Portugal vs Italy vs Greece: where to move in 2026

All three countries rewrote their rules within the last twenty-four months, and they moved in different directions.

Portugal closed the property route to its Golden Visa in October 2023, replaced NHR with the much narrower IFICI regime in 2024, and doubled its naturalization period from five years to ten in May 2026. Greece roughly tripled its Golden Visa property thresholds in September 2024 and expressly prohibited short-term letting of the qualifying property. Italy tripled its flat tax for new residents from €100,000 to €300,000 with effect from January 1, 2026.

The common thread is that the era of inexpensive European residency through property is over in all three. What remains is three different products solving three different problems, and most buyers arrive comparing them on the wrong axis.

What each country now offers on residency

Greece is the only one of the three with a property route to residency. The Golden Visa operates on three tiers under Law 5100/2024: €800,000 in prime areas including the municipalities of Athens and Thessaloniki, Mykonos, and Santorini; €400,000 in most other regions; and €250,000 for the conversion of commercial buildings to residential use or the restoration of listed heritage buildings, with no geographic restriction. The two upper tiers carry a 120 square meter minimum and a single-property requirement. A separate €250,000 route through startups registered with Elevate Greece was added by Law 5162/2024. There is no minimum stay requirement for renewal.

Portugal’s Golden Visa continues without property. Qualifying routes are CMVM-regulated investment funds at €500,000, cultural heritage donation, capital transfer, business creation, and research investment. The presence requirement is an average of seven days per year, the lowest in Europe. Portugal also operates the D7 for those with passive income, the D8 for remote workers, and the D2 for entrepreneurs, all requiring genuine residence.

Italy has never had a property route and still does not. Its investor visa operates through business investment rather than real estate. Its elective residence visa serves those with substantial passive income who will not work in Italy. Buying an Italian house confers nothing beyond the house.

Citizenship: the timelines have reversed

Two years ago Portugal offered the fastest route in this group at five years. It now offers one of the slowest.

Greece requires seven years of lawful residence for naturalization, with EU long-term resident status available after five subject to tax residency and other conditions.

Portugal requires ten years under Organic Law No. 1/2026, in force since May 19, 2026, reduced to seven for nationals of Portuguese-speaking countries and EU member states. The clock now runs from issuance of the residence title rather than from application submission, which given AIMA’s processing backlog adds real time on top.

Italy requires ten years for non-EU nationals.

For a buyer whose objective is an EU passport rather than a residence permit, Greece is now the fastest of the three, and by a meaningful margin for anyone outside the CPLP and the EU.

The special tax regimes, compared

Each country runs a preferential regime for new arrivals. They are not comparable products, and the differences matter far more than the headline rates.

Italy’s flat tax under Article 24-bis replaces ordinary income tax on all foreign-source income with a single annual payment, now €300,000 following the January 2026 increase, for up to fifteen years. Family members can be included at an additional annual charge. Eligibility requires not having been Italian tax resident for nine of the previous ten years. There is no minimum investment and no work requirement. Italian-source income remains subject to ordinary rates of 23% to 43%.

Its value extends well beyond income. During the regime, foreign assets are exempt from Italy’s wealth taxes — IVIE on foreign real estate and IVAFE on foreign financial assets — and, more significantly, foreign-situs assets fall outside Italian inheritance and gift tax entirely for transfers made while the regime is in force. That estate planning dimension is the least discussed and frequently the most valuable feature.

Those who validly opted in before January 1, 2026 retain their original rate, so anyone comparing against published figures should check which vintage they are reading.

Greece’s non-dom regime applies a €100,000 annual flat charge on foreign-source income for up to fifteen years, with a lower charge for family members, conditional on investing at least €500,000 in Greece within three years. Greece also runs a separate 7% flat rate on all foreign-source income for foreign pensioners transferring tax residence, for up to fifteen years, which has no equivalent in either of the other two.

Portugal’s IFICI offers a flat 20% on qualifying Portuguese employment and self-employment income and an exemption on most foreign-source income for ten years. Eligibility is the narrowest of the three: a qualifying degree at EQF level 6 or above, a designated high-skilled activity performed in Portugal, and satisfaction of that condition annually. Pension income is excluded entirely, which the old NHR covered and which Greece’s 7% regime covers directly.

