Portugal or Malta in 2026: Residence permit, citizenship, taxes - comparison for investors

The essence in two words: how Portugal differs from Malta

If we set aside marketing and talk business, the difference between the two countries in 2026 comes down to several fundamental points - and almost each one has changed this year.

Portugal is a large Atlantic coastal country with a population of around 10 million. The investor's path is a Golden Visa residence permit through funds, then transitioning to permanent residence and citizenship through naturalization. Minus - Portuguese language A2 for passport and reform extending the residency requirement.

Malta is a small Mediterranean archipelago with a population just over half a million, where English has the status of official language alongside Maltese. Here, investors have access to the MPRP permanent residence programme. However, Malta's main trump card from previous years - citizenship by investment - was recognized as unlawful by the EU Court in April 2025 and closed.

• Both countries - are full EU and Schengen members, therefore freedom of movement across Europe is the same for residents.
• Portugal - the path to EU citizenship through residence and years of living, but with language requirements and extended residency period.
• Malta - fast and language-comfortable residence permit, but without a short path to a passport following the EU Court decision.

Further, we will examine each section in detail and compile everything into a comparison table.

EU and Schengen: what's common and where there's no difference

Let's start with what the two countries have in common - to avoid attributing imaginary advantages to one. Both Portugal and Malta are members of the European Union and the Schengen area. This means that a resident of either country receives a practically identical set of travel freedoms within Europe.

What this provides in practice:

• Freedom of travel within Schengen. With a Portuguese or Maltese residence permit, you move across Schengen countries without visas and border control within permitted stay periods.
• Access to the EU single market. After obtaining citizenship of either country, you have the right to live, work and study in any EU country.
• European infrastructure. Banks, healthcare, education, rights protection - all within the EU legal framework.

It's important to be here: in terms of freedom of travel, the choice between Portugal and Malta is neutral. Both are in Schengen, and a passport from either (once obtained) is equally strong within Europe. Therefore, the decision should be made not on "passport strength for tourism," but on actual conditions for obtaining status, language, taxes and lifestyle. We'll discuss this next.

Portugal residence permit: Golden Visa through investment funds

Portugal's main investment route is a residence permit Golden Visa (officially - ARI, residence permit for investment activity). In 2023, the programme underwent a major reform through the Mais Habitacao law: direct property purchase routes and simple capital transfer were closed to prevent housing price increases. But the programme itself remains alive - it's just that investment must now work differently.

What is available in 2026:

• Investment Funds - Investment from €500,000 in qualified Portuguese funds (venture capital, private equity). The most popular route today.
• Scientific Research - from €500,000 in research activities.
• Cultural Heritage - from €250,000 to support culture and arts.
• Job Creation - opening a company with employee hiring.

The key advantage of the Golden Visa is minimal residency requirements: it is sufficient to spend approximately 7 days per year in the country on average (14 days over a two-year period). This allows you to maintain status without physically relocating. After five years of legal residency, the path to permanent residency and citizenship opens. A detailed breakdown of conditions and routes is available in our Portugal Golden Visa guide, and the specifics of the fund route are covered in our article on Golden Visa investment funds.

Malta Residence Permit: MPRP Permanent Residency Programme

In Malta, investors have access to the Malta Permanent Residence Programme (MPRP) - permanent residency through investment for non-EU citizens. This is neither citizenship nor temporary residence; rather, it is a permanent resident status that grants the right to live in Malta and enjoy Schengen travel freedom.

MPRP expenditure structure in 2026 (approximate; figures should be verified at the time of application):

• Administrative Fee - approximately €60,000 for the primary applicant for the residential rental route (lower when purchasing property), plus additional fees for dependent adults.
• State Contribution - approximately €37,000 (non-refundable donation); the amount is the same for both purchase and rental.
• Real Estate - purchase from €375,000 or rental from €14,000 per year, to be maintained for a minimum of 5 years.
• Charitable Donation - approximately €2,000.
• Asset Verification - possession of capital of at least €500,000 (including €150,000 in liquid assets).

The programme covers the primary applicant, spouse, dependent children, and dependent parents. The main advantage of MPRP compared to the Portuguese route is language comfort and clear structure; the main disadvantage is that after 2025, this status does not lead to rapid Malta citizenship, as investor citizenship has been closed.

Malta Citizenship: Why the Programme Closed in 2025

This is the most important and point of the entire comparison. For many years, Malta's trump card was citizenship by investment (CBI) - an EU passport for a substantial contribution (approximately €600,000-750,000) and formal residency. In practice, many obtained citizenship after spending less than a month in the country.

