If you want the Portugal Golden Visa fund route without locking money in a closed-end vehicle for a decade, the 3CC Portugal Golden Income Fund is one of the more straightforward options in our database. It offers daily NAV, daily redemptions, a bond-heavy multi-asset portfolio and unusually good documentation, at the cost of a declining exit fee that makes leaving before five years expensive. For US citizens, advertised SDIRA access and reported QEF availability make it one of the stronger stories we have catalogued, though one claim still needs confirming.
Key takeaways
- Open-ended, CMVM-authorized fund (no. 2108) with roughly €95M in assets as of June 2026 and daily liquidity.
- Portfolio core is Portuguese investment-grade credit (60-90%), plus equities (10-30%) and up to 20% in alternatives including gold and digital assets.
- Class A costs: 0% entry, 1.5% management, 20% performance fee above a 5% hurdle, and a 5% to 1% declining exit fee inside five years.
- Manager accepts US investors, advertises SDIRA access, and QEF reporting is reportedly available (confirm before subscribing).
- Since inception in October 2024, the fund has returned 9.56% cumulatively to June 2026. Past performance does not predict future results.
What does the fund actually invest in?
The mandate commits 60-90% of assets to investment-grade credit (bonds, commercial paper, deposits), 10-30% to equities, and 0-20% to alternatives including gold and digital assets via ETFs and ETCs, per the fund's prospectus and KIID. At least 65% must sit with Portuguese issuers, with no leverage and no currency hedging.
That 65% Portuguese floor is not a stylistic choice. It is what keeps the fund inside the post-October 2023 Golden Visa rules, which require a non-real-estate collective investment vehicle with majority Portuguese exposure. The fund holds no direct or indirect real estate.
The June 2026 fund report shows how the mandate translates into an actual book: 62.8% fixed income, 21.56% equities, 8.3% alternative assets (gold and digital assets) and 7.33% cash. Regionally, 66.1% sits in Portugal, 22.25% globally and 4.32% in the US.
Two things stand out for a fund labelled "income". First, the equity sleeve is meaningful, over a fifth of assets. Second, the alternatives sleeve includes crypto exposure, which most bond-fund investors won't expect. Both are disclosed clearly, but they change the risk profile versus a pure corporate-bond fund. Investors who want that crypto exposure dialled up rather than down may want to compare the Horizon Fund, which takes the same Portuguese-bonds-plus-digital-assets idea much further.
What do the fees cost you over a Golden Visa hold?
Class A charges no subscription fee, a 1.50% annual management fee and a 20% performance fee on returns above a 5% annual hurdle, per the manager's fund page and KIID. The KIID estimates total recurring costs at 1.60% per year, slightly above the headline management fee once fund-level expenses are added.
The share classes differ enough to matter:
| Class | Minimum | Management fee | Entry fee | Early exit fee | Policy |
|---|---|---|---|---|---|
| A | €100,000 | 1.50% | 0% | 5% → 1%, then 0% | Accumulating |
| D | €250,000 | 1.75% | 0% | 5% → 1%, then 0% | Distributing |
| AS | €100,000 | 1.50% | 1.50% | Flat 2.5% | Accumulating |
| DS | €250,000 | 1.65% | 1.50% | Flat 2.5% | Distributing |
Now the arithmetic on a €500,000 Golden Visa subscription in Class A. Entry costs nothing. Management fees run about €7,500 per year at 1.50%, or roughly €45,000 over six years and €52,500 over seven, before compounding effects. Using the KIID's 1.60% recurring-cost estimate instead, budget closer to €8,000 per year, or about €48,000 to €56,000 across a six-to-seven-year hold. Exit after five years and one day costs nothing; a year-three redemption would cost 3%, about €15,000 on the same ticket.
The performance fee only bites above 5% per year, so in a flat or modest year you pay recurring costs only. In a strong year, the manager takes a fifth of the excess.
