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Key Restrictions and Regulations for Foreign Real Estate Buyers in Different Countries

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This article is essential for anyone considering buying real estate abroad. You'll find a summary of laws on the sale of residential and commercial properties to foreigners, links to detailed transaction procedures, as well as contact information of real estate experts who can offer advice.

Many countries want to attract investments by making it easier for foreigners to buy houses, apartments, and business spaces. Even Middle Eastern and Southeast Asian states, which remained closed to global capital for many years, have changed their policies.

In some regions, transactions with foreign buyers exceed 25% of total sales. This is the case in Cyprus or the UAE, and in resort areas of Turkey, Spain, or Georgia.

Nevertheless, various restrictions on the sale of real estate to foreigners are still in effect.

Classification of Restrictions on Real Estate Sales to Foreigners

  • By Type of Property: Agricultural lands are often under restrictions.
  • By Number and Size of Properties: Some countries limit the number and size of properties that foreigners can own.
  • By Ownership Type: For instance, some places allow foreigners to buy real estate only under long-term lease rights (leasehold, usufruct).
  • By Owner's Status: Restrictions may apply to citizens of certain countries based on reciprocity or special laws. Some nations allow foreigners to be engaged in real estate transactions only if they have a residence permit or have registered a legal entity.
  • By Location: Many countries prohibit foreigners from buying properties in specific areas: near the borders, critical infrastructure, national parks, etc. Some countries have designated areas/complexes where properties are sold to foreigners without restrictions.
  • By Price: To protect local citizens' interests, some countries introduce price restrictions, and foreigners are not allowed to purchase real estate below the minimum threshold.
  • By Transaction Structure: It is often necessary to obtain permission to purchase from local authorities. In some countries this procedure is formal, bu it may be strict in others.  Foreigners may also face special conditions, such as need to conduct transactions through a trust or hire a certified appraiser, or simply pay higher taxes, etc.
  • By Purpose of Use: There may be restrictions for foreign buyers related to renting out properties or using them as a “second home”

Albania

In Albania, foreigners do not have the right to purchase agricultural land and forest land with an area of more than 1 thousand square meters. m. If you need to buy just such a plot, you will have to open a legal entity in the country under which you can register the transaction. Another option is to arrange a long-term lease of land for up to 99 years.

All other types of residential and commercial real estate in Albania are sold without restrictions. Moreover, purchasing a home gives you the right to obtain a residence permit.

Austria

Austria has tight restrictions for foreign real estate buyers.

Before making a deal, you must get special permission from local authorities. It's not always granted, and many are denied.

Each federal state has its own approach. It is relatively easy for foreigners to purchase real estate in the regions of Lower Austria, Upper Austria, Styria, Carinthia, and Burgenland. But at the ski resorts - in the lands of Tyrol, Salzburg and Vorarlberg - the rules are stricter.

The permission to purchase real estate in Austria is issued if the transaction is of social or economic interest for the federal state. Social interest refers to the foreigner's close ties to Austria, for example if he has a residence permit. Economic interest may be manifested in the intention to establish a business in Austria. Therefore, it is easier for a foreigner to obtain permission to implement an investment project to build a hotel in the Alps than to purchase an ordinary chalet. Each case is considered individually.

Foreign buyers without a residence permit in Austria can purchase real estate under the name of a company registered in the European Union. However, this method is justified only when purchasing expensive objects.

Permissions to buy agricultural land are rarely granted to foreigners.

Bosnia and Herzegovina

Foreigners can purchase real estate under the terms of a reciprocity agreement between Bosnia and their country of origin. If there's no agreement, the deal can only be registered to a legal entity.

Foreigners are allowed to buy residential and commercial real estate, as well as land with an area of no more than 500 square meters. If the land exceeds 500 square meters, it must be registered to a company opened by the buyer. The purchase of arable land and properties in protected natural areas is prohibited.

