IMGA GV Portuguese Equities is one of the few Golden Visa funds offering pure listed-equity exposure with daily pricing: at least 65% Portuguese listed companies, run by IM Gestão de Ativos, Portugal's largest independent asset manager. The structural appeal, daily NAV and no capital calls, is real. So are the costs of the wrapper: a 2.5% entry fee, 1.95% annual management and a 3.5% exit fee inside five years, on a fund that held just €6,414,483 five months after launch. The manager's own documents also disagree with each other on the entry fee, which deserves attention before any wire.
Key takeaways
- Open-ended listed-equity fund effective 23 December 2025: at least 65% Portuguese equities, up to 35% US and other OECD markets, at least 85% in equities at all times, SFDR Article 8.
- Unit Class G terms: €100,000 minimum, 1.95% management fee plus 0.10% depositary fee, 2.5% entry, 3.5% exit within five years, no performance fee.
- Daily NAV and daily dealing with settlement in roughly four to six working days; the 3.5% early-exit fee acts as a soft five-year lock.
- Tiny so far at €6,414,483 (29 May 2026); unit prices imply roughly +10.4% since launch, a derived estimate, not an official figure.
- Document inconsistencies to resolve: the English KID states 1.75% entry against 2.5% everywhere else, and risk ratings of 4 of 7 (KID) versus 3 (factsheet).
What does the fund actually invest in?
Listed shares, almost exclusively. The mandate requires at least 65% in equities of Portuguese companies, held directly or indirectly, with up to 35% in equities listed on US and other OECD markets, and at least 85% of assets in equities at all times. Management is active with no benchmark, under SFDR Article 8 ESG exclusions, and the stated aim is to reflect the aggregate performance of the Portuguese equity market. David Afonso manages the fund with António Dias as co-manager.
That makes this a transparency play by Golden Visa standards. Unlike the closed-end venture funds that dominate the category, everything here is exchange-listed and priced daily, with Bison Bank, S.A. as depositary and Forvis Mazars as auditor. CMVM authorised the fund on 9 October 2025 and it became effective on 23 December 2025; Unit Class G carries ISIN PTIGGHHM0008.
It also makes this a concentrated bet. Portugal's listed market is small, and a fund required to keep the large majority of assets in it will move with a handful of domestic names. The KID classifies the fund at 4 of 7 on the risk scale, though the May 2026 factsheet shows 3, one of several places where the manager's documents do not quite line up. The current portfolio composition has not been published in machine-readable form.
What do the fees cost you over a Golden Visa hold?
| Cost item | Unit Class G |
|---|---|
| Entry fee | 2.5% (prospectus, fund page, factsheet); English KID states 1.75% |
| Management fee | 1.95% per year |
| Depositary fee | 0.10% per year |
| Performance fee | None |
| Exit fee | 3.5% within 5 years of subscription; 0% thereafter |
On a €500,000 Golden Visa subscription, entry at 2.5% costs €12,500 up front. Management at 1.95% runs about €9,750 a year, roughly €58,500 over six years or €68,250 over seven, with the 0.10% depositary fee adding around €500 annually, all before compounding and market movement. Budget somewhere near €71,000 to €81,000 in entry-plus-recurring charges across a six-to-seven-year hold. An exit inside five years would add €17,500.
There is no performance fee, so the manager's economics come entirely from the fixed charges. What do you get for them? The manager publishes no target return; directory data circulates an 8% expected-return figure, which we treat with low confidence since it appears nowhere in the manager's materials. The stated objective is a long-term premium over money-market instruments.
The manager's documents disagree on the entry fee: the English KID shows 1.75%, while the prospectus, fund page and factsheet all state 2.5%. The 1.75% figure matches the sister GV corporate debt fund, suggesting a documentation slip. On €500,000 the difference is €3,750, so get the applicable fee schedule confirmed in writing before subscribing.
Liquidity, the exit fee and the citizenship timeline
Dealing is daily in both directions, at daily NAV, with cash settlement in about four working days per the fund page (the Portuguese factsheet says up to the sixth working day). There is no formal lock-up and no fund maturity: the vehicle is open-ended with indeterminate duration, so nothing expires and nothing gets extended. Income is not distributed; the fund accumulates.
The five-year exit fee is the timeline mechanism. Naturalisation for Golden Visa holders realistically takes about six to seven years from application once processing is included, and the qualifying €500,000 must stay invested while the permit runs. By the time you are legally free to redeem, the 3.5% fee window will normally have closed on its own. The economic risk sits elsewhere: this is an equities fund, and the value of your qualifying investment at the end of the hold depends on the Portuguese stock market, not on a fee table.
What should US citizens know?
The published record is silent. Neither the manager nor directory data says whether US persons may subscribe, and there is no PFIC, QEF or IRA information anywhere in the fund's materials. As a non-US pooled fund it would generally be a PFIC for US taxpayers, and IMGA does not advertise QEF reporting for its mutual funds, so the default expectation should be the punitive PFIC regime with annual Form 8621 filings unless IMGA confirms otherwise.
Two questions therefore belong in writing before this fund reaches a US person's shortlist: are US persons accepted at all, and will QEF annual information statements be provided? The up-to-35% sleeve of US-listed equities in the portfolio has no bearing on either answer. FATCA reporting on Form 8938 applies regardless of how the PFIC question resolves.
How does it compare with other Golden Visa funds?
Within our database this fund occupies an unusual niche: daily-liquidity, pure listed equities, from an institution managing over €5 billion and CMVM-registered since 1989. Most Golden Visa vehicles are closed-end private funds with capital calls, multi-year lock-ups and 20%-style carry; this one has none of that. Its €100,000 minimum is typical for the category, while the 1.95% management fee sits at the upper edge of the usual 1.5-2% band, and the 2.5% entry plus 3.5% early-exit fees are a heavier bookend than several open-ended peers charge.
Two comparisons sharpen the picture. Within IMGA's own shelf, the retail IMGA Ações Portugal fund offers similar Portuguese equity exposure without the GV wrapper's terms, a fact worth weighing if visa eligibility is not your driver. And within the GV range itself, the sister IMGA GV Portuguese Corporate Debt fund swaps equity risk for investment-grade credit at a 1.7% fee. The fund's own weaknesses are youth and scale: €6,414,483 in assets and a few months of history, with roughly +10.4% implied by unit prices since launch, a derived figure rather than an official one. The wider set is in our fund database. Past performance is no guide to future results, and capital is at risk.
What the fund has not published
The gaps, listed plainly. The CMVM registration number 2345 comes from directory data and has not been verified against the registry. US-investor acceptance and PFIC/QEF practice are unknown. There are no official performance figures, only the unit-price estimate above. The current portfolio composition was not machine-readable in the documents we fetched. And it is not confirmed whether the manager provides a formal Golden Visa eligibility legal opinion, since the prospectus never mentions the visa. None of these is a verdict; each is a diligence question whose weight depends on your situation and risk appetite.
Next step
If you want your Golden Visa capital in transparent, daily-priced listed equities and can live with concentrated Portuguese market risk for five-plus years, this fund is one of the few direct expressions of that idea. Roots can walk you through its terms alongside the debt-based alternatives, independently and with no sales agenda. This article is information, not investment, tax or immigration advice.