One data-quality note worth pausing on. A widely used fund directory lists the management fee at 1.2%. The manager's own fund page, KIID and monthly reports all say 1.50% for Class A, and we re-confirmed that conflict on 7 July 2026. We record the manager's documents as authoritative. It is a small discrepancy with a useful lesson: aggregator data drifts, and fee figures should always be checked against the KIID you are actually asked to sign.
Liquidity, lock-up and the citizenship timeline
There is no formal lock-up. The fund prices daily, and redemptions are processed daily with an 11:00 Lisbon/London cut-off, per the prospectus and fund reports. What replaces a lock-up is economics: the declining exit fee on Class A and D (5% in year one down to 1% in year five, zero after five years and one day) makes the fund a de facto five-year commitment.
How does that map onto naturalization? In practice, the road from Golden Visa application to Portuguese citizenship tends to run roughly six to seven years once processing queues are counted. The fund's fee schedule clears at just over five years, comfortably inside that window, and because the vehicle is open-ended with indefinite duration there is no fund maturity to wait for and no extension risk of the kind closed-end funds carry.
The caveat is legal rather than financial. Your qualifying €500,000 must stay invested while the Golden Visa is active, so the earliest sensible redemption date is set by your immigration timeline, not by the day exit fees hit zero. Coordinate the two before you plan around daily liquidity.
What should US citizens know?
More good news than usual. The manager states it accepts US investors and advertises direct self-directed IRA (SDIRA) investment on its fund page, which is rare among Portuguese Golden Visa funds. Directory data additionally records QEF reporting as available, which matters enormously for the tax outcome.
Here is why. As a non-US pooled fund, this vehicle is a PFIC for US taxpayers. Under the default PFIC regime, gains can be taxed at top ordinary rates plus an interest charge. A QEF election, which requires the fund to issue annual information statements, converts that into annual pass-through taxation at normal rates, a far better result for most holders.
The QEF claim is currently sourced from directory data only; we have not found it confirmed in the manager's own fund documents. Before subscribing, ask 3 Comma Capital in writing for a sample PFIC annual information statement. If they cannot produce one, the US tax math changes materially.
FATCA reporting (Form 8938) and the annual PFIC form (8621) apply either way. In our experience, the difference between a fund that provides QEF statements and one that doesn't is often larger than the difference in headline fees, so model this with a US tax adviser before wiring anything.
How does it compare with other Golden Visa funds?
Within our database, this fund sits at the liquid, transparent end of the spectrum. Its €100,000 minimum matches the typical entry ticket for open-ended Golden Visa funds, and its 1.5% management fee sits inside the usual 1.5-2% range rather than below it. What is less common is the combination: daily dealing, published monthly reports with full performance tables, audited accounts, and explicit US-investor infrastructure in one package.
Performance so far is modest and consistent with the mandate. The June 2026 fund report shows 9.56% cumulative since the October 2024 launch, 1.94% over the first half of 2026, and roughly 4.7% over the trailing twelve months when compounded from the published monthly figures. The KIID's moderate scenario points to 6.4% per year over the recommended five-year period, while a 7-10% target return circulates in directory data without appearing in the manager's own documents. Past performance is no guide to the future, and capital is at risk.
If your priority is a purer bond exposure with a lower-volatility profile, the Heed Top Fund runs a comparable daily-liquidity structure without the crypto sleeve, and the Optimize Golden Opportunities fund offers a UCITS wrapper with no lock-up at all. The full comparison set is in our fund database.
What the fund has not published
Honesty about gaps matters more than a long feature list, so here is what the fund has not published. No target fund size is disclosed anywhere we have seen. The QEF reporting claim rests on directory data rather than fund documents, as flagged above. And the 7-10% return target comes from the same directory source; the manager's own materials only show KIID scenarios.
None of these is disqualifying. All three are questions you should put to the manager directly, in writing, during your subscription diligence.
Next step
If daily liquidity, a bond-led portfolio and workable US tax mechanics match what you are looking for, the sensible next move is a structured walkthrough of the documents rather than a leap. Roots can walk you through this fund's terms alongside comparable options, independently and without a sales agenda. Nothing here is investment, tax or immigration advice; it is information to make your own advised decision easier.