Bulgaria

In Bulgaria, there are restrictions on buying properties with land plots, such as private homes in villages and other standalone buildings that come with a plot of land. A foreigner, not an EU citizen, can only own land through a legal entity established in Bulgaria. Theoretically, one could lease land from the state, but properties are usually not sold without the land. The building can be registered to an individual.

There are exceptions. In some organized resort complexes, villas are sold without land plots (the land remains the property of the management company), and in such cases, the transactions can be concludede with an individual.

Real estate in Bulgaria without land – such as apartments or commercial spaces in business centers – is sold to foreigners without any restrictions.

Canada

As of January 1, 2023, there is a law prohibiting foreigners without a residence permit from purchasing real estate in Canada. Exceptions are made for those working in Canada – they are allowed to buy no more than one residential property, and for foreign companies expanding their Canadian business.

In many provinces, foreigners are also barred from purchasing agricultural and recreational lands, and additional taxes are imposed on them.

Croatia

Since 2014, foreigners have the right to buy real estate in Croatia as an individual; previously, transactions were registered only in the name of local companies. However, they are required to obtain permission to purchase from the Ministry of Justice. The procedure is formal and standardized, but it takes a lot of time - up to six months. In practice, foreigners enter into a purchase and sale agreement, use the property and wait for a permit to be issued. They rarely refuse.

It is not necessary to obtain permission from the Ministry of Justice if the buyer is an EU citizen or the property is registered under a legal entity established in Croatia. There is also a ban on the sale of agricultural land and forests to foreigners.

Cyprus

Non-EU citizens must request permission from the Council of Ministers to conduct real estate transactions. This procedure is a simple formality, and applications are approved.

A foreign citizen can own no more than two properties totaling no more than 4014 square meters. To bypass this limitation, foreigners can open a company and register the property in the name of the company or simply transfer the rights to family members.

Buying property in Cyprus worth at least €300,000 grants the right to apply for permanent residency.

Denmark

Foreigners without a residence permit who have not resided in the country for five years must obtain permission to purchase property in Denmark from the Ministry of Justice. This rule also applies to legal entities that do not have a representative office in Denmark.

EU citizens are exempt from from the need to obtain permission for a transaction subject to a number of conditions. For example, if they intend to use the property as a permanent residence or plan to conduct business in Denmark.

Egypt

In the Sinai Peninsula (Sharm el-Sheikh, etc.), a foreigner has the right to purchase real estate on a long-term lease for up to 99 years (leasehold, the term usufruct is also used). The ban on private property in this region was established in 2005.

In the African part (for example, in Hurghada), real estate is registered in full freehold ownership (freehold). In the case of state registration of the transaction and execution of a green contract (this is an optional stage), foreigners can purchase no more than two freehold properties in Egypt, which must be retained in ownership for at least five years.

Since 2023, foreigners must pay for property in foreign currency and conduct transactions through state banks.

Estonia

There are some restrictions on the purchase of real estate in Estonia for non-European Union citizens. These restrictions apply to land transactions.

• It is prohibited to purchase land, including private houses built on it, in border areas (this also applies to maritime borders), some islands such as Saaremaa and Hiiumaa, and in the area of Lake Peipus. These restrictions can be circumvented by registering the property under a legal entity, but prior permission for the transaction is required.

• Only EU citizens can buy agricultural land and forest land with an area of 10 hectares or more as an individual.

Finland

Since January 1, 2020, foreigners from non-EU or non-European Economic Area (EEA) countries need permission from the Ministry of Defense to buy property in Finland (primarily referring to private houses, as apartments are sold as shares in housing companies and are not subject to this law).

The restriction applies throughout Finland, except for the Åland Islands, where transactions with foreigners are completely prohibited.

Greece

Non-European buyers of real estate in Greece must request special permission from local authorities for transactions in border regions, including some Greek islands near Turkey, like Rhodes and Kos. This procedure is formal, and the applicants are rarely denied. A notary submits the application to the municipality, and permission is usually granted within ten days.

Hungary

Citizens from non-EU countries must obtain permission from the local municipality to buy property in Hungary. Unlike Austria, this procedure is formal, and refusals are extremely rare. A licensed Hungarian lawyer, who handles the permission application, can complete the process in about two months.

