Across the 65 markets in our Destination Factbooks, a foreign buyer can purchase freehold on the same terms as a citizen in 30. In the other 35 something stands in the way: a licence, a company structure, a fenced-off zone, or an outright bar.
That is the single most expensive thing to discover late. Below is every market we cover, grouped by what you may actually hold. The rule quoted under each is from that market's factbook; the grouping is ours.
The five regimes
- Open to foreign buyers — 30 markets
- Open with a licence or consent — 12 markets
- Open only in designated zones or schemes — 6 markets
- Freehold not available to foreigners — 12 markets
- Restricted or closed — 5 markets
Open to foreign buyers (30)
A foreign buyer may hold freehold on the same terms as a citizen. Some carry a footnote — border zones, agricultural land, a surcharge — but nothing stands between you and a normal purchase.
| Market | The rule |
|---|---|
| Argentina | Open; foreigners buy urban property freely. Rural/large or border land needs approval under the Rural Land Law (foreign caps apply). |
| Barbados | Open; no restriction on foreign buyers. Register incoming funds with the Central Bank to simplify future repatriation. |
| Belize | Fully open: foreigners buy fee-simple with the same rights as locals; no restrictions, no CGT. |
| Brazil | Open for urban property; rural land faces area caps and near-border restrictions for foreigners. Use a CPF tax number and local lawyer. |
| Cayman Islands | Fully open; foreigners buy freehold with no restriction and no need for a licence. Property ≥ ~$1.2m can support residency. |
| Chile | Fully open; foreigners buy freehold with the same rights as nationals (minor border-zone limits). |
| Colombia | Fully open; foreigners hold identical property rights. Register the FX inflow with a bank at purchase to ease later repatriation. |
| Costa Rica | Fully open (freehold titled land, same rights as locals). Beach 'maritime zone' (first 200 m) is concession/leasehold — verify title carefully. |
| Dominican Republic | Fully open; foreigners own freehold with the same rights as citizens. CONFOTUR projects offer transfer-tax and property-tax exemptions. |
| France | Fully open to foreign buyers via the notaire system. No restriction; mortgages available to non-residents. |
| Georgia | Open for residential/commercial freehold; agricultural land is restricted for foreigners. Property €100k+ can support residency. |
| Germany | Fully open; no restriction on foreign ownership. Financing readily available. |
| Greece | Fully open (border-region land needs permission). Golden-visa residency via property (€250k– €800k by zone). STR registered via AMA number. |
| Italy | Open to most foreigners (reciprocity applies; fine for US/UK/EU). Notarial deed system; mortgages available to non-residents. |
| Jamaica | Open; foreigners buy freehold with no restriction. Funds move via an authorised dealer/attorney escrow. |
| Japan | Fully open: foreigners buy land and buildings freehold, no visa/residency needed. (Some new national-security land-survey rules near bases/borders — minor for most buyers.) |
| Montenegro | Open; foreigners buy residential freely (agricultural/certain land via a local company). Euro-using EU candidate. €150k+ tax-value property supports temporary residence. |
| Morocco | Open for non-agricultural property; agricultural land is restricted for foreigners. Currency: register FX inflow to ease repatriation. |
| Panama | Fully open: foreigners own titled freehold with the same rights as nationals (except some near-border land). Watch 'ROP/possession rights' vs titled land — buy titled. |
| Paraguay | Fully open; foreigners buy with identical rights (passport + RUC tax number), no residency required. Simple SUACE permanent-residency programme. |
| Portugal | Fully open; foreigners buy freehold via NIF. Golden-visa property route ended 2023 (fund route remains). Local-lodging (AL) licence needed for STR — restricted in Lisbon/Porto zones. |
| Réunion | Fully open (French territory; EU-standard freehold). No special restriction; French mortgages available. |
| Saint Barthélemy | Fully open (French territory; EU-standard freehold). No special restriction on foreign buyers. |
| Spain | Fully open; foreigners buy freehold via NIE number. Golden-visa property route ended in 2025. STR requires a regional tourist licence — increasingly restricted. |
| São Tomé & Príncipe | Open (frontier): foreigners may buy under Portuguese-based law; the market is small and informal — strong local legal diligence essential. New CBI from ~$90k (fund contribution). |
| The Bahamas | Fully open; foreigners register purchases under the Landholding Act (permit needed only for large tracts or to rent out). Purchase ≥ $750k supports residency. |
| Turkey | Open; foreigners buy freehold (limits: max 30 ha per person and ≤10% of a district's area; some military zones barred). CBI from $400k property (3-year hold). |
| Turks & Caicos | Open; foreigners buy freehold. No annual property tax; a one-time stamp duty is the main cost. |
| United Kingdom | Fully open to foreign buyers (freehold/leasehold). Note: 2% non-resident SDLT surcharge and 5% second-home SDLT surcharge stack up. |
| United States | Open to foreigners with no restriction on residential purchases; financing available (typically 30– 40% down for non-residents). Diligence: county-level STR permits. |
Open with a licence or consent (12)
Freehold is available, but a permit, licence or ministerial consent comes first. Mostly routine, and mostly priced: several of these run to a percentage of the purchase.
