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Key Points
- Portugal increases the naturalisation period from 5 to 10 years with new real residence and civic criteria
- Portugal Golden Visa facing up to 3-year processing delays despite €500,000+ investment
- Italy raises the flat tax threshold to €300,000 for non-doms from 2025
- France reintroduces pressure on wealth structuring via real estate tax reforms
- UK tax measures against high-income earners continue to compound the effects of the UK Res Non Dom abolition pushing non-doms to Malta's res non dom regime.
- Malta reinforces its Permanent Residence Programme as a long-term EU foothold
- Malta’s Citizenship by Merit remains the only structured short-path to EU citizenship (8–36 months) based on national contribution
As 2025 progresses, European countries continue to evolve their legal and administrative frameworks relating to residence-by-investment and citizenship pathways. For globally mobile individuals, families, and private clients – including founders, investors and family offices – understanding the impact of these developments is key to effective long-term planning. This update outlines key changes and emerging dynamics in Portugal, Italy, France, and Malta.
Italy: Revised Entry Threshold for Flat Tax Regime
Italy has amended its preferential tax regime for new residents. From mid-2025, the annual flat tax available to non-domiciled individuals has increased from €100,000 to €300,000, reflecting a policy move toward aligning the regime’s fiscal impact with broader budgetary goals. The lump-sum tax remains optional and offers full exemption on foreign income and inheritance taxes, continuing to appeal to those relocating with complex international wealth structures.
France: Changes in Taxation for High-Value Real Estate Holdings
Recent legislative proposals in France are expected to alter the application of the Impôt sur la Fortune Immobilière (IFI), France’s wealth tax on real estate. These proposals aim to narrow exemptions available to non-residents and increase reporting obligations, especially where high-value properties are held via corporate structures. Clients holding French assets or considering residence options should factor these into their succession and tax planning frameworks.
Portugal: Legislative and Administrative Shifts Impacting Golden Visa Holders
Portugal’s Golden Visa regime remains open, though recent legal and administrative changes are shaping how it is used:
- Administrative Delays: Applicants report extended delays in residence card issuance and renewals, in some cases exceeding 24 months. These delays stem from broader restructuring within Portugal’s immigration system and the establishment of the new agency AIMA.
- Path to Citizenship: Legislation passed in late 2025 will extend the residency requirement for citizenship from 5 to 10 years, while introducing additional integration obligations such as cultural knowledge assessments and stronger residency presence during the qualifying period. The new law is expected to enter into force once formally promulgated.
These changes should be considered by applicants seeking long-term EU citizenship as part of their investment strategy. While the programme continues to offer a pathway to permanent residence, naturalisation timelines and requirements have evolved.
Malta: Developments in Residence and Citizenship Frameworks
Malta continues to maintain distinct legal pathways for both permanent residence and naturalisation, each with clear eligibility criteria:
- The Malta Permanent Residence Programme (MPRP) offers indefinite legal residence based on investment, with no annual renewal requirement. The programme is suited to individuals seeking long-term residency rights with flexible presence obligations within the Schengen area.
- Maltese Citizenship by Merit is available under Maltese law to individuals who provide exceptional service or contribute meaningfully to the public interest, including philanthropic, cultural or economic initiatives. Applications may be considered for naturalisation following a minimum of 8 months legal residence, subject to a holistic assessment and a comprehensive due diligence process.
Both pathways continue to be governed by clear regulatory structures and reflect Malta’s commitment to compliance with EU law and international best practices.
Strategic Outlook for HNW and Entrepreneurial Clients
Clients considering residence or citizenship within the EU should take note of the widening divergence in timelines, qualifying conditions, and tax positioning across jurisdictions. While Portugal, France and Italy remain relevant for specific lifestyle and fiscal planning objectives, practical timelines and policy shifts must be reviewed in the broader context of legal stability, procedural efficiency and long-term mobility goals.
Malta, Italy, France and Portugal each offer structured routes to residence – but increasingly differ in the nature and duration of the rights they confer. As the regulatory environment continues to evolve, a jurisdiction-neutral, objective approach to planning remains essential.
Our international private client team can assist in evaluating residence and citizenship pathways aligned with legal, philanthropic, and family wealth objectives across Europe.
