Canada has extended its restrictions, Australia has prolonged its freeze on existing homes, and South Korea has introduced occupancy requirements. Meanwhile, New Zealand and Saudi Arabia have created new avenues for foreign buyers.
For cross-border purchasers, the headline classification of a market is only part of the picture. Two factors are particularly important: how foreign ownership is restricted and whether those restrictions are becoming tighter or more permissive.
Property markets range from jurisdictions offering unrestricted freehold ownership to those that effectively prohibit foreign residential purchases. Between these extremes are systems involving condominium ownership quotas, geographic exclusion zones, government approval requirements, additional taxes and duties, and property rights that expire after a fixed period.
The overview below examines major markets according to their current level of access for foreign buyers and recent policy direction. All figures and rules described were current as of August 2026.
Markets Where Foreign Buyers Generally Have the Same Ownership Rights as Locals
In the most open jurisdictions, holding a foreign passport does little to limit what a buyer can purchase.
The United States has no federal prohibition on foreign residential property ownership. Foreign buyers can purchase homes in any state and hold title in their own names.
There are, however, tax considerations. Under the federal Foreign Investment in Real Property Tax Act (FIRPTA), 15% of the sale price is generally withheld when a foreign owner disposes of U.S. real estate. Some states also impose transfer taxes on non-resident buyers.
The United Kingdom likewise permits foreign nationals to purchase residential property. In England and Northern Ireland, however, foreign buyers are subject to a 2% stamp duty surcharge in addition to the standard rates. This increases the cost of acquisition but does not prevent the purchase.
Most of Western Europe follows a similarly open model. Portugal, Italy, France and Ireland do not impose nationality-based restrictions on residential purchases, while Greece also allows foreigners to buy property on the same basis.
Recent policy changes in these countries have focused more heavily on immigration benefits than on ownership itself. Portugal removed real estate as a qualifying investment for its golden visa in 2023, while Greece increased the investment threshold for investor residency to €800,000 in Athens, Thessaloniki and the most sought-after islands.
As a result, foreigners can still purchase residential property in these markets, but using that investment as a route to residence has become more difficult or, in some cases, no longer possible.
Several markets outside Europe also maintain broad access. Japan does not generally restrict foreign ownership of residential property or land, placing it among the relatively few major Asian markets where foreign and domestic buyers are treated alike.
Georgia, Panama and Brazil likewise permit foreigners to acquire urban property on a freehold basis. Brazil's restrictions primarily concern rural and border areas.
Markets Where Foreigners Can Own Apartments but Not the Land
Another common model permits foreign ownership of individual residential units while reserving ownership of the underlying land for citizens. In these jurisdictions, both the ownership structure and the proportion of a building that foreigners can acquire become important.
Thailand is a prominent example. Foreigners may own condominium units outright and register title in their own names, but foreign ownership within a building cannot exceed 49% of its total floor area.
Once that quota has been reached, buyers generally have to consider alternatives such as a 30-year lease or a Thai corporate structure. Foreigners cannot directly own land, meaning villas are typically acquired through long-term lease arrangements or with ownership limited to the building rather than the land.
Proposals have been made to increase the condominium ownership ceiling to 75% and extend lease terms to 99 years. Neither proposal had become law by August 2026.
The Philippines operates under a comparable framework. Its Condominium Act prevents a unit from being transferred to anyone other than a Filipino citizen or a corporation that is at least 60% Filipino-owned. Foreign nationals are also prohibited from owning land.
Vietnam revised its foreign property ownership framework through the 2023 Housing Law and 2024 Land Law. Under the resulting rules, foreigners can own apartments for renewable 50-year periods.
The ownership limits remain specific: foreign buyers can hold no more than 30% of the units in a building and no more than 250 houses within a single ward. Ownership of the underlying land-use right does not pass to the foreign buyer.
Countries With Geographic Restrictions on Foreign Purchases
Some jurisdictions permit foreign ownership generally but impose special restrictions on particular areas.
Mexico provides a clear example. Foreigners can directly acquire property throughout most of the country, including Mexico City and inland areas.
The constitutional restriction applies within the so-called restricted zone: land located within 50 kilometres of the coast or 100 kilometres of an international border. Direct foreign ownership is prohibited there. Instead, foreign purchasers can acquire coastal or border property through a fideicomiso, a bank trust that holds legal title on their behalf, or through a Mexican company.
Turkey also allows foreign buyers to purchase property across much of the country and offers a citizenship route for those investing $400,000 in real estate. Certain military and security areas remain off-limits, while individual foreign buyers are subject to a 30-hectare ownership limit and a 10% ceiling at district level.
Turkey abandoned its previous reciprocity-based system in 2012 and replaced it with a list of eligible countries. Nationals of certain countries remain prohibited from purchasing property. Consequently, a transaction that is permissible in Istanbul may not necessarily be available to the same buyer in another part of the country.