| Market | The rule |
|---|---|
| Antigua & Barbuda | Open with a licence (Non-Citizen Land Holding Licence, ~5%), waived within designated/CBI developments. CBI real-estate from ~$300k. |
| Croatia | Open: EU citizens buy freely; non-EU (incl. US/UK) buy via reciprocity (generally granted) with ministry consent. Buying via a Croatian company is a common workaround. |
| Cyprus | Open with consent: non-EU buyers get routine Council of Ministers approval (usually one property). PR via €300k+ new-build. EU buyers unrestricted. |
| Dominica | Open; CBI route via approved real estate from $200k (hold 3 yrs) waives the licence; otherwise foreigners need an Alien Landholding Licence (~10%). |
| Egypt | Open with limits: foreigners may own up to two properties (≤4,000 m² total) for residence; Sinai land is restricted/leasehold. Red Sea and mainland resorts are open. |
| Gibraltar | Open to foreign buyers (some developments need government approval); no annual property rates on homes. Purchase does not grant residency — the Category 2 (Cat 2) HNWI route needs an approved home plus confirmed net worth (typically £2m+) and caps tax on the first ~£105k of income. |
| Grenada | Open with a licence (Alien Land Holding Licence ~10%), waived in CBI projects. CBI real-estate from ~$270k. |
| Jordan | Open with approval: foreigners buy with Council of Ministers consent (reciprocity); Aqaba's ASEZ is especially investor-friendly. JOD 200k+ held 5 yrs supports residency. |
| Malta | Open with conditions: outside SDAs an AIP permit limits you to one home (min value ~€275k apartment / ~€330k house) with no letting; SDAs allow multiple units and free rental. MPRP residency from qualifying property. |
| Saint Kitts & Nevis | Open with a licence, waived in CBI-approved projects. CBI real-estate from ~$325k (approved developments). |
| Saint Lucia | Open with a licence: foreigners need an Alien Landholding Licence (fee ~ up to 10%). CBI real-estate option from ~$200k (approved projects). |
| Seychelles | Reopened 2025 with sanction: foreigners may buy with government approval; minimum value ~SCR 10m (~$695k) for residential, plus a sanction fee. Eden Island is the main open-market enclave. |
Open only in designated zones or schemes (6)
Freehold is real but geographically fenced. You may buy inside named developments or above a price floor, and not outside them. The rule that catches people is not whether they may buy, but where.
| Market | The rule |
|---|---|
| Malaysia | Open (freehold) above state minimums: typically ~RM1m in KL and Penang island (lower on the mainland/other states). MM2H visa for long stays; mortgages available to foreigners. |
| Mauritius | Open via approved schemes (PDS, IRS, RES, Smart City, or apartments in ground-plus-2 buildings). $375k+ purchase = residency for the owner and family. |
| Oman | Open in ITCs only: foreigners buy freehold in designated Integrated Tourism Complexes (Al Mouj, Muscat Bay, Jebel Sifah, Yiti), which confer residency. |
| Qatar | Open in designated zones (The Pearl, Lusail, West Bay Lagoon) for freehold; other zones offer 99-year leasehold. Property ≥ $200k supports residency; ≥ $1m permanent residency. |
| Tanzania (Zanzibar) | Open in approved schemes: 2024 Investment Act allows 100% foreign ownership within Zanzibar Investment Authority projects; otherwise 99-year leasehold. Purchase can confer residency. |
| United Arab Emirates | Open for foreigners in designated freehold zones (Palm Jumeirah, Downtown, Marina, JVC, etc.). AED 2m+ property = 10-year Golden Visa. |
Freehold not available to foreigners (12)
No foreign freehold. Ownership runs through a lease, a company or a trust, and what you hold is a term of years or a shareholding rather than land. These are workable and widely used — but read the exit, not the entry.
