Greytech III is the third vintage of an experienced Portuguese manager's mid-market strategy, and on strategy and Golden Visa eligibility the record is solid. The problem sits elsewhere: directory data suggests the fund does not accept US persons under Regulation S, its fees rest on a single unconfirmed source, and even its constitution date is disputed. For American applicants, one written question to the manager decides whether this fund belongs on the shortlist at all.
Key takeaways
- Directory data (low confidence) indicates Greytech III is not offered to US persons under Regulation S. Unconfirmed by the manager, but if true, the analysis ends there for US citizens.
- Golden Visa eligibility is manager-confirmed: at least 60% in Portuguese companies, no real estate, €500,000 qualifying subscription against a €100,000 fund minimum.
- Reported fees of 1.75% management and 22.5% carry are single-source. At face value, a €500,000 ticket pays roughly €52,500 in management fees over six years and €87,500 over the full term.
- Closed-end structure: 10-year fund life, 5-year investment period, no interim redemptions. Capital comes back via exits and liquidation.
- Iberis Capital manages over €600m for roughly 1,300 investors and cites more than 300 successful Golden Visa applications across its funds.
What does Greytech III actually invest in?
The strategy is the best-documented part of the fund, because it comes from the manager itself. Greytech III makes opportunistic growth and buyout investments in solid Portuguese mid-market SMEs with EBITDA between €2 and €10 million, concentrated in tradable sectors, particularly industry and technology. The manager argues this segment is structurally short of capital, which is the core of the investment thesis.
The structuring is more distinctive than the sector focus. Deals are done as minority or majority stakes through equity, senior equity or debt-equity hybrids, built around downside protection and a preferred return rather than pure equity upside. The portfolio plan is 6 to 8 investments at €3 to €12 million per company, deployed over a 5-year investment period inside a 10-year closed-end life.
One structural point deserves emphasis: this is a young blind pool. The subscription period reportedly runs until January 2028, and no performance has been published, which is expected for a recently launched closed-end fund. Even the vintage is fuzzy. One directory implies constitution around mid-2025, based on a stated end date of July 2035, while another lists 2026. The conflict is unresolved, a small but telling data-quality note. Your underwriting target is the team: partners Luís Quaresma, Diogo Chalbert, João Henriques and David Pinheiro, with Salvador Leite Castro heading investor relations.
Behind them sits Iberis Capital, legally Iberis Semper SCR, S.A., founded in 2017, managing over €600 million for roughly 1,300 investors, and citing more than 300 successful Golden Visa applications across its funds. The manager markets expected returns above 15% IRR across its funds, though directory data lists 8 to 15% per annum for this fund specifically. Either way, these are targets, not expectations, and no vintage-level track record for Greytech I or II is public.
Can US citizens invest at all?
Directory data indicates Greytech III is not available to US persons as defined by Regulation S under the Securities Act of 1933. This is a low-confidence, aggregator-sourced claim: a second directory records US acceptance as merely "not confirmed", and the manager has not verified either version. If the exclusion is accurate, US citizens and tax residents cannot subscribe regardless of where they live, and nothing else in this review matters for them. Confirm in writing with Iberis Capital before doing any further work on this fund.
It's worth being precise about what a Reg S exclusion means in practice, because the label understates how absolute it is. Regulation S lets non-US funds raise capital offshore without SEC registration, on the strict condition that they do not sell to US persons. That definition is wide: it captures US citizens and green card holders living anywhere, US-resident individuals, and many US-controlled trusts and entities. A fund relying on the exemption will usually decline the subscription at the application stage, because a single US investor can complicate the entire offering.
The knock-on effect is that the usual US tax questions become moot. There is no published PFIC status, no QEF reporting policy, no IRA route, and if the fund won't take US money, none of that needs answering. If the manager instead confirms it does accept US persons, the entire PFIC and QEF analysis reopens, and you should demand written answers on annual information statements before subscribing. Standard FATCA and foreign-asset reporting would apply in any case. In our experience, the fastest path is one email to investor relations asking two questions: do you accept US persons, and on what US tax reporting basis?
What would the reported fees cost you?
