Can Foreigners Own Property Abroad? Freehold, Leasehold and Use Rights

Ask what a country allows foreigners to own and most answers collapse into "freehold or leasehold," as though every market offers the same two choices in different proportions. It does not. Some countries hand a foreign buyer the deed to the land itself, but only inside lines drawn on a map. Others will never let a foreigner own land at all, only a fixed share of the floor area in a building, and that share can simply run out. Others grant something closer to a personal permit than a property right, one that can expire alongside your visa rather than your ownership. The question worth asking before comparing price across borders is not freehold or leasehold. It is what happens to this asset if your resident status changes, because that is where the four structures below actually diverge.

Freehold means owning the land and whatever is built on it, indefinitely, with the right to sell, lease, mortgage or pass it on. Leasehold means holding the right to occupy and use land or a building for a fixed term, typically decades, after which the right reverts to the landowner unless renewed. A use right sits apart from both: it grants permission to occupy and benefit from a property, sometimes registered and transferable, but tied to conditions, commonly a residence or visa status, that a straightforward leasehold is not.

The United Arab Emirates lets a foreign buyer, of any nationality, hold full freehold title, including the land itself, but only inside more than 60 designated freehold zones across Dubai. Inside those zones there is no residency requirement to buy and no cap on how many properties one buyer can hold; the title is absolute, transferable, mortgageable and inheritable. Outside them, the position reverses entirely: freehold is reserved for UAE and Gulf Cooperation Council nationals, and a foreign buyer is limited to leasehold contracts running up to 99 years. Freehold and Leasehold Zones in Dubai: Where Foreigners Can Buy maps where that line actually falls, and Buying Property in Dubai as a Foreign Buyer: The Complete Guide covers the rest of the process.

Thailand does not offer foreigners freehold land under any circumstance, zoned or otherwise. What it offers instead is a freehold share of a condominium building, capped by the Condominium Act at 49% of the building's total registered floor area held by foreign owners collectively. That cap is measured in area, not units: a single large penthouse consumes as much of the quota as several small studios, and a popular building can simply run out of foreign-eligible floor area regardless of how much a buyer is willing to pay. Once the quota is full, the remaining route for a foreigner is a registered land lease, capped at 30 years with the option to renew. Thai authorities have also tightened enforcement against nominee structures, where a foreigner holds land through a Thai company or proxy owner in substance rather than in form, with stricter monitoring of buildings approaching their foreign quota. Condominium Quota: The One Freehold Route for Foreigners in Thailand and Thai Land Leases: The 30-Year Rule and Its Limits cover both routes, and Nominee Ownership Structures and Why They Fail explains why the proxy-company workaround is a real legal exposure rather than a shortcut.

Indonesia goes further than Thailand: there is no freehold route for a foreign individual at all, not even a capped one. What a qualifying foreigner can hold directly, in their own name, is Hak Pakai, a registered right to use, granted for an initial term of up to 30 years and renewable in stages to a maximum of roughly 80 years combined. Holding it requires a valid Indonesian stay permit, a KITAS or KITAP, and the right is tied to that status: if the permit lapses and is not renewed, the Hak Pakai title is exposed to reverting. This is the structure behind most of what gets marketed to foreign buyers in Bali. The alternative structures, a long-term lease or a foreign-owned investment company known as a PT PMA, carry their own trade-offs rather than avoiding this one. Owning Property in Indonesia as a Foreigner: The Complete Guide and PT PMA: Setting Up a Foreign-Owned Company to Hold Property cover both paths in full, and Residency and Visa Routes Tied to Property Ownership explains this same visa-dependency pattern across other markets.

Sri Lanka draws the line differently again. The Land (Restrictions on Alienation) Act blocks a foreigner from holding freehold land directly, but a foreigner can buy a condominium apartment outright, full freehold, provided the purchase price is paid in through an inward foreign remittance before the transfer deed is executed. A persistent misconception dates the position wrong by close to a decade: a land lease tax once charged specifically to foreign buyers was repealed by the Land (Restrictions on Alienation) Amendment Act No. 3 of 2017, yet still turns up in cost estimates as though it were current. Can Foreigners Own Land in Sri Lanka? The Current Position and The 99-Year Lease Route in Sri Lanka cover the land-lease alternative for anyone who wants ground rather than a unit.

Ownership type and running cost are not separate questions. Dubai charges a one-time Dubai Land Department transfer fee of 4% of the purchase price at registration, and beyond that levies no annual property tax, no personal income tax and no capital gains tax on the sale, whatever structure the property is held in. That combination, a real cost at the point of transfer and effectively none afterward, is part of why zoned freehold in Dubai gets compared so often to markets where the reverse is true: modest transfer costs but a running annual charge for as long as the property is held. Thailand and Sri Lanka both apply transfer fees and, in Thailand's case, an annual land tax on top; Indonesia layers a land and building tax alongside a separate transfer tax on acquisition. None of these numbers are interchangeable across countries or even across the four structures within one country, so Thai Property Transfer Fees and Annual Land Tax, Sri Lankan Property Taxes and Transfer Costs for Foreigners and Property Tax in Indonesia: PBB, BPHTB and Rental Income Tax carry the actual figures rather than a comparison table that would go stale the next time any one of the four revises a rate.

Line the four up by what happens when your circumstances change rather than by price, and the real differences show up. Dubai's freehold, once bought inside a zone, does not depend on your visa status at all; a title holder can lose residency and keep the property without the ownership itself being at risk. Indonesia's Hak Pakai is the opposite case: the property right and your immigration status are bound together by design, so a visa lapse is a property risk, not just an inconvenience. Thailand sits in between, freehold ownership of a condo unit is not visa-dependent, but the quota that made the freehold available in the first place is a fixed, shared resource that can close to new foreign buyers regardless of anyone's individual circumstances. Sri Lanka's condominium exemption behaves like Dubai's zoned freehold, secure once acquired, but it applies only to apartments, never to the land under a house.

None of the four is simply better than the others; they solve different problems for different buyers. A buyer who wants an asset fully independent of their own residency plans is looking for something like Dubai's zoned freehold or Sri Lanka's condominium exemption. A buyer planning to live in the country long-term, with a stable visa path already in hand, may find Indonesia's Hak Pakai perfectly workable despite the dependency, since the visa was going to be renewed anyway. What breaks down is assuming any one of these patterns generalises to the next country on a shortlist. Due Diligence When Buying Property in Another Country and Leasehold Abroad vs Freehold at Home: The Trade-Off Nobody Prices go further into how to actually weigh that trade-off once a specific market is on the table, and Financing a Property Purchase Abroad covers a separate constraint that interacts with all four: many lenders price a loan differently depending on which of these structures the collateral actually is.

• UAE Dubai Land Department: designated freehold zones and ownership rights for foreign nationals
• Thailand Condominium Act: 49% foreign ownership quota by registered floor area; Land Code: 30-year registered lease limit for foreigners
• Indonesia Government Regulation on Hak Pakai for foreign individuals: term structure and residence-permit condition
• Sri Lanka Land (Restrictions on Alienation) Act, and its condominium exemption and remittance requirement for foreign buyers