Permission is NOT required if the property is registered to a legal entity or transferred to the new owner as an inheritance.

Only EU citizens can purchase agricultural lands and state-protected properties.

Indonesia

Foreign buyers face significant restrictions on real estate in Indonesia. Firstly, there are price limits that foreigners must adhere to. For instance, on the island of Bali, apartments must cost more than 2 billion rupiah ($126,000) to be eligible for foreign purchase.

Secondly, properties are usually transferred to foreigners under long-term use (hak pakai) or long-term lease (hak sewa) agreements, with terms up to 80 years. The law secures the rights to use the property, but it does not constitute full private ownership.

Israel

In Israel, there are two types of lands: private and state-owned. Foreigners can freely buy properties located on private land without any permissions from authorities.

Buying property on state lands comes with some restrictions:

  • Only Israeli citizens or foreigners eligible for repatriation under the "Law of Return" can complete transactions.
  • Permission from the Land Administration is required (except for apartments in condominiums).

To get this permission, one needs to provide a convincing motivation letter showing the potential contribution the applicant can make to Israel. Another option is to register a company and/or a non-profit organization, mainly consisting of Israeli citizens on its board.

Italy

There are no restrictions on real estate purchases in Italy for foreigners, provided the principle of reciprocity is respected. This means Italy applies the same requirements to foreign investors that their countries apply to Italians.

For example, Swiss citizens cannot buy a house larger than 200 sqm in Italy, Kazakhs without residency cannot purchase property as individuals. Following the 2023 ban on foreigners buying property in Canada, Canadians faced challenges in completing most transactions in Italy.

Latvia

Buying properties without land is unrestricted. For transactions involving land, such as private homes or land for construction, you'll need permission from the local government, which has the pre-emptive right to purchase. The procedure is formal, and if the property's price is close to the market value, obtaining permission takes no more than two weeks.

Foreigners from outside the European Union are prohibited from purchasing certain categories of real estate in Latvia: agricultural and forest lands; lands in border areas; lands in nature reserves and other protected areas.

Lithuania

Foreigners can't own farm lands in Lithuania. But, they can lease such plots for 99 years. They can also register the land in the name of a company in Lithuania to get around this rule.

Foreigners also face restrictions on purchasing properties in border regions, dune areas, and coastal zones.

In 2023, Lithuania introduced special restrictions for Russian citizens: they can buy property in the country only if they have a residence permit.

Malta

Foreigners wishing to buy property in Malta must obtain a special permit to carry out the transaction (acquisition of immovable property, AIP). It will be issued subject to a number of conditions: the object must be used only for permanent residence (cannot be rented out), it is not a cultural property, its value exceeds the established limit (in 2023 - from €143 thousand).

You do not need to obtain permission if you purchase real estate in luxury residential complexes (special designated areas, SDA): the cost of objects there is higher than the minimum amount, but there are no restrictions for foreigners.

Mexico

Foreigners are prohibited from buying property in a “restricted zone” – within 100 kilometers from the international border and 50 kilometers from the sea coast. Transactions with foreign buyers in these regions go through, but are registered through a trust fund. In this case, the bank acts as a trustee, and the trust retains ownership of the property, giving the foreigner all rights to dispose of the property.

An alternative form of acquisition of real estate by foreigners is the purchase of a property by a Mexican company, which can be 100% owned by a foreigner.

Mexico also has restrictions on the sale of agricultural and forestry land to foreign individuals and legal entities.

Montenegro

Foreigners cannot own certain types of real estate in Montenegro, such as agricultural land, forests, land plots in national parks, cultural monuments, properties within one kilometer of the state border, or on islands, objects of strategic importance.

As an individual, a foreigner can purchase a land plot of up to 5,000 square meters with a building on it. Purchasing land without construction is possible only if the site is included in a detailed urbanization plan, that is, construction on it is permitted according to an approved project.