Every number here is single-source and hedged accordingly. One directory lists a 1.75% annual management fee and 22.5% carried interest, re-verified against that same directory but confirmed nowhere else. The manager does not publish fees. No hurdle rate and no subscription fee have been disclosed. On a €500,000 Golden Visa subscription, and assuming 1.75% applies to the full amount throughout, the arithmetic runs:
| Cost line | Reported rate | 6-year hold | 7-year hold | Full 10-year term |
|---|---|---|---|---|
| Management fee | 1.75% p.a. | €52,500 | €61,250 | €87,500 |
| Carried interest | 22.5% of profits | depends on exits | depends on exits | depends on exits |
Because capital is committed for the full closed-end life, the honest column is the last one: roughly €87,500, or 17.5% of your subscription, before any carry. The fee basis is also unpublished. PE funds often charge on committed capital early and invested capital later, so the true figure could land either side of that estimate.
The 22.5% carry sits above the 20% private equity standard, and with no published hurdle you don't know whether it bites from the first euro of profit or only above a minimum return. That single term can move your net outcome by tens of thousands of euros. One more wrinkle: the manager markets "no out-of-pocket fees" for investors, which usually means costs are charged inside the fund rather than invoiced separately. Ask what the phrase covers, because it is a marketing line, not a fee schedule.
Can you exit before year 10?
Plan on no. Greytech III is closed-end, with a 10-year fund life confirmed by the manager and a 120-month lock-up listed in directory data, consistent with a stated end around July 2035. No interim redemption mechanism has been published, and consequently no redemption fee exists either. Capital comes back through distributions as the 6 to 8 portfolio companies are sold, then through liquidation at term. Extension terms are not published, so the fund could run longer than 10 years; that is normal for the asset class and a standard question for the manager.
How does that map onto the citizenship timeline? Reasonably, in one direction. Naturalisation realistically takes six years or more, and the €500,000 qualifying investment must stay in place throughout the residency process. A 10-year fund will not force a mid-application reinvestment the way a shorter vehicle might. The asymmetry runs the other way: your passport question will likely be settled years before your capital is, and the preferred-return structuring softens but does not remove that. If committed illiquidity for a decade is a dealbreaker, this is the wrong category of fund, full stop.
How does Greytech III compare?
Within the funds database, Greytech III sits close to the centre of the Golden Visa private equity cluster on entry terms and slightly rich on carry. Its €100,000 minimum matches the typical fund-route floor, and the reported 1.75% management fee lands inside the usual 1.5 to 2% band. The reported 22.5% carry is above the 20% norm for the category, which makes the unpublished hurdle rate the term to chase hardest.
Among our pilot funds, the closest structural neighbour is Explorer V: another 10-year closed-end Portuguese buyout fund, with a higher reported minimum and a longer manager track record, but similarly thin public disclosure. The opposite pole is the Optimize Portugal Golden Opportunities Fund, an open-ended vehicle with published documents and regular liquidity. Greytech III's differentiators within the PE group are its downside-protected deal structures and the manager's unusually deep Golden Visa processing experience. Its differentiator against the whole database, if the directory data holds, is a hard US exclusion that most competing funds do not impose.
What the fund has not published
An honest review has to list what nobody outside the manager currently knows. For Greytech III, the open items are substantial:
- US eligibility. The Reg S exclusion is aggregator-sourced only and not confirmed by the manager. This is the single most decision-relevant gap for American readers.
- Economics. The 1.75% fee and 22.5% carry are single-source, and the hurdle rate, fee basis, subscription fee and distribution policy are all unpublished.
- Scale. Neither target fund size nor current AUM has been disclosed.
- Infrastructure. Custodian and auditor are not identified in any public source.
- Registry. The CMVM registration number (reported as 2267) and ISIN (reported as PTICRDIM0002) each come from a single directory and have not been checked against the CMVM registry.
- Vintage. The constitution date conflicts across sources, 2025 versus 2026, and remains unresolved.
None of this is disqualifying for a privately marketed PE fund. It is simply the checklist you take into the fund regulations and the subscription documents, because "normal for the asset class" and "safe to sign unverified" are different standards. Past performance, where any is eventually cited, is no guide to future results, and capital is at risk throughout.
Next step
If you're not a US person and you want mid-market Portuguese private equity from a manager with genuine Golden Visa processing depth, Greytech III earns a place on the shortlist, pending the document checks above. If you are a US person, resolve the Regulation S question first, in writing, before spending another hour on this fund. Roots can walk you through the fund regulations and the verification checklist independently before you engage the manager. This article is information, not investment, tax or immigration advice.
