Case · Applying for Portugal's Golden Visa via the Qualified-Fund Route

This case is a representative, composite scenario. Client details have been anonymised, and the timeline and decision points reflect patterns we typically see across similar cases. Actual approval outcomes, document requirements and processing times depend on the latest rules of the Portuguese authorities and on each individual case. SHIJIA Portugal Service Group does not guarantee approval outcomes.

Client profile

• Main applicant: Ms Wu, 46, finance professional in Hong Kong, asset-allocation focused
• Family: husband (investment-bank executive) and two children (16 and 11)
• Assets: highly liquid; €600,000 ready to allocate immediately
• Goal: not to relocate immediately, but a flexible "Schengen access + education option" for the next 5 years
• Time window: no rush, but hoping to start within the year

Why the Golden Visa (ARI)

Ms Wu's situation differs fundamentally from the earlier cases:

• She doesn't plan to spend most of the year in Portugal. The D7 / D8 both emphasise actual residence, which doesn't suit her.
• The Golden Visa's minimum stay is "14 days every two years" — a perfect fit for her "flexible access" goal.
• She has ample capital to allocate, and the €500,000 fund route is within budget.

But we also told her plainly: Portugal's Golden Visa changed significantly in 2023, and the property-investment route was scrapped. The two main routes now are:

1. Qualified-fund investment ≥ €500,000 (private equity / venture capital funds)
2. Capital transfer ≥ €1,500,000

Ms Wu chose the fund route.

What we do is not "selling a fund"

We need to be clear on this: the firm is not a fund seller, and the local fund managers we introduce are not firm employees. Our role is:

1. Help the client build a fund due-diligence checklist (lawyer reviews the prospectus + credentials; accountant reviews performance + risk)
2. Coordinate bank-account opening + large cross-border transfers
3. Coordinate the whole flow: subscription, ARI application, AIMA appointment
4. Renewal maintenance (every two years)

The investment risk of the fund itself is assessed and borne by the client. The lawyer / accountant handle compliance and process, not investment advice.

Timeline (about 14 months)

Stage	Time	Milestone
Week 0	First assessment	Joint lawyer + accountant review confirms ARI fits
Weeks 1–4	Fund due diligence	Reviewed 3 candidate funds in parallel (prospectus, custodian, track record, liquidation terms)
Week 5	Fund selected	Chose a local tech + real-estate hybrid fund (unnamed)
Week 6	NIF (FastNIF)	3 days
Weeks 7–9	Portuguese bank account	Millennium private-banking arm
Weeks 10–12	Cross-border funds	€500,000 from Hong Kong to the Portuguese account (Hong Kong AML review — done in 2 weeks)
Week 14	Fund subscription	Funds moved from the Portuguese bank into the fund's custody account
Week 16	Apostilles	Birth / marriage / children's birth / criminal record
Week 18	Commercial registry	Investment-proof documents issued by the fund manager
Week 22	ARI online filing	Submitted via the AIMA online system
Week 36	AIMA appointment notice	Waited ~14 weeks
Week 40	Biometrics	Main applicant first, family to follow
Week 56	Cards arrive	Four cards for the family

Three key risk points

1. Cross-border funds compliance

A one-off €500,000 transfer triggers AML review on both ends:

• The Hong Kong side must prove a lawful source of funds (tax records, pay records, investment-exit documents)
• The receiving Portuguese bank runs client due diligence (KYC + EDD)

We prepared a complete Source of Funds Letter + historical bank statements six weeks ahead. It cleared first time.

Real-world experience: we've seen plenty of clients run this step themselves and have the funds bounced back because the source-of-funds explanation wasn't clean — throwing the whole visa timeline off.

2. Fund lock-up + exit

The fund route has a minimum holding period (typically 5 years), and the fund's own liquidation / exit mechanism depends on the terms. Before investing, a client should be clear on:

• What's the minimum lock-up?
• Can you redeem early? What are the penalties?
• Can you redeem when the fund matures after 5 years?

Ms Wu's fund had a 5-year lock-up with phased redemption available from year 6. The lawyer reviewed the prospectus, but the choice is the client's.

3. Change of fund manager

Uncommon, but it does happen: a few years in, the fund's management team changes, affecting performance and compliance. We advise clients to require an annual compliance-and-performance report from the fund manager and to keep those records.

Ongoing maintenance

Getting the ARI isn't the end:

• Year-two renewal — we continue to assist
• Proof of continued holding — obtained yearly from the fund manager
• 14 days of residence every two years — arranged by the client
• Year-five permanent residence / citizenship prep — A2 Portuguese exam / a complete evidence chain

What the client valued most

"The firm's greatest value was giving me a 'framework for judgement': which funds are worth a look, which terms to watch out for, how to keep cross-border money from getting stuck. The final choice was mine, but they made me capable of making it."

What we will never promise

• We do not guarantee approval outcomes. The Portuguese ARI is discretionary, and the authorities can refuse.
• We do not recommend a specific fund as investment advice. We provide a due-diligence checklist and compliance review.
• We do not absorb a client's investment losses. Fund risk is borne entirely by the client.

These lines are a law firm's professional ethics. If anyone tells you "we guarantee a 100% Golden Visa approval" or "this fund is capital-protected," walk away.

Want to know if the Golden Visa fits you?

• Free online assessment — enter your investment range to see if you qualify
• Talk to an adviser — a joint lawyer + accountant case review; the first consultation is free
• Get started with FastNIF — the first step of the ARI process