Is Panama the New Portugal? 2026 Residency-by-Investment Face-Off

Is Panama Replacing Portugal as the Top Residency by Investment Destination?

For more than a decade, the Portugal Golden Visa was the undisputed heavyweight champion of residency-by-investment programs. It offered the "Holy Grail": a low-risk real estate investment, minimal stay requirements, and a clear five-year path to an EU passport. It was the most flexible EU residency to citizenship program through it’s Golden Visa pathway.

But as we close out 2025, the landscape has shifted dramatically.

While Portugal has tightened its belt, removing real estate options and extending citizenship timelines, Panama has rolled out the red carpet. With the recent ratification of Executive Decree No. 193 (October 2024) and the streamlined "Red Carpet" processing in 2025, in addition to the new ‘traveller passport’ feature introduced in October of 2025, Panama has rapidly become the preferred "Plan B" for investors seeking speed, certainty, and tangible assets.

This article compares the Panama Qualified Investor Visa (QIV) and the Portugal Golden Visa as of December 2025, cutting through the marketing noise to give you the factual, regulatory reality.

Preview: Portugal Becoming More Difficult

If you have been following the headlines in late 2025, you know the Portugal Golden Visa is not the program it was two years ago.

• Real Estate is Gone: You can no longer buy a property to qualify. The door closed in late 2023 and remains firmly shut in 2025.

• The "10-Year" Bombshell: The most significant update in late 2025 is the Portuguese Parliament’s approval of a bill increasing the residency requirement for citizenship eligibility from 5 years to 10 years for most non-EU nationals (starting the clock from the issuance of the card, not the application). While this maintains the residency rights, it fundamentally changes the "ROI" for those seeking a quick second passport. Instead of the 5 years citizenship eligibility from the application submission date, now it will be 10 years for non-Portuguese nationals in addition to the extra 1-2 years of processing time for the initial residency approval (i.e. total 12 years)

Typical Profile of an Applicant for Portugal Golden Visa (2025)

Despite the changes, Portugal remains attractive for a specific type of investor. You are the ideal candidate if:

• - Your Goal is Lifestyle & Travel, Not Just a Passport: You want immediate visa-free travel across the 29 Schengen countries but are willing to wait a decade for citizenship.

• - Your final goal is to obtain a EU passport: Portugal remains one of the most flexible Golden Visa programs in the EU region to offer a citizenship pathway without full time residency – which no other EU country currently offers.

• - You Prefer Financial Assets: You are comfortable investing a minimum of €500,000 in regulated Private Equity or Venture Capital funds rather than managing a physical property.

• - You Have a Long Horizon: You are planning a "slow migration" or retirement in Europe 10+ years down the line and don't need an immediate second nationality.

• - You Can Wait for Processing: You can tolerate a 12–18 month processing window while AIMA (the immigration agency) clears historical backlogs.

Typical Profile of an Applicant for Panama’s Qualified Investor Visa

Panama is attracting the "action-oriented" investor who previously looked at Portugal’s real estate route. You are the ideal candidate if:

• - You Want Real Estate: You prefer to hold hard assets. You can invest $300,000 in a tangible property (mortgage-free) rather than a financial fund.

• - You Need Speed: You want Immediate Permanent Residency (issued in ~30 days), not a temporary permit that needs constant renewal. The entire process including the real estate title transfer process until your immigration is approved would take ~90 days in total.

• - You Hate Tax Complexity: You want to live in (or invest in) a jurisdiction with a Territorial Tax System, meaning you pay zero tax to Panama on your income earned outside of Panama.

• - You Want a "Plan B" in the Americas: You prefer a dollarized economy close to North America with a stable government.

Quick Introduction & Key Points (Latest 2025-2026 Regulations)

Portugal Golden Visa

• Current Status: Open, but restricted to non-real estate options.

• Top Route: €500,000 Investment Fund Subscription (must be a qualifying non-real estate fund).

• Key Constraint: The "NHR 2.0" tax regime (IFICI) is now restricted to highly qualified professionals (scientific/innovation), meaning standard retirees no longer get the blanket 10-year tax holiday on pensions/dividends that existed prior to 2024.

Panama Qualified Investor Visa

• Current Status: Fully operational and streamlined (the new improved version since its re-launch post-pandemic period)

• Top Route: $300,000 Real Estate Purchase. 

• Key Benefit: Immediate Permanent Residency upon approval. No "temporary" phase.

Detailed Comparison: Panama vs. Portugal

Data accurate as of December 2025 Government Regulations.

 
Flight Time Comparison

For North American investors, Panama offers a significant logistical advantage.

The Practical Conclusion: Which Program Wins in 2025?

The "winner" depends entirely on your objective.

1. The Case for Panama (The "Smart Money" Choice)

Panama is the clear winner in 2025 and 2026 for investors who want tangible value. For $300,000 (depending on your nationality)  you own a hard asset (apartment or home or office space) in a growing economy. You get Permanent Residency immediately, not in two years. You pay zero tax on your global crypto, stock, or business income. If you are from the US or Canada, it is in your time zone and easy to visit. It is the ultimate "Plan B" for asset protection and lifestyle.

2. The Case for Portugal (The "EU Heritage" Choice)

Portugal is the choice for those who absolutely need European access. If your goal is to let your children study in Europe or to retire in the Schengen zone, the Golden Visa is still the best vehicle, even with the higher €500k fund cost. However, you must accept the new reality: obtaining a Portuguese passport is no longer a 5-year sprint; it is a 10-year marathon.

The Truth About Panamanian Citizenship

A note of caution from our experts: While Panama allows you to apply for citizenship after 5 years, it is not "pay-for-passport." You must demonstrate genuine ties to the country and speak Spanish. However, as a Permanent Resident, you enjoy almost all the rights of a citizen (except voting), making the citizenship step optional for many.

Secure Your Strategy for 2026!

Government policies change fast, as we've seen with Portugal's sudden shift to a 10-year timeline and Panama's deadline-driven regulations.

Don't leave your global mobility to chance.

At Ingwe Investment & Migration, we specialize in helping investors navigate these exact complexities. Whether you want to lock in Panama's $200,000 to $300,000 Real Estate option before any future price hikes or structure a compliant Portuguese Fund investment, our team is ready to guide you.

Contact us today to schedule your consultation and find out which residency regime fits your family's future.