Optimize vs 3 Comma: Open-Ended Fund Comparison
Both funds offer liquidity after the 5-year lock-up, but differ in fees, PFIC status, and investment strategy. Which suits your Golden Visa goals?
When choosing an open-ended fund for your Portugal Golden Visa, Optimize Portugal Golden Opportunities and 3 Comma Portugal Golden Income are the two most prominent options. Both offer the liquidity that closed-ended funds cannot—but they differ in meaningful ways.
Citizenship alignment advantage: Open-ended funds naturally align with any citizenship timeline—whether 5 years (current) or 10 years (proposed under Law 61/2025). No liquidity mismatch risk. See the alignment status in our Fund Database.
Why open-ended funds appeal to Golden Visa investors:
- Liquidity after the mandatory 5-year holding period
- Lower volatility than VC/PE alternatives
- NAV-based redemptions (know what you're getting)
- Psychological comfort of "exit when ready"
- Full alignment with any citizenship scenario—no reinvestment risk
The trade-offs:
- Lower target returns (3-4% vs 10-15% for PE/VC)
- "Gating" risk during market stress (redemptions may be queued)
- Must not redeem before 5 years—cancels your visa
This comparison breaks down exactly how Optimize and 3 Comma differ so you can make an informed choice. For a side-by-side interactive comparison with live TCO data, use the comparison feature in our Fund Database.
Key Metrics Comparison#
| Metric | Optimize Golden Opportunities | 3 Comma Golden Income |
|---|---|---|
| Structure | Open-ended | Open-ended |
| Minimum Investment | €500,000 | €500,000 |
| Target IRR | ~4% annually | ~3.5% annually |
| Management Fee | 1.0% | 0.75% |
| Subscription Fee | 0% | 0% |
| Performance Fee | 0% | 0% |
| TER (Total Expense Ratio) | ~1.25% | ~1.0% |
| PFIC Status | Unknown | QEF-Compliant |
| AIMA Status | Confirmed Eligible | Confirmed Eligible |
| Lock-up Period | 5 years (visa requirement) | 5 years (visa requirement) |
| ISIN | PTOPZWHM0007 | — |
Key takeaway: 3 Comma has lower fees (0.75% vs 1.0% management) and is QEF-compliant for US investors. Optimize has a slightly higher target return but unknown PFIC status.
Important
7-Year Total Cost Analysis#
Scenario: €500,000 investment held for 7 years (typical citizenship timeline)
Optimize Golden Opportunities
- Subscription fee: €0 (0%)
- Annual management: €5,000/year × 7 = €35,000
- TER impact: ~€6,250/year × 7 = €43,750
- Approximate total fees over 7 years: €43,750 (8.75% of initial investment)
3 Comma Golden Income
- Subscription fee: €0 (0%)
- Annual management: €3,750/year × 7 = €26,250
- TER impact: ~€5,000/year × 7 = €35,000
- Approximate total fees over 7 years: €35,000 (7.0% of initial investment)
Fee difference: €8,750 over 7 years
This difference compounds. Over a 10-year holding period (potential Law 61/2025 scenario), the gap widens to approximately €12,500.
Investment Strategy Differences#
Optimize Golden Opportunities
- Focus: Diversified multi-asset portfolio
- Strategy: Balanced exposure across Portuguese equities, bonds, and alternative investments
- Goal: Capital preservation with moderate growth
- Risk level: Low-moderate (2/5)
3 Comma Golden Income
- Focus: Income-generating investments
- Strategy: Emphasis on regular distributions and capital preservation
- Goal: Steady income with principal protection
- Risk level: Low-moderate (2/5)
Strategic fit:
- If you prefer regular distributions: 3 Comma's income focus may suit you
- If you prefer growth orientation: Optimize's diversified approach may provide slightly better upside
- Both are conservative relative to PE/VC funds
US Investor Considerations (PFIC)#
For US citizens and tax residents, PFIC status is critical.
