Our Independence Manifesto

The Incentive Misalignment

When an advisor earns 3–5% from a fund manager for each investor referral, three predictable patterns emerge:

1. Fund steering: Advisors recommend funds that pay the highest commissions, not funds best suited to the investor's profile. With 30+ CMVM-approved funds available, recommending the same 2–3 funds to every client suggests commission influence.

2. Fee indifference: An advisor earning commissions has no incentive to recommend lower-fee funds. The difference between a low-fee and high-fee fund can exceed €60,000 over 7 years — but the advisor's commission is the same or higher with the expensive fund.

3. Tax blindness: Commission-earning advisors rarely specialize in cross-border tax implications. For US investors, recommending a fund without a PFIC annual information statement can trigger punitive tax treatment under IRC Sections 1291–1298. For UK investors, the Reporting Fund status distinction determines whether gains are taxed at income rates or capital gains rates.

The Scale of the Problem

Consider this: our fund database tracks 30+ funds marketed for Golden Visa. Of these, the vast majority do not publicly disclose their fee structures in marketing materials. When fees are opaque, commission-earning advisors have no incentive to push for transparency on your behalf.

Real Consequences

From our case studies:

• A US investor nearly subscribed to a fund with no PFIC annual information statement — which would have resulted in punitive excess distribution taxation. Independent analysis redirected them to a QEF-eligible fund.
• A UK investor was recommended a fund without Reporting Fund status, which would have meant paying income tax rates rather than capital gains tax rates on all fund distributions.

These aren't theoretical risks. They're the predictable outcomes of conflicted advice.

1. Zero Commissions From Fund Managers

We do not accept placement fees, trailer fees, performance fee shares, or any other form of compensation from fund managers or their distributors. Our revenue comes exclusively from advisory fees paid by investors.

Why it matters: When we recommend a fund, you know the recommendation is based on your profile — not on which fund pays us the most.

2. Full Market Assessment

We evaluate all CMVM-approved funds available for Golden Visa investment. Our fund database covers 30+ funds with standardized data on fees, strategy, risk profile, and tax compliance documentation.

Why it matters: Under MiFID II Article 24(7), independent advisors must assess a sufficient range of instruments. We go beyond the minimum by covering the entire market.

3. Fee Transparency

We disclose our advisory fees upfront, before engagement. There are no hidden charges, no embedded costs, and no post-subscription surprises.

Why it matters: You should know exactly what you're paying and to whom, before committing €500,000.

4. Nationality-Specific Tax Awareness

We flag tax implications specific to your nationality — particularly PFIC considerations for US investors and Reporting Fund status for UK investors. We don't provide tax advice (consult a qualified tax professional), but we ensure you're aware of fund-level tax compliance factors before you subscribe.

Why it matters: A fund that's excellent for a German investor may create significant tax penalties for a US investor. Commission-driven advisors rarely have the expertise or incentive to make this distinction.

5. Honest Risk Communication

We present realistic expectations, not marketing promises. Our content discusses risk factors, red flags, and the 50 due diligence questions every investor should ask. We never guarantee returns.

Why it matters: The Golden Visa investment is a minimum €500,000 commitment for 5–10+ years. You deserve honest risk assessment, not reassuring sales pitches.

Independent financial advice isn't just a marketing claim — it's a legal standard defined by EU regulation.

MiFID II: The EU Standard

The Markets in Financial Instruments Directive II (Directive 2014/65/EU) establishes two categories of investment advice in the EU:

• Independent advice (Article 24(7)): The advisor must assess a sufficient range of instruments and cannot retain third-party commissions
• Non-independent advice (Article 24(9)): The advisor may accept commissions but must disclose them and demonstrate they enhance service quality

Portugal transposed MiFID II through Decreto-Lei 109-H/2021, with the CMVM supervising compliance.

The Structural Gap

Most Golden Visa advisors — immigration lawyers, relocation agencies, consultancies — are not registered as investment firms with CMVM. They fall outside MiFID II's scope entirely. This means:

• No obligation to disclose commissions under financial regulation
• No requirement to assess a range of investment options
• No regulatory standard for the quality of fund recommendations

This is not a criticism of these professionals — they provide valuable immigration services. But investors should understand that a fund recommendation from an immigration lawyer carries different regulatory protections than advice from a CMVM-registered investment firm.

Investor Compensation

Portugal's investor compensation scheme (Sistema de Indemnização aos Investidores) covers up to €25,000 per investor if an authorized investment firm fails to return client assets. This covers custodian failure, not investment losses. It is established under Decreto-Lei 222/99, transposing EU Directive 97/9/EC.

Independence isn't free. Here's the honest trade-off:

What You Pay

With an independent advisor, you pay an explicit advisory fee. This is transparent: you know the cost before you engage, and you can compare it to other advisory models.

What You Save

Independent advice typically saves investors money in three ways:

1. Lower fund fees: Without commission incentives, we can recommend funds with lower subscription and management fees. Over a 7-year holding period, the difference between a 1% and 3% management fee on €500,000 is approximately €70,000 in cumulative fees.

2. Tax efficiency: For US investors, choosing a fund that provides PFIC annual information statements (enabling QEF elections) can save tens of thousands in avoided excess distribution taxes. For UK investors, Reporting Fund status means the difference between capital gains tax rates and income tax rates.

3. Better fund fit: A fund matched to your actual risk tolerance, timeline, and financial goals is more likely to meet your expectations — avoiding early exits, unnecessary reinvestment costs, or misaligned strategies.

The Math

Even a modest advisory fee is typically recovered many times over through lower fund fees and tax-efficient fund selection. The question isn't whether independent advice costs money — it's whether conflicted "free" advice costs you more.

We don't ask you to take our word for it. Here's how to independently verify every claim we make:

Regulatory Sources

• MiFID II full text: EUR-Lex Directive 2014/65/EU — search Article 24 for inducement rules
• ESMA guidance on inducements: ESMA publications — supervisory Q&A on MiFID II Article 24
• CMVM registry: CMVM website — verify whether any advisor is registered as an investment intermediary
• Portuguese Securities Code: Search for "Código dos Valores Mobiliários" on Diário da República

Fund Data

• CMVM fund registry: Verify any fund's registration status on CMVM's public database
• Fund prospectuses: Request the Information Memorandum (prospeto) directly from the fund manager — this must disclose all fees under CMVM Regulation 7/2023
• Our fund database: Browse all funds and compare fees using our standardized data

Tax Information

• PFIC rules: IRS PFIC overview and Form 8621 instructions
• UK Reporting Fund: HMRC Reporting Fund regime

Investor Protection

• Investor compensation scheme: Established under Decreto-Lei 222/99, coverage up to €25,000 per investor per authorized institution
• AIFMD requirements: Directive 2011/61/EU — governs alternative investment fund managers

We link directly to primary sources throughout this site because we believe informed investors make better decisions.