The arithmetic nobody publishes

Italy’s flat tax is frequently presented as the strongest offer in Europe. Whether it is depends entirely on a calculation that marketing material omits.

At €300,000 per year, and against an Italian top marginal rate around 43%, the regime breaks even at roughly €1 million of annual foreign passive income. Below that figure you are paying more than ordinary taxation would cost. Well above it — at €3 million, €5 million, or more — the regime is extraordinarily efficient, because the charge is fixed regardless of income.

Greece’s €100,000 charge breaks even correspondingly lower, but it carries a €500,000 investment obligation that Italy does not, so the true comparison must include the opportunity cost of that capital.

Portugal’s IFICI carries no charge at all, but its foreign income exemption only helps someone whose home country stops taxing them on departure, and its narrow eligibility excludes most of the people who would benefit.

The practical consequence: these three regimes serve three different income levels. Italy is for very large offshore portfolios. Greece is for substantial ones willing to commit capital locally. Portugal’s is not really a wealth regime at all — it is a skilled-worker regime that happens to exempt foreign income.

Baseline taxation when no special regime applies

Most buyers will not qualify for, or will not want, a special regime. The ordinary position then decides the outcome, and here the ranking changes.

Portugal has the mildest baseline of the three. There is no general wealth tax. AIMI applies only to Portuguese residential property and building land above €600,000 per person, or €1.2 million per couple, at 0.7% to 1.5%, and it is assessed on tax value rather than market value. Financial assets fall outside it entirely. There is no inheritance tax; gratuitous transfers to a spouse, descendants, and ascendants are exempt from the 10% stamp duty that otherwise applies.

Italy taxes foreign assets held by its residents through IVIE on foreign real estate and IVAFE on foreign financial assets, alongside annual reporting obligations, unless the flat tax regime applies. Italian inheritance tax runs at 4% to 8% depending on relationship, with substantial thresholds for close family.

Greece levies ENFIA, an annual property tax, and taxes residents on worldwide income at progressive rates absent a special regime.

For a family with a globally diversified portfolio who will not elect a special regime, Portugal’s ordinary position is materially cheaper to hold than either alternative. That is the reverse of the special-regime ranking, and it is the single most common analytical error in this decision.

The Greek restriction that changes the investment case

If you buy Greek property to obtain residency, you cannot let it on Airbnb or any short-term platform, and you cannot sublet it. The prohibition is express, and violation triggers revocation of the permit and an administrative fine of €50,000. The same penalty applies where a property acquired through the conversion route is used as a company’s registered seat or branch office.

This removes the yield case that historically justified the Greek route. An €800,000 Athens apartment held for residency is a cost of carry, not an income asset, and the model should be built accordingly.

The market has already responded. Bank of Greece data show foreign capital inflows into Greek property fell approximately 24% between January and September 2025 against the same period of 2024, from around €1.93 billion to €1.46 billion — following the threshold increases and the letting restriction.

Portugal’s position differs in kind rather than degree: property does not qualify for residency at all, so there is no equivalent restriction. Portuguese short-term letting is regulated municipally, with containment zones in parts of Lisbon, Porto, and the Algarve, and municipalities with more than 1,000 registrations must adopt or revise their regulations by the end of 2026.

Acquisition costs

Portugal. From September 1, 2026, buyers who are not Portuguese tax residents pay a flat 7.5% IMT on residential property under Decree-Law No. 97/2026, with no exemptions or reductions and a partial refund available if the buyer becomes tax resident within two years. Stamp duty adds 0.8%.

Italy. Registration tax generally applies at 2% for a qualifying main residence and 9% otherwise, calculated on cadastral value rather than price where the buyer is an individual purchasing from a private seller, which frequently produces a substantially lower effective cost than the headline rate suggests. New-build purchases from developers attract VAT instead.

Greece. Property transfer tax is comparatively low at around 3%, with VAT applying to certain new builds, though that treatment has been subject to suspension periods.

Italy’s cadastral valuation mechanism is the one most often misread by foreign buyers, in both directions. It can make Italian acquisition cheaper than the stated 9% implies, and it does not apply in every transaction type.

