Europe narrows in-country routes as new options emerge in the Americas
At the September Roundtable, members compared notes from Georgia to Chile: tighter rules in Portugal, France and Luxembourg, a rare easing in Spain, and new investment routes in the Americas.
Key takeaways
- In-country filing is closing in Europe. Luxembourg moves to consulate-only applications from 1 October 2026, and Portugal no longer lets students switch status after arriving on a Schengen visa.
- Files from Russian nationals face closer review, notably for French programmes filed in Moscow and the UAE.
- Spain is the exception, with court-led easing of family reunification and a flexible vocational-study route.
- The Americas are adding routes: a new Panama threshold split, a one-year VAT holiday on new builds in Chile, and an Argentine programme expected shortly.
Europe
Portugal
Alex Alekseev (Immigration Relocator) walked members through the year's changes. The residence requirement for naturalisation rose from five to ten years in May (seven for nationals of Portuguese-speaking countries), and children born in Portugal now qualify for citizenship only once a parent has five years of legal residence. September's package ended tacit approval of applications, closed in-country applications for students arriving on Schengen visas, and limited family reunification with children to children who hold Portuguese citizenship.
Processing is improving. AIMA's online renewal portal now covers golden visa holders, and its latest report shows a sharp rise in permits issued as old backlogs clear. A surge in citizenship applications preceded the change, and naturalisation now takes around three years. Yuri Yurchik (Move to Cascais) added that refusals at renewal are rising where salary or tax obligations were not met.
France
Yulia Ryabchuk (Visere) reported that French consulates in Moscow are interviewing most Talent Passport applicants by phone and refusing many Visitor applications, while refusals from the UAE arrive within days. Filings from another EU residence have fared well, and she now plans a second filing through the French consulate in Spain from the outset where needed. Renewals inside France are checked more closely against the original business plan.
Luxembourg
Mihail Voldochinskiy, Managing Partner of Fiduciary Legal Partners, points out that moving to Luxembourg now starts at the consulate. Since 1 October 2026, anyone applying for a first Luxembourg residence permit must go through a consulate in person: the option of filing directly with the immigration authority is gone. Those who already hold a permit are not affected and renew as before. The good news: the path to Luxembourg citizenship is still just five years.
Spain
Irina Sudakova (EU Consulting) explained that Spain's Supreme Court amended the 2025 foreigners regulation this summer. Parents of Spanish citizens can now be reunited on the basis of support provided inside Spain, a family member's criminal record no longer blocks residence automatically, and foreign guardianship documents are recognised after homologation. Ukrainians under temporary protection may move to any residence type available from within Spain. The mass regularisation is less settled: of roughly 1.2 million applications, she has so far seen approvals only for minors, and she flagged that the arraigo routes could narrow after the next election.
Vera Katkova, representing Instituto IEAE, explained that eligible vocational training programmes may include up to 50% online instruction, provided that the applicable in-person attendance requirements are met. Students may combine their studies with work for up to 30 hours per week, provided they have the necessary work authorisation and their working hours are compatible with their studies. After successfully completing the programme and obtaining the relevant certificate, graduates may apply for a residence and work permit, including for employment in a field different from their area of study, subject to meeting the legal requirements.
Georgia
CBC Group reported that every employed foreigner now needs a work permit and residence permit, with a turnover threshold per foreign employee. New companies under three months old are exempt from the threshold at first application.
Americas
Canada
Slava Apel (CanadaRBI) reported that the Start-up Visa is paused amid a large backlog, with a successor programme aimed at larger businesses expected. Provincial entrepreneur streams remain a path to permanent residence, outside Ontario.
Chile
Aleksandr Lukianov (Waveris) said a one-year VAT exemption on new-build homes, worth roughly 13 to 14 per cent of the price, has been approved but not yet published. Foreign buyers have the same rights as locals.
Panama
Slava Apel noted that the qualified-investor real estate route is now split: the lower threshold applies only to new builds, with a higher one for existing property.
Argentina
Slava Apel added that Argentina was expected to announce a citizenship-by-investment programme shortly.
Update, 2 October 2026. Argentina's Economy Ministry announced on 2 October that applications to its citizenship-by-investment programme will open in the fourth quarter of 2026, through a non-refundable contribution of US$350,000 or the purchase of a US$800,000 public bond. Final terms and the start date remain to be confirmed.
Africa
Sao Tome and Principe
Aleksandr Lukianov reported that the new programme has issued its first passports, with processing nearer six to eight months than the two to three promised. Whether holders benefit from shorter naturalisation in Brazil remains untested.
Questions from the room
Can Ukrainians under temporary protection in Spain move to another residence permit without the regularisation? Yes, according to Irina Sudakova (EU Consulting). They are lawfully resident, so they can switch to any residence type available from within Spain, such as self-employment, employment or financial means. If protection is extended as expected, many will also reach the five years needed for long-term residence.
Does Canadian residence add to the tax burden of a US passport holder? No, said Slava Apel (CanadaRBI): the treaty between the two countries prevents double taxation, and Canadian rates are generally lower. Some clients go further and give up US citizenship once a second passport is in place.
Is there a minimum period of UAE residence before applying at a French consulate there? Not in practice, said Yulia Ryabchuk (Visere): one client filed the day after receiving an Emirates ID.
Can a property purchase in Chile be paid in cryptocurrency? Yes, said Aleksandr Lukianov (Waveris). Chile is crypto-friendly, and licensed exchangers can convert the funds to pesos and pay the developer directly.
What it means for practice
Plan European files for consular filing and closer review, especially for Russian nationals, and build a fallback route into the engagement from the start. In the Americas, timing matters: Chile's VAT holiday lasts a year, and Argentina plans to open applications in the fourth quarter.
This recap is general information, not legal, tax or immigration advice. The views are the participants' own.