
3 Comma Capital
IMI Official Partner
The elimination of real estate from Portugal’s Golden Visa program has fundamentally altered the investment landscape. Fund selection now stands as the defining choice for residency seekers—one that demands a nuanced understanding of risk, liquidity, and long-term value preservation.
Yet beneath this apparent simplification lies a complex decision matrix: the choice between venture capital and open-ended funds, and within those categories, the critical evaluation of investment strategies that can withstand both market volatility and regulatory scrutiny.
The Critical First Decision: Open-Ended vs. Closed-Ended Funds
The initial choice facing investors is between closed-ended venture capital funds and open-ended investment funds. While venture capital funds offer the potential for high returns, they come with significant considerations:
- Extended lock-up periods limiting investor flexibility
- Higher risk profiles inherent in early-stage investments
- Limited liquidity options during the investment period
Open-ended funds, conversely, provide several strategic advantages:
- Daily liquidity (daily unite prices), offering transparency and investment flexibility
- Lower risk profiles through diversified portfolios
- No lock-up period, allowing tactical adjustments
- Annual income distributions
Understanding Liquidity and Exit Strategy
A crucial distinction between open and closed-ended funds lies in their liquidity profiles. The Portugal Golden Income Fund stands unique in the market through its true daily liquidity structure—a feature rarely found in Golden Visa funds.
While some open-ended funds offer weekly, monthly, or quarterly redemption windows, the fund provides daily unit trading and NAV calculations, with all portfolio assets convertible to cash within five working days. This isn’t just a convenience feature; it’s a fundamental safeguard for investors who value the possibility of early redemptions.
The liquidity is seamlessly integrated into investors’ bank statements, providing total transparency and control over their investment at all times.
The Hidden Challenge: Market Volatility
Most Golden Visa-eligible open-ended funds concentrate heavily on Portuguese equities, exposing investors to a stock market that lacks diversification, liquidity, and risk-adjusted returns.
This creates a paradox: while seeking the stability of open-ended structures, investors often find themselves subject to the unpredictable movements of a relatively small equity market.
The Solution: A Bond-Centric multi-asset approach to Golden Visa Investment
The Portugal Golden Income Fund stands as the first Golden Visa-eligible fund focused specifically on capital preservation through investment-grade Portuguese corporate bonds.
While most Golden Visa funds default to Portuguese equities, this pioneering approach addresses fundamental limitations in the Portuguese market, where only 5-6 stocks offer sufficient liquidity and market depth.
Instead, the Portugal Golden Income fund has developed a corporate bond strategy that unlocks access to a vastly broader investment universe while maintaining full Golden Visa eligibility. All bond investments are strictly investment-grade, offering institutional-quality security and stability rarely found in Golden Visa investment options.
“The number of investable Portuguese equities is very limited, whereas there are numerous large companies in Portugal with excellent credit ratings, either due to their solid balance sheets or because they are state-owned. For example, Caixa Geral de Depósitos (Portugal’s largest bank), we cannot buy its equity, but we can invest in its bonds. Fidelidade (Portugal’s largest insurance group). No access to equity, but we can buy their bonds. The same applies to key sectors such as healthcare or infrastructure companies”, says Nuno Serafim, 3 Comma Capital founder and Managing Partner.

Overview of The Fund
The fund operates with complete transparency and efficiency:
- No subscription fees or entry costs
- Daily unit prices integrated directly into bank statements
- Independent depository bank ensuring asset safekeeping
- Strict risk management protocols and volatility controls
This strategic choice opens doors to major Portuguese institutions not accessible through equity markets.

Strategic Portfolio Construction
Core Stability (70% Allocation).
The fund’s foundation rests on Portuguese investment-grade corporate bonds, offering several unique advantages:
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 AuM of €50 million, with strong 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 (high-risk, high-return 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 through investment-grade bonds forms the core, the fund embraces strategic growth through:
- 15% position in S&P 500 ETF, accessing global market growth
- Dynamic allocation to digital assets (up to 15%), offering exposure to the world's historically best-performing asset class

The digital assets component represents a particularly strategic element of the portfolio. Through professional management, the fund can flexibly adjust this allocation based on market opportunities, potentially increasing or decreasing exposure as conditions warrant.
*Digital assets have demonstrated superior performance, being the top-performing asset class in 11 of the previous 14 years. This flexibility in allocation, combined with professional management, allows the fund to capture significant upside potential while maintaining its core stability mandate.
A New Era of Golden Visa Investors
The Golden Visa landscape has undergone a significant demographic shift, particularly in the American investor segment. While historically attracting professionals in their 40s and 50s, the program now sees a substantial increase in applicants aged 65 and older.
This evolution reflects a growing recognition among American retirees of Portugal's unique value proposition: combining European residency with sophisticated investment options that prioritize stability and reliable income generation.

These experienced investors bring distinct needs and expectations to the investment process. They seek not just financial returns, but comprehensive support in transitioning to European life.
This demographic shift has prompted a reimagining of how Golden Visa funds should operate, emphasizing stability, regular income options, and extensive support services.
Comprehensive Support for the Modern Investor
3 Comma Capital has developed a sophisticated concierge service specifically tailored to this new wave of investors. Understanding that the journey to European residency extends far beyond portfolio management, the firm provides comprehensive support across multiple areas.
Financial Navigation
- Direct fund transfers from foreign accounts without immediate need for Portuguese bank account
- IRA-compatible investment structure for tax-efficient portfolio management
- Professional guidance through both investment selection and residency processes
- Ongoing wealth management excellence through premier financial advisors
Transition Support
- Banking relationship establishment and management
- Tax optimization strategies with experienced local accountants
- Property search and relocation assistance when desired
- Community integration and social network development
This comprehensive support infrastructure addresses a crucial concern among older investors: the fear of navigating a complex foreign system without adequate assistance. By providing patient, expertise-driven support at every step, 3 Comma Capital ensures that the transition to Portuguese life becomes an enriching journey rather than a daunting challenge.
Download our fund and services presentation here.
Begin Your European Journey
Connect with 3 Comma Capital's investment team to explore how our Golden Visa-qualified, bond-focused strategy can secure your path to European residency. Our regulated platform offers professional guidance through both investment selection and residency processes, supported by comprehensive concierge services for your transition to European life.
Contact us:
- Email: sales@3commafunds.com
- Phone: +351 213 622 464 | +351 911 924 773
- Location: Avenida Duque de Loulé 106, 6º floor, 1050-093 Lisboa, Portugal
- Website: www.3commacapital.com