On 29 April 2025, the Court of Justice of the European Union issued a ruling in case C-181/23 (European Commission v. Malta), finding Malta's investment citizenship scheme in breach of EU law. The court's reasoning:

• Commercialisation of citizenship is inadmissible. The provision of nationality of an EU member state in exchange for predetermined financial contributions was classified by the court as "trading" in Union citizenship.
• Breach of EU treaties. The scheme was found to breach Article 20 of the Treaty on the Functioning of the EU and Article 4(3) of the Treaty on the EU (principle of loyal cooperation).
• Competence with reservation. Although countries themselves determine citizenship rules, this competence must be exercised in accordance with EU law.

Practical conclusion for 2026: it is no longer possible to directly purchase Malta citizenship. The only option is general naturalisation - a lengthy process requiring genuine residence. Therefore, if the goal is an EU passport, Malta should no longer be considered a fast-track route to citizenship.

Portugal Citizenship: Naturalisation and Residency Requirements Reform

Portugal has never sold citizenship by investment in its pure form - a passport is obtained here through naturalisation after several years of residency, which the Golden Visa can facilitate. This is a different mechanism from the closed Malta scheme: the state does not trade in passports but grants them based on actual residence.

Maximum honesty is required regarding 2026. For a long time, Portugal was renowned for a relatively short residency requirement - five years before applying for citizenship. However, in 2025-2026, the government initiated a reform aimed at extending this period:

• Naturalisation Residency Requirement is proposed to be increased from 5 to 10 years for most applicants (for citizens of Portuguese-speaking countries (CPLP) - to 7 years).
• Language - the requirement to know Portuguese at level A2 is retained.
• Protection of Submitted Applications Typically, reforms include transitional provisions for those who have already submitted documents, but the mechanism and implementation date should be verified at the time of application - the reform status should be clarified as "pending adoption".

Conclusion: Portugal still leads to full EU citizenship, but relying on "five years and a passport" as a given in 2026 is no longer possible - the timeframe is expected to be extended. We discuss the details in our article on Portugal citizenship.

Language: English in Malta versus Portuguese A2

This is one of the most underestimated yet decisive factors for daily life. Here, the two countries differ radically.

In Malta, English has official status on equal footing with Maltese. This is a legacy of the British period: official procedures, education, and business are conducted in English; the vast majority of the population speaks it fluently. For an investor who is comfortable in English, this is a tremendous convenience:

• Documents, contracts, and communications with government bodies in an understandable language.
• Schools and universities with English-language instruction.
• No language exam required for residence permit.

In Portugal, the state language is Portuguese. For daily life in tourist areas, English is often sufficient, but obtaining citizenship will require passing a Portuguese language exam at A2 level (elementary proficiency). This is not an insurmountable hurdle, but you will need to study the language and allocate time for it.

Summary on language: if life and document management in English without learning the local language is critical for you, Malta wins by a significant margin. If you are prepared to master Portuguese at a basic level for a passport, Portugal will not create a barrier.

Lifestyle, climate, and country size

It's easy to forget behind the numbers that you're choosing a place where you'll live or at least spend time regularly. These two countries differ significantly - and it's not just about weather.

Size and space. Portugal is a full-fledged country on Europe's edge: Atlantic coastline, mountains, wine valleys, two major cities - Lisbon and Porto, diverse regions from green north to southern Algarve. Malta is a compact archipelago of three inhabited islands; the entire country can be driven across in an hour, offering intimacy but also a sense of confinement given high population density.

• Climate. Portugal - mild Atlantic and Mediterranean climate, ocean winds, surfing. Malta - dry, hot Mediterranean summers and mild winters, sea literally at every step.
• Cost of living. In Portugal outside Lisbon, life can be noticeably cheaper; in Malta, due to limited island territory, real estate and rent are expensive.
• Environment. Portugal - more of a "European country for living" with space and nature; Malta - international, English-speaking, but densely built hub.

If space, nature, and diversity matter - Portugal tips the balance. If compactness, English-speaking environment, and Mediterranean rhythm of a small island appeal - Malta.

Compliance and nuances for Russian and CIS citizens

Separately and - on applicants from Russia and CIS countries. Both Portugal and Malta operate strictly within EU legal framework, meaning enhanced due diligence and no workarounds.

What to pay attention to:

• Source of funds. Both countries require transparent confirmation of investment money's origin - through income documentation, asset sales, business records. This is not a formality but a critical stage.
• Sanctions compliance. All transactions undergo checks against EU sanctions regimes. Any sanctions circumvention schemes are excluded - this leads to rejection and blocking.
• Banking compliance. Account opening, fund transfers, investment payments - all accompanied by bank checks; documents must be prepared in advance.