Succession

All three apply forced heirship in domestic law — the legítima in Portugal, the legittima in Italy, and reserved shares in Greece — and all three sit within the EU Succession Regulation, so a foreign national may elect the law of their nationality to govern their estate. That election must be made expressly in a valid disposition and is not achieved by a standard notarial will in any of the three.

The tax outcomes diverge sharply. Portugal effectively does not tax transfers to a spouse or in the direct line. Italy taxes Italian-situs assets at 4% to 8% by relationship, with foreign assets outside the charge entirely during the flat tax regime. Greece taxes according to relationship bands.

For a family whose primary planning objective is passing property to children, Portugal’s position is the simplest of the three by a wide margin.

The property markets themselves

Portugal offers Lisbon and Cascais, the Algarve’s golf-led resort market, Porto in the north, and Comporta on the Alentejo coast. Atlantic rather than Mediterranean, with materially cooler summers than either alternative, and the strongest English-language service infrastructure of the three.

Italy offers the deepest and most varied inventory in Europe at this level: Tuscany and Umbria, the lakes, Milan and Rome, Puglia, and the Amalfi coast, with a genuine heritage restoration market that neither of the others matches. Transactions are slower and administratively heavier, and regional variation in practice is considerable.

Greece offers the islands, the Athens Riviera, and mainland coastal markets, at the lowest entry pricing of the three, with the most seasonal demand profile and the thinnest year-round infrastructure outside Athens and Thessaloniki.

Choosing between them

Your objective is an EU passport. Greece, on the timeline alone — seven years against ten in both alternatives, or seven in Portugal only for CPLP and EU nationals.

Your objective is residency without relocating. Portugal, on the seven-day presence requirement, unless you want a property asset in the deal, in which case Greece is the only route that includes one.

You have very large offshore income and will actually move. Italy, decisively, above roughly €1 million of annual foreign passive income and increasingly so as that figure rises. Below it, the flat tax costs more than it saves.

You are a foreign pensioner. Greece, on the 7% regime, which Portugal explicitly excludes from IFICI and Italy addresses only through its separate southern-regions scheme.

Your wealth is substantial and predominantly financial, and you will not elect a special regime. Portugal, on the absence of any general wealth tax and the absence of inheritance tax in the direct line.

You want rental income from the property that gets you residency. None of them cleanly. Greece prohibits short-term letting on qualifying property, Portugal’s property route is closed, and Italy has no route. Separate the residency decision from the income decision.

You want to buy property and are indifferent to residency. All three are open, and the choice reduces to market, climate, ongoing tax, and succession — where Portugal’s baseline is mildest, Italy’s inventory is deepest, and Greece’s entry pricing is lowest.

The most common mistake is choosing the country on the strength of its special tax regime, then discovering that eligibility is narrower than advertised or that the break-even sits above your actual income. Establish which regime you genuinely qualify for, and what it costs against your real numbers, before anything else. The property decision should follow that, not precede it.

One further point applies to all three equally. The EU Entry/Exit System became fully operational on April 10, 2026, replacing passport stamps with automatic biometric tracking of the 90/180 day allowance across all Schengen states, and ETIAS is expected later in 2026. For anyone currently managing European time on visa-free access rather than a residence permit, that allowance is now counted precisely. Holders of residence permits are not registered in the system at all.

FAQ

Which country is best for European residency in 2026?
It depends on the objective. Greece is the only one of the three offering residency through property, and has the shortest citizenship timeline at seven years. Portugal offers the lowest presence requirement at seven days per year, through investment funds rather than property. Italy offers the strongest tax regime for very large offshore income but no property route to residency at all.

Can I still get residency by buying property in Europe?
In Greece, yes, at €800,000 in prime areas including Athens and Thessaloniki municipalities, Mykonos, and Santorini, €400,000 elsewhere, or €250,000 for commercial-to-residential conversions and restoration of listed buildings. Portugal closed its property route in October 2023 and Italy never had one. Spain closed its program entirely in April 2025.

How much is Italy’s flat tax in 2026?
€300,000 per year on all foreign-source income, raised from €200,000 with effect from January 1, 2026, for up to fifteen years, with an additional annual charge per included family member. Those who validly opted in before that date retain their earlier rate. Italian-source income remains subject to ordinary rates of 23% to 43%.