Oman

Since 2007, foreigners can fully own properties in Oman within Integrated Tourism Complexes (ITCs). These government-approved megaprojects feature advanced infrastructure and various property types, including Al Mouj, Muscat Bay, Muscat Hills, and Jebel Sifah; in 2023, licenses were issued for 19 more complexes.

In other regions of Oman, foreigners can acquire properties on a long-term lease basis (usufruct) for up to 99 years with certain restrictions. For example, in a multi-story building, there must be at least four floors, and the property value must exceed 45,000 Omani rials ($117,000).

There's also a list of regions where non-Omanis are prohibited from owning land and property, such as islands, locations near royal palaces, and ancient archaeological areas.

Serbia

The right to purchase from foreigners arises on the principle of reciprocity, that is, if Serbian citizens are allowed to buy objects on the territory of these states, then their citizens can become owners of real estate in Serbia.

Foreigners are entitled to purchase any type of property except for agricultural land (including forests, fields, gardens, orchards, vineyards, meadows, pastures, ponds, and swamps) and properties in protected areas.

Slovenia

Non-EU citizens cannot buy property in Slovenia according to the law. They must conduct the transaction through a company they have registered in the country. Once they set up a company, they can own any type of property in any region without restrictions.

 Switzerland

The purchase of real estate in Switzerland by foreigners is limited and strictly regulated. Only holders of a residence permit have the right to buy housing for permanent residence. All other foreigners have access to resort properties (subject to prior permission from the cantonal authorities, which is not easy to obtain) or commercial real estate.

In Switzerland, there are also restrictions on the number and size of properties that can belong to foreigners and the ways they can be used.

 Thailand

In Thailand, land ownership is permitted only  to local citizens or registered companies in the country. When purchasing a villa, foreigners can either register the land under a legal entity or lease it for up to 99 years. The building itself can be registered in full private ownership.

Foreigners can own condominium apartments in freehold ownership, subject to a quota: developers can sell up to 49% of the units in the complex to foreign investors, while the remaining units can only be registered in leasehold to foreigners.

Turkey

Turkey still maintains some restrictions for foreign property buyers.

• The maximum area of land that can be owned is 30 hectares (before 2012 it was 2.5 hectares).

• Foreigners are not allowed to buy property in areas bordering Syria (Mardin, Hatay, Kilis).

• There are certain restricted zones considered strategically important for the country's security.

• Citizens of Armenia, Cyprus, Cuba, Yemen, Nigeria, Syria, and North Korea cannot buy property in Turkey.

UAE 

Citizens of any country can buy property in the UAE, but there are territorial restrictions. Only UAE and Gulf Cooperation Council (GCC) citizens and companies registered in these countries can enter into transactions anywhere.

Foreigners of non-Arab origin can buy homes and commercial properties in specific freehold regions in the UAE. Property ownership is full and private, allowing for sale, rental, gifting, or inheritance.

From 2006 to 2008, free zones were established in Dubai, Umm Al-Quwain, Ras Al-Khaimah, and Ajman; in 2019, Abu Dhabi opened freehold for foreigners, and in 2022, Sharjah followed. Now, foreigners have access to nearly all regions of the country.

USA 

As of July 1, 2023, the state of Florida has implemented Senate Bill 264, which prohibits foreigners from China and several other countries from acquiring agricultural land and any real estate located near critical infrastructure. This restriction does not apply to properties in other states.

Both individuals and legal entities can conduct transactions, and they can purchase properties of any category in the United States.

 Vietnam

Foreigners can buy up to 10% or no more than 250 detached villas in one administrative district (whichever is less) and no more than 30% of the units in a condominium. Foreign buyers are allowed to purchase apartments in residential commercial projects across the country, where there are no restrictions for foreigners.

In Vietnam, there are restrictions on land ownership, which can only be transferred to foreigners on a leasehold (long-term lease) basis. Leaseholders have rights to exchange, transfer, sublease, inherit, gift, and use properties as collateral.

 Photo by VJ Von Art on Unsplash

Quoting conditions of Prian.info materials

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