Golden Visa ARIT Fund Database

Dual Determination Framework

Fund eligibility requires confirmation from two separate authorities:

AIMA holds exclusive authority to designate eligible funds. CMVM confirms fund existence and registration. No fund is considered eligible without both confirmations.[^1][^2]

Verification Hierarchy[^2]

We follow a three-tier verification approach:

• Tier 1 (Mandatory): AIMA official site (avisos, FAQs) + CMVM public database (ficha de informação, ISIN)
• Tier 2 (Curated): Portuguese law firms, financial news (Jornal de Negócios, Eco Sapo), IMI Daily—used as seed data, verified against Tier 1
• Tier 3 (Specific): Fund manager websites, prospectus (prospeto), management reports (relatório de gestão)

Eligibility Status Labels

For detailed eligibility rules, see our Regulatory Status page.

Under Law 56/2023, funds cannot hold direct real estate in restricted zones—but the Operating Company exception allows investment in businesses that operate real estate-heavy industries.

Eligible (Operating Companies)

• Hotel management companies (Mercan, Stag/Ando Europe, Lakeview)
• Agricultural operations (Pela Terra, Aim Forest)
• Logistics and industrial park operators
• Solar energy and infrastructure operators

Ineligible (Passive Real Estate)

• Direct residential property ownership
• REITs holding rental portfolios
• Commercial property development for sale
• Short-term rental platforms (Airbnb-like)

The Test: Is the underlying asset a business operation or passive property holding?

• A fund owning a hotel = ineligible (passive property)
• A fund investing in a hotel management company = eligible (operating business)

Red Flags to Watch For

• PropTech platforms or short-term rental technology
• Property management software companies in restricted zones
• Funds with valuations dependent on property appraisals rather than operating income
• "Technology" VC funds with proptech exposure

60% Portugal HQ Rule: At least 60% of fund capital must be invested in commercial companies headquartered in Portugal.[^1]

For complete eligibility rules, see our Regulatory Status page.

Eligibility Status

• AIMA eligibility confirmation
• CMVM registration status
• Prospectus and annual report links (where available)
• Last verification date

Fee Structure (Standardized)

• Subscription fee (one-time, typically 0-2.5%)
• Annual management fee (0.25-2.25%)
• Performance fee (often 20% above hurdle)
• Total cost projection over 5, 7, and 10 years (TCO)

Risk Classification

• Fund type (VC, PE, diversified mutual fund)
• Fund cluster: Capital Preservation, Strategic Growth, Sustainable/Real Asset, Liquid/Open-Ended
• Portfolio concentration
• Sector exposure

Manager Credentials

• SGOIC license verification
• Years in operation
• Previous fund performance
• Golden Visa fund experience

Tax Compliance (by Nationality)

• PFIC annual statement availability / QEF status (US investors)
• UK Reporting Fund Status
• CRS compliance documentation

Cluster 1: Capital Preservation / Hospitality PE
Target IRR: 4-8% annually. These funds focus on established hospitality operating companies, providing capital preservation with modest growth. Examples: Mercan, Stag/Ando Europe, Lakeview Hospitality.

• Best for: Conservative investors prioritizing capital preservation
• Term: Typically 6-10 years (closed-end)

Cluster 2: Strategic Growth / VC & PE
Target IRR: 10-15%+ annually. VC funds investing in Portuguese technology startups and growth companies. Higher risk with potential for significant returns. Examples: Indico, Lince Innovation, BlueCrow.

• Best for: Investors comfortable with higher risk for growth potential
• Term: Often 10+ years

Cluster 3: Sustainable & Real Asset (Agriculture, ESG, Forestry)
Target IRR: 5-10% annually. Funds investing in sustainable operations—agriculture, forestry, renewable energy. Tangible assets with ESG alignment. Examples: Pela Terra, Aim Forest, Iberis.

• Best for: ESG-focused investors seeking tangible asset backing
• Term: Typically 8-10 years

Cluster 4: Liquid & Open-Ended
Target IRR: 2-5% annually. Open-ended mutual funds with daily/weekly liquidity (after initial lock-up). Lower risk, maximum flexibility. Examples: Optimize, 3 Comma.

• Best for: Investors prioritizing flexibility and liquidity
• Term: Open-ended (redeem after 5-year minimum)

Additional Sectors

• Healthcare & Life Sciences: Pharma, biotech, medical devices
• Tourism Services: Travel tech, sustainable tour operators (not property)

Step 1: Filter by Risk Tolerance
Start by eliminating funds outside your risk comfort zone. If you're conservative, filter out venture capital funds. If you want growth potential, focus on PE and VC options.

Step 2: Apply Tax Filters (If Applicable)
US investors should filter for funds with PFIC statement availability. UK investors should check for Reporting Fund Status. This eliminates funds that would create unnecessary tax complications.

Step 3: Compare Total Costs
Look at the 7-year total cost projection (matching the typical citizenship timeline). Fee differences compound significantly over time.

Step 4: Review Manager Track Records
Prioritize established managers with transparent performance history. Newer funds without track records carry additional risk.

Step 5: Create Your Shortlist
Narrow down to 5-7 candidates for deeper due diligence, including reviewing prospectuses and requesting investor references.

We keep a transparent record of material updates to this ARIT fund database so you can see when information was last refreshed.

Version 1.0.0 – 6 February 2025

• Initial launch of structured fund records for 13 AIMA-eligible ARIT funds
• Standardized fields for fees, risk level, sectors, PFIC status, and eligibility status
• Added helper filters for QEF-compliant funds and 10-year citizenship path alignment

For each fund, we also track an infoSourceDate field (where available) indicating when data was last verified against AIMA/CMVM or official manager documentation.¹²

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References

Footnotes

1. Diário da República – Official gazette of the Portuguese Republic, including Law No. 56/2023 ("Mais Habitação"). ↩

2. CMVM – Comissão do Mercado de Valores Mobiliários (Portuguese Securities Market Commission), official institutional portal and public fund/SGOIC registry: https://www.cmvm.pt/PortalInstitucional?Input_language=pt-PT and AIMA (formerly SEF) official guidance on Golden Visa / ARI: https://www.aima.gov.pt/. ↩