Visa and D7. Spain remains a great choice for long-term residence through other visas (such as non-lucrative, student, or work visas), but the closure of its Golden Visa limits investment routes.

At INLIS Consulting, we help individuals understand which program aligns best with their goals, whether you’re planning to relocate, invest, retire, or build a long-term future in Europe.