The Horizon Fund is the crypto outlier of the Golden Visa fund route: an open-ended Portuguese alternative fund from Lisbon-based Octanova SCR that pairs roughly 65% Portuguese fixed income with up to 35 to 40% in Bitcoin, Ethereum and Solana. It offers monthly liquidity, which is rare, but charges hedge-fund economics of 2% management and 20% performance over a 2% hurdle, on top of a 2% entry fee. The honest framing: this is the highest-risk-appetite option in our pilot set, and it only makes sense for investors who would hold Bitcoin exposure anyway.
Key takeaways
- A barbell of ~60 to 65% Portuguese fixed income (PSI-20 issuers) and ~35 to 40% digital assets held via ETFs or regulated custodians. The bond core is what keeps it Golden Visa eligible.
- Fee stack is hedge-fund-like: 2% entry, 2% p.a. management, 20% performance above a 2% hurdle. Roughly €70,000 to €80,000 in fixed charges on €500,000 over 6 to 7 years, before any carry.
- Open-ended with monthly NAV and monthly redemptions on 15 days' notice, but a reported 3% fee on exits within the first five years.
- US persons are reportedly accepted (single directory source, unconfirmed by the manager); no PFIC or QEF information is published.
- Launched November 2024: no audited track record, AUM undisclosed, and the target size is stated as €50m in one document and €100m in another.
What does the fund actually invest in?
Two things that rarely share a wrapper. The core, around 60 to 65% of the portfolio, is fixed income from Portuguese issuers, primarily companies listed on the PSI-20, capped at 10% per issuer. The satellite, around 35 to 40%, is large-cap digital assets: Bitcoin, Ethereum and Solana, accessed through ETFs or regulated crypto custodians rather than held directly. The manager markets it as the first regulated Portuguese fund to combine these asset classes.
The design logic is straightforward. The Portuguese bond core keeps the fund above the 60% Portuguese-securities threshold that Golden Visa eligibility requires, with no real estate exposure. The crypto sleeve is what actually drives the return profile. One aggregator reports an expected IRR of 15 to 20% per year, but that figure does not come from the manager, depends almost entirely on crypto performance, and should be read as a scenario, not a plan.
Be clear-eyed about what a 35 to 40% digital-asset weight means. In a severe crypto drawdown, that sleeve alone could take a large bite out of NAV regardless of how the bonds behave, and the bond core adds its own Portuguese interest-rate and credit risk. There is no track record to lean on: the fund launched in November 2024 (ISIN PTEBEEHM0002) and no audited performance has been published. Capital is at risk, and past crypto returns are no guide to future results.
Size this position as if it were a direct Bitcoin allocation, because to a meaningful degree it is. A €500,000 Golden Visa subscription implies roughly €175,000 to €200,000 of effective crypto exposure at the stated allocation. If you would not comfortably hold that as a standalone position through a 50%+ drawdown, this is the wrong fund for your visa capital, however appealing the monthly liquidity looks.
What do the fees cost over a Golden Visa hold?
This is where the fund demands the most scrutiny. The investor presentation term sheet puts Category A investors at 2% annual management and a 20% performance fee on returns above a 2% benchmark hurdle; one directory adds that a high-water mark applies. There is also a 2% subscription fee on entry, and a reported 3% fee on redemptions within the first five years. Notably, none of these fees is published on the manager's own site.
On a €500,000 Golden Visa subscription, assuming a flat NAV for simplicity and a hold long enough to avoid the early-exit fee:
| Cost line | Rate | 6-year hold | 7-year hold |
|---|---|---|---|
| Entry fee (once) | 2% | €10,000 | €10,000 |
| Management fee | 2% p.a. | €60,000 | €70,000 |
| Early redemption fee | 0% after year 5 | €0 | €0 |
| Fixed charges | €70,000 | €80,000 |
That is roughly 14 to 16% of capital before the performance fee even enters the picture. And the carry can be substantial precisely because the strategy is volatile: with only a 2% hurdle, a strong crypto year hands 20% of nearly the entire gain to the manager. If the fund returned 15% in a year, the low end of the aggregator-reported target, the performance fee would claim around 2.6% of NAV for that year alone. You keep the downside in full; the upside is shared. That trade is defensible only if you genuinely want this exposure.
