Portugal’s Golden Visa: Investors Must Choose Between Unlimited and Venture Capital Funds in 2025

Investors face a choice between closed-ended venture capital funds and open-ended investment funds. Venture capital funds offer potential for high returns but have considerations:

• Extended lock-up periods that limit flexibility
• Higher risk profiles due to early-stage investments
• Limited liquidity during the investment period

Open-ended funds offer advantages:

• Daily liquidity (daily unit prices), offering transparency and flexibility
• Lower risk profiles through diversified portfolios
• No lock-up period, allowing tactical adjustments
• Annual income distributions

A key difference between open and closed-ended funds is liquidity. The Portugal Golden Income Fund offers daily liquidity—a rare feature in Golden Visa funds.

While some open-ended funds offer weekly, monthly, or quarterly redemption windows, this fund provides daily unit trading and net asset value (NAV) calculations, with all assets convertible to cash within five working days. This is a safeguard for investors who value early redemptions.

Liquidity is integrated into bank statements, providing transparency and control.

Many Golden Visa-eligible open-ended funds focus heavily on Portuguese equities, exposing investors to a stock market lacking diversification, liquidity, and risk-adjusted returns.

This creates a situation where investors seek the stability of open-ended structures but are subject to the movements of a relatively small equity market.

The Portugal Golden Income Fund focuses on capital preservation through investment-grade Portuguese corporate bonds.

While many funds default to Portuguese equities, this approach addresses limitations in the Portuguese market, where only a few stocks offer sufficient liquidity and market depth. The fund unlocks access to a wider investment universe while maintaining Golden Visa eligibility. All bond investments are investment-grade, offering stability.

“The number of investable Portuguese equities is limited, while numerous companies have excellent credit ratings, either due to strong financials or state ownership. For example, we cannot buy equity in Caixa Geral de Depósitos (Portugal’s largest bank), but we can invest in their bonds. The same applies to key sectors like insurance or infrastructure companies,” says Nuno Serafim, 3 Comma Capital founder and Managing Partner.

Overview of the Fund

The fund operates with transparency and efficiency:

• No subscription fees or entry costs
• Daily unit prices integrated into bank statements
• Independent depository bank ensuring asset safekeeping
• Strict risk management protocols and volatility controls

Core Stability (70% Allocation).

The fund’s foundation rests on Portuguese investment-grade corporate bonds:

Institutional Market Access

• Investment in a highly institutional market with superior liquidity
• Access to both listed and non-listed Portuguese blue-chip companies
• Exposure to strategic sectors, including banking, insurance, healthcare, and infrastructure
• Average Bloomberg Composite rating of A-
• An average maturity of four years
• Fixed income yield to maturity of 4%

Portfolio Management Parameters

• Minimum 65% allocation to Portuguese corporate bonds
• 10-30% allocation range for equities
• 0-20% flexible allocation to digital assets
• Target assets under management of €50 million, with early adoption exceeding €10M

Technical Advantages

Within a portfolio that includes a 15% allocation to US equities and 15% to Bitcoin, the 70% bond exposure delivers a key benefit: Low correlation with growth assets, helping to reduce overall portfolio volatility while maintaining attractive returns (7.5% return since inception on October 2nd, 2024).

• Predictable income stream from investment-grade bonds
• The bond’s revenue accrual effect translates into a built-in cushion against potential drawdowns in the risk assets bucket over the five to six-year Golden Visa period
• Low correlation with growth assets, reducing overall portfolio volatility
• Higher risk-adjusted returns compared to equity-focused alternatives
• Professional portfolio management with strict risk controls

Strategic Growth Elements (30% Allocation)

While stability forms the core, the fund embraces growth through:

• 15% position in an S&P 500 ETF, accessing global market growth
• Dynamic allocation to digital assets (up to 15%), offering exposure to a historically strong asset class

The digital asset component offers flexibility, allowing for adjustments based on market opportunities.

Digital assets have historically demonstrated superior performance. This flexibility, combined with professional management, allows the fund to capture potential upside while maintaining stability.