When is Italy’s flat tax worth it?
At roughly €1 million or more of annual foreign passive income, against an Italian top marginal rate near 43%. Below that level the €300,000 charge exceeds what ordinary taxation would cost. The regime also exempts foreign assets from Italian wealth taxes and places foreign-situs assets outside Italian inheritance and gift tax while it is in force, which can shift the calculation independently of income.

Can I rent out a Greek Golden Visa property?
Not on short-term platforms. Greek law expressly prohibits short-term letting and subletting of property acquired through the Golden Visa, with violation triggering permit revocation and a €50,000 administrative fine. This removes the yield case that previously supported the route, and the property should be modeled as a cost of carry rather than an income asset.

How long does citizenship take in each country?
Greece requires seven years of lawful residence. Portugal requires ten under Organic Law No. 1/2026, reduced to seven for nationals of Portuguese-speaking countries and EU member states, with the clock now running from issuance of the residence title rather than application submission. Italy requires ten years for non-EU nationals.

Which country has the lowest ongoing taxes on wealth?
Portugal, for anyone not electing a special regime. It has no general wealth tax; AIMI applies only to Portuguese residential property above €600,000 per person, assessed on tax value rather than market value. Italy taxes residents’ foreign real estate and financial assets through IVIE and IVAFE unless the flat tax applies, and Greece levies ENFIA on property.

Is Portugal’s IFICI as good as NHR was?
No. IFICI is considerably narrower. It requires a qualifying degree at EQF level 6 or above and a designated high-skilled activity performed in Portugal each year, and it excludes pension income entirely, which NHR covered. Many people who would have qualified under NHR do not qualify under IFICI.

Which is best for a retiree with a foreign pension?
Greece, which applies a flat 7% to all foreign-source income for foreign pensioners transferring tax residence, for up to fifteen years. Portugal’s IFICI excludes pension income. Italy’s comparable 7% scheme is restricted to qualifying municipalities in its southern regions.

Is this article tax or immigration advice?
No. It presents general information as of August 2026 on three tax and immigration systems, all complex, fact-specific, and subject to change. Independent professional advice in the relevant jurisdiction is required before any decision.

DISCLAIMER

Important information

This article is provided for general information only and reflects publicly available regulatory and tax information as of August 2026. It does not constitute tax, legal, investment, or immigration advice in any jurisdiction.

Tax outcomes in all three countries depend on individual circumstances including residence, domicile, nationality, income composition, asset structure, and family situation. Provisions referenced here — including Article 24-bis of the Italian Income Tax Code, Greek Laws 5100/2024, 5162/2024, and 5275/2026, Portuguese Decree-Law No. 97/2026 and Organic Law No. 1/2026, and the IFICI regime — are subject to amendment, and several have changed materially within the last twenty-four months. Grandfathering provisions may mean that published figures apply to some individuals and not others.

Break-even calculations shown are illustrative, based on headline marginal rates, and do not account for surtaxes, treaty relief, deductions, or the composition of an individual’s income. They are not a substitute for modeling an actual position.

Luznur Capital is a licensed real estate brokerage and advisory firm (AMI 22354) operating in Portugal and, through partnership, in Spain. It is not a law firm, tax practice, or immigration advisor, and does not advise on Italian or Greek law. Independent professional advice must be obtained in each relevant jurisdiction before any acquisition, structuring, or relocation decision.

General information as of August 2026, not tax, legal, or immigration advice. All three countries changed their rules within the last two years and grandfathering may apply. Break-even figures are illustrative. Obtain independent advice in each jurisdiction. Luznur Capital (AMI 22354).

Choosing a country before choosing a property

The country decision turns on residency objective, income composition, wealth structure, and nationality rather than on preference, and it should be settled before any property is viewed. Luznur Capital advises international buyers and family offices on the Portuguese side of that decision — Lisbon, Cascais, Comporta, the Algarve, Porto, and Madeira — with coordinated legal, tax, and immigration partners, and alongside clients’ existing advisors in other jurisdictions.

To discuss a specific mandate, contact info@luznurcapital.com.