3 Comma: QEF-Compliant
- Explicitly markets PFIC compliance
- Provides QEF (Qualified Electing Fund) election support
- Annual PFIC statements available for Form 8621
- Taxed at ordinary income rates on your share of fund income (avoids punitive "excess distribution" regime)
Optimize: Status Unknown
- PFIC status not publicly confirmed
- May or may not provide QEF election support
- Action required: Contact Optimize directly to verify PFIC statement availability before investing
Why this matters:
Without a QEF election, PFIC gains are taxed at the highest marginal rate plus an interest charge—potentially 40-50% effective tax rate. With QEF election, you pay tax on your annual share of income at ordinary rates (up to 37% federal, but avoiding the interest penalty).
Recommendation for US investors: Unless Optimize confirms QEF compliance, 3 Comma is the safer choice from a tax perspective.
Note
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Liquidity and Redemption#
Both funds are open-ended, meaning you can redeem after the 5-year Golden Visa holding period. However, open-ended doesn't mean "instant cash."
How redemptions work:
- Submit redemption request to fund administrator
- Fund processes at next NAV calculation date (daily/weekly/monthly)
- Receive proceeds (typically T+3 to T+10 days)
Gating risk:
During market stress or high redemption demand, funds may:
- Queue redemptions (first-come, first-served)
- Limit redemption amounts per period (e.g., 10% of fund per month)
- In extreme cases, suspend redemptions temporarily
Neither fund has publicly disclosed gating provisions in detail. Review the prospectus (prospeto) for exact redemption terms.
Practical reality:
For Golden Visa investors holding €500,000 in a €50M+ fund, your redemption is unlikely to trigger gating. But if Portugal's Golden Visa program changes dramatically and many investors exit simultaneously, queues could form.
Timeline and Citizenship Path Alignment#
Current law (5-year path):
Both funds align well. After 5 years, you can:
- Apply for citizenship
- Redeem your investment
- No reinvestment required
Proposed Law 61/2025 (10-year path):
If the 10-year rule takes effect:
- Open-ended funds work well—no fund maturity forcing you out
- Continue holding the same investment for the full period
- No "liquidity mismatch" risk that affects 6-7 year closed-ended funds
Open-ended advantage: You're not forced to reinvest if the citizenship path extends beyond the fund's original term. This flexibility is why some advisors recommend open-ended funds despite lower returns.
Which Fund Should You Choose?#
Choose 3 Comma Golden Income if:
- You are a US citizen or tax resident (QEF compliance)
- You prioritize lower fees over marginally higher returns
- You prefer income-focused investing
- You want the fund with explicitly confirmed PFIC support
Choose Optimize Golden Opportunities if:
- You are NOT a US tax resident (PFIC irrelevant)
- You prefer diversified multi-asset exposure
- You're comfortable with slightly higher fees for potentially higher returns
- You verify their PFIC status if you're US-connected
Neither fund is objectively "better"—the right choice depends on your nationality, tax situation, and investment preferences.
Tip
Frequently Asked Questions
Technically possible but not recommended. Redeeming and reinvesting restarts your 5-year clock for that portion of the investment. You'd need to maintain €500,000 continuously invested to preserve your visa status.
3 Comma is structured for income distribution, so you may receive periodic payments. Optimize typically reinvests returns. Check current distribution policies with each fund, as these can change.
Open-ended funds can close to new investors or merge. Your investment would typically transfer to a successor fund or you'd receive a redemption option. This shouldn't affect Golden Visa eligibility if you promptly reinvest in another qualifying fund.
Neither fund imposes holding periods beyond the regulatory 5-year Golden Visa requirement. After 5 years, you can redeem subject to the fund's normal redemption procedures.
Both funds were established in the post-2023 Golden Visa landscape targeting the fund-only route. Track records are limited. Focus on the fund manager's broader experience and the clarity of their investment strategy.
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