How do liquidity and the lock-up fit the citizenship timeline?
Unusually well, on paper. The fund is open-ended with an indeterminate duration, monthly NAV, and monthly subscriptions and redemptions on 15 days' notice. That removes the classic mismatch of closed-end Golden Visa funds, whose fixed 6 to 10 year terms can wind up before your naturalisation completes or extend beyond it. Here, you stay invested as long as the residency and citizenship process requires, then redeem at NAV.
The five-year early-exit fee is the catch, and it is a deliberate one. Redemptions within the first five years reportedly incur a 3% charge, which on €500,000 is €15,000. Combined with the Golden Visa requirement to keep the qualifying amount invested throughout the residency process, practical liquidity in the early years is more theoretical than real. Since naturalisation realistically takes six years or more, the fee schedule and the visa timeline point to the same conclusion: plan for a 6 to 7 year hold, and treat the monthly redemption window as an emergency exit, not a feature you expect to use.
What should US citizens know?
The headline is positive but thinly sourced. Directory data records the fund as confirmed to accept US persons, re-verified in July 2026. That is a single source: neither the manager's site nor the investor presentation says so. We rate it medium confidence. If you are American, get the acceptance confirmed in writing before you do anything else.
The tax picture is entirely unpublished. As a non-US pooled fund, the Horizon Fund would ordinarily be expected to fall under the PFIC regime, but the manager discloses nothing about PFIC status, QEF reporting or IRA eligibility. Without a QEF election, PFIC treatment of a volatile, crypto-heavy fund can be genuinely punitive, and the digital-asset sleeve adds mark-to-market complexity on top. Standard FATCA and foreign-asset reporting obligations apply regardless. Obtain the manager's US tax position in writing and model the after-tax outcome with a US adviser before subscribing. If US-friendliness is your priority, other funds in the database publish far more.
How does it compare with other Golden Visa funds?
On headline terms it looks conventional: the €100,000 fund minimum matches the typical Golden Visa fund ticket, and the €500,000 visa threshold applies as everywhere else. Everything else about it is unusual. Most eligible funds are closed-end venture capital or private equity vehicles with management fees around 1.5 to 2%; the Horizon Fund is open-ended, monthly-dealing, professional-investor-only, and stacks a full 2 and 20 with an entry fee on top. You are paying private-fund economics for exposure you could partly replicate with listed instruments, in exchange for the regulated Golden Visa wrapper and the eligibility attestation.
Within our pilots, the natural comparisons are the liquid open-ended funds. The 3CC Golden Income fund is a corporate-bond-led open-ended vehicle with daily dealing and a digital-asset sleeve alongside equity and gold, at a 1.5% management fee: a materially tamer version of a similar idea. The Optimize Golden Opportunities fund offers daily liquidity with no performance fee at all, via listed Portuguese equities and bonds. Against either, the Horizon Fund is the aggressive end of the spectrum: more return potential if crypto performs, more fee drag and far deeper drawdown risk if it does not. The full set of terms across every fund we track is at the funds database.
What hasn't been disclosed?
The gaps here are material, so name them. Current AUM is not published. Even the target size conflicts across the manager's own materials: the site says €50 million, the early-2025 investor presentation says €100 million, and we treat the site figure as current. The full fee schedule appears in the investor presentation but not on the manager's site. PFIC status and QEF reporting for US investors are unpublished. The distribution policy is unknown. The CMVM registration number, reported as 2122, has not been verified against the CMVM registry, and direct links to the factsheet and management regulation PDFs could not be extracted from the manager's site. None of this is disqualifying for a fund this young, but every item belongs on your pre-subscription question list, starting with the target-size discrepancy.
Next step
If you have already decided you want Bitcoin-linked exposure and would rather hold it inside a regulated, Golden Visa-eligible Portuguese wrapper, the Horizon Fund is the database's clearest expression of that view. The sensible next move is an independent walkthrough of the term sheet, the fee arithmetic above and the open questions before you speak with Octanova; Roots can work through those documents with you line by line. This article is information, not investment, tax or immigration advice, and capital is at risk.
