Is there a window for investors to still apply for Portugal’s Golden Visa or are the applications immediately closed after the announcement by the PM?

We are monitoring this situation. The proposal of the PM will still have to pass in the Parliament. However, the government has majority, which means it is likely that the measures will be close to what was announced. The latest news indicates that visa applications after 16 February (day of the announcement by the PM) will not be accepted, but we think this is completely unconstitutional and shall not be approved in the future. That being said, until these amendments get into force, you would be able to submit your GV application.

The government has no legislative competence to approve changes to the Golden Visa program. The competent body is the Parliament, which should then receive a proposal for voting. There is now expected to be a month for a public hearing, followed by the sending of the final proposal to Parliament for discussion on 16 March, where it should take 15 to 20 days for approval. After that, the diploma should be sent to the President of the Republic, who may react as follows: (i) direct ratification and, in this case, the proposal will be published in the official gazette, subject to a transition period not yet disclosed. (ii) The President doesn't accept the proposal as it stands, and returns it to Parliament for amendment or; (iii) the President accepts the document but asks the Constitutional Court to assess whether any fundamental right or principle is being challenged by the new legislation. In this sense, there is still no certainty that the program ends, since it still lacks approval by a parliamentary majority.

We still do not know. We expect that some forms of investment are kept, and to be a transition period. The law will go on discussion the 16/03. Then we will know more. 

Yes, there is. The Golden Visa program is not cancelled yet. Its revocation will only take place after a new law, approved by Parliament, enters into force, and this process may take months. I also believe that the Government will have the good sense to end the program smoothly, with enough time, so that ongoing investments are not jeopardised.

The Golden Visa program is active and applications can (and should) be submitted. We have seen only an announcement of a set of measures, there is no legislation approved yet. At the present time, we don’t know the exact changes and their implementation period.