The practical point is simple: the cleaner and more transparent your asset and income structure, the higher your chances of passing verification without delays in either country. During preparation, we always structure your source of funds file so government bodies and banks have no questions - this saves months and eliminates rejection risk at final stage.

Who suits Portugal and who suits Malta

Let's consolidate all said into practical profiles. This is not a ranking - each country has its strength, and choice depends on your goal.

Portugal suits you if you:

• Aim for full EU citizenship long-term and are ready for naturalization through years of residence.
• Are willing to learn Portuguese to A2 level for a passport.
• Want a large country with space, nature, and regional diversity.
• Have passive income and consider accessible D7 pathway instead of major investment.

Malta suits you if you:

• Value English as official language and don't want to learn local.
• Need permanent EU resident status without physical relocation requirement.
• Accept that fast citizenship for investment is gone (program closed in 2025).
• Prefer compact Mediterranean island and international English-speaking environment.

The key fork in 2026: if the ultimate goal is EU passport, Portugal remains a working pathway (albeit with lengthening residency requirements), while Malta after the EU Court decision is not. If you need comfortable resident status with English here and now, Malta remains strong.

What to check before deciding: expert perspective

Over years of practice, I see investors most often err not in country choice but by deciding on outdated data. 2026 is particularly tricky: both Portuguese citizenship reform and Malta's CBI closure are recent changes, which many consultants discuss using old figures out of habit.

Before making any transfers, be sure to verify the following points based on current information:

• Status of Portugal's citizenship reform. Clarify the stage of the residency requirement extension law, whether there is protection for already submitted applications, and the effective date.
• What Malta has closed and what remains available. Investment citizenship is closed, but MPRP is operational—do not confuse these two different products.
• Your tax profile. Whether you qualify for the narrow IFICI regime in Portugal and how your income is calculated in Malta—this should be modeled in advance.
• Source of funds. Whether your source of funds documentation is ready for verification by banks and EU government bodies.

Current official Portugal data should always be cross-checked on the government portal. gov.ptA decision involving hundreds of thousands of euros should not rely on articles from a year ago—in this field, a year changes everything.

Taxes: the IFICI regime in Portugal and the refund system in Malta.

Tax considerations often weigh more than the cost of the program itself. Let us compare approaches and without promises of "zero taxes."

Portugal. The famous NHR regime closed to new applicants in 2024. It has been replaced by the IFICI regime—an incentive for research and innovation, sometimes called "NHR 2.0":

• Flat rate 20% on qualified Portuguese income from employment and self-employment.
• Exemption of a significant portion of foreign income for a period of up to 10 years.
• Narrow conditions: the regime is designed for qualified professions, R&D, startups—not suitable for everyone.

Regular income tax in Portugal is progressive, up to 48%. Resident status arises upon residing 183 days per year or possessing permanent housing.

Malta. Malta is known for its refund system: formally, the corporate tax rate is high, but through a refund mechanism to shareholders, the effective rate is significantly reduced. For individuals, foreign income taxation regimes operate on a remittance basis (tax applies to income brought into Malta). Rates depend on status and structure—they are calculated individually.

Conclusion: both jurisdictions offer legitimate optimization tools, but are structured differently. For more details on Portugal, see the overview of Portugal's NHR and IFICI tax regimes..

For annuitants and retirees: the D7 route in Portugal.

Not every investor is prepared to invest half a million euros in a fund. For those with stable passive income—pensions, rental income, dividends—Portugal offers a separate and far more affordable route: the D7 visa.

How it works:

• Income requirement - stable passive income of approximately 870 euros per month (reference: 12 times the minimum annual salary, approximately 10,440 euros), plus allowances for family members.
• Housing - you must rent or purchase housing in Portugal.
• Residence - unlike the Golden Visa, D7 requires actual residence in the country, not merely symbolic presence.

D7 leads to the same result as the Golden Visa—permanent residence and citizenship through naturalization—but is designed for those who genuinely relocate to Portugal to live. For retirees and annuitants, this is often the optimal route: cheaper than the investment fund route and more logical if you plan to live in the country anyway. Malta has no direct equivalent of such an "income-based" route for non-investors under MPRP—its foundation is investment-based. Details are available in the article on Portugal's D7 visa..

Cost and entry threshold: where to enter more affordably.

Let us compare the amounts actually needed at the outset. The figures are approximate and depend on family composition, chosen route, and current rates—an exact estimate is always calculated for a specific case.

Rough conclusion: when comparing capital investments directly, Malta's rental option may appear cheaper at entry, but a significant portion of funds represents a non-refundable contribution and donation. In Portugal, the fund investment formally remains your asset, which in a favorable scenario can be recovered, but the sum is higher. For those with passive income, the Portuguese D7 is radically more affordable entry than any investment program.