| Market | The rule |
|---|---|
| Cambodia | Condos freehold (above ground floor, ≤70% foreign per building); no foreign land ownership (use long lease or local structures). Dollarized economy reduces FX risk. |
| Indonesia (Bali) | No foreign freehold: use leasehold (25–30 yrs, extendable) or a PT PMA company holding Hak Pakai/ HGB. Nominee ('borrowed name') structures are legally unprotected — avoid. |
| Kenya | Leasehold for foreigners: non-citizens may hold land on leases up to 99 years (freehold is citizen-only). Apartments/sectional title common on the coast. |
| Maldives | Leasehold only: no foreign freehold; islands/land leased (typically 50 years, extendable). July 2025 residence-by-investment from $250k; branded residences the main private route. |
| Mexico | Open via fideicomiso: foreigners can't hold direct title within 50 km of coast / 100 km of borders; a 50-year renewable bank trust gives full control. Inland, direct ownership is allowed. |
| Pacific Islands | Varies by nation: Fiji — freehold in designated zones + 99-yr leases (no residential freehold inside towns); French Polynesia — open French freehold; Cook Islands & Samoa — leasehold/customary only, no foreign freehold. |
| Philippines | Condos only (≤40% foreign per building); no foreign land ownership. Land via 25+25-year lease or a ≤40% foreign-owned company. Cash-driven market (no foreign mortgages). |
| Singapore | Condos/apartments only for foreigners, with a 60% ABSD on top of ~3–6% BSD; landed homes barred except Sentosa Cove (with approval). US citizens are ABSD-exempt under the FTA. Seller's stamp duty if sold within 4 years. |
| Sri Lanka | Leasehold for foreigners: no freehold land; 99-year leases and condo ownership (upper floors) are the routes. Structures via local company are common — take legal advice. |
| Thailand | Condos freehold (≤49% foreign per building); land/villas leasehold (30 yrs, renewable) or via a Thai-majority company. No foreign freehold land. |
| Vanuatu | Leasehold only: all land held on 75-year renewable leases (no foreign or local freehold). Citizenship-by-investment programme (contribution-based) runs alongside. |
| Vietnam | Condos/units for 50 years (renewable): ≤30% of a building may be foreign-owned; no foreign land freehold. Cash market (no foreign mortgages). |
Restricted or closed (5)
A non-resident foreign buyer is barred or heavily gated. Exemptions exist in every one of these and are the whole game: check which applies to you before anything else.
| Market | The rule |
|---|---|
| Australia | Restricted: foreign non-residents need FIRB approval and can generally buy only new dwellings (established-home purchases banned 2025–27). Foreign-buyer duty surcharges apply (up to 8%). |
| Canada | Restricted: a federal ban on non-Canadian purchases of residential property runs to Jan 2027, with exemptions (recreational properties, certain census areas, some visa-holders). Verify eligibility before offering. |
| Denmark | Highly restricted: non-residents usually need Ministry of Justice permission; summer-house purchases face additional limits even for EU citizens. Get legal advice first. |
| India | Restricted: non-resident foreign nationals cannot buy under FEMA; NRIs/OCIs may buy residential/ commercial (not farmland/ plantation). Foreigners resident 182+ days may buy with RBI conditions. |
| New Zealand | Highly restricted: non-residents generally cannot buy existing homes (OIA 2018). 2025 change allows Active Investor Plus visa-holders (~NZ$5m+ invested) to buy high-value homes; residents/ Aussies/Singaporeans have more access. |
What this table cannot tell you
Three things, and each has cost someone a purchase.
Your nationality changes the answer. Several of these regimes are reciprocal: Croatia, Italy and Jordan all grant on the basis of what your country offers theirs. "Open" here means open to the buyers we most often write for, not open to everyone.
Your residency changes it again. The bars in Canada, Australia and New Zealand fall on non-resident foreign buyers. Hold the right visa and several of them lift entirely.
Buying and letting are different permissions. Nothing in this table concerns whether you may rent the property out. That is a separate regime, it is tightening across Europe, and it is worth settling before you buy rather than after — see short-term rental rules by market.
These are planning bands, not advice, and ownership law moves. Every market above links to its factbook, where the rule sits alongside prices, taxes and what is actually available. Confirm anything you intend to act on with a lawyer in the country — not with the agent selling to you.