Markets Where Approval or Higher Costs Create an Additional Barrier
Some countries allow foreign purchases but place another hurdle between the buyer and the transaction, either through formal government approval or through additional costs substantial enough to affect demand.
Switzerland applies some of the strictest rules. Under the federal Lex Koller framework, most non-resident foreigners cannot freely acquire residential property, and the number of holiday homes that can be sold to foreigners is also subject to annual limits.
In April 2026, the Federal Council launched a public consultation on draft measures that would tighten the framework further. In general, foreigners can purchase a Swiss home only after obtaining Swiss residence.
Singapore takes a different approach. Foreigners can purchase condominiums, but residential acquisitions are subject to a substantial financial surcharge: an additional buyer's stamp duty of 60%.
Purchasing landed residential property requires government approval, which is rarely granted outside the Sentosa Cove area. U.S. nationals and citizens of certain treaty countries receive local treatment for the purposes of the duty.
Malaysia uses a minimum purchase price as a principal restriction. Foreign buyers generally must purchase property above a specified threshold, commonly one million ringgit, although the amount differs between states. Most transactions also require approval from the relevant state authorities.
South Korea has introduced an additional requirement based on how the property will be used. Rules that came into force on August 26, 2025 require foreign purchasers to obtain a permit before buying property in Seoul, 23 cities and counties in Gyeonggi Province, and seven districts of Incheon.
Once approved, buyers must move into the property within four months and retain ownership for at least two years. The designation was initially scheduled to remain in force through August 25, 2026, although it can be extended. Its status should therefore be checked before entering into a transaction.
India bases access largely on the buyer's status. Non-resident Indians and holders of Overseas Citizen of India cards can freely acquire residential and commercial property.
Foreign nationals without Indian origin generally cannot purchase a home without approval from the country's central bank, while nationals of several neighboring states face outright restrictions.
Markets That Restrict Most Foreign Residential Purchases
At the most restrictive end are countries where foreign buyers generally cannot purchase residential property at all.
Canada introduced a prohibition on residential purchases by foreign nationals and foreign-controlled entities at the beginning of 2023 and subsequently extended it through January 1, 2027.
The prohibition applies only to properties located within a census metropolitan area or census agglomeration, leaving certain smaller communities and rural areas outside its scope. There are also exceptions for some students, temporary workers and refugee claimants, as well as buildings containing four or more units.
Australia took a different route by suspending foreign purchases of established residential housing in April 2025. The federal budget announced in May 2026 extended the measure through June 2029, significantly beyond its original March 2027 expiry date.
Foreign buyers can still access newly built housing subject to the required approval. This maintains Australia's established policy of directing foreign investment toward additional housing supply rather than existing residential stock.
China is also highly restrictive for most foreign purchasers. In general, a foreign national may acquire only one residential property for personal use and must first have lived, worked or studied in the country for at least one year.
Indonesia does not permit foreigners to hold freehold title. The strongest form of ownership, Hak Milik, is reserved for Indonesian citizens. Foreign buyers can instead use rights of use, leases or Indonesian corporate structures, none of which provides outright ownership of the land.
New Zealand has also belonged to this group since 2018, when it introduced a broad prohibition on foreign residential purchases. Recent reforms, however, demonstrate that these restrictions are not necessarily permanent.
Where Foreign Property Access Is Expanding
The long-term trend toward tighter foreign-buyer restrictions is no longer consistent across markets. Some governments are now creating targeted exceptions or reopening selected categories of investment.
New Zealand's 2018 restrictions already contained exemptions for Australians, Singaporeans and purchasers of new apartments. In 2025, Parliament approved further amendments allowing holders of an Active Investor Plus visa to purchase homes valued at NZ$5 million or more.
The reform took effect in March 2026 following an earlier delay. It preserves the broader restrictions on foreign residential ownership while creating a specific pathway for high-value investors.
Saudi Arabia has also expanded access. A new law that came into effect in January 2026 allows foreigners to purchase property in designated areas. Foreign residents can own one home, while additional restrictions apply in Makkah and Madinah.
The new framework replaced a previous system under which independent property purchases were largely limited to people holding Saudi Arabia's premium residency.
The policy direction is not uniformly toward greater access, however. Spain continues to permit foreigners to purchase property, but ended its golden visa on April 3, 2025.
The Spanish government has also proposed a tax of up to 100% for non-EU, non-resident buyers. The proposal stalled in Parliament due to insufficient support and, as of March 2026, had not been debated.
This leaves Spain formally open to foreign property ownership while policymakers pursue measures that could make the market less attractive to the same category of international buyers being targeted elsewhere.
Why the Legal Mechanism Matters More Than the Label
Foreign property markets cannot always be meaningfully divided into simply "open" and "closed" categories. The legal mechanism behind the restriction can make a substantial difference.
Two countries may both appear open to foreign buyers, for example, while offering very different ownership rights. One may provide unrestricted freehold title, while another may impose acquisition taxes or other costs that materially affect the transaction.
The same applies to restrictive markets. A country classified as closed may already be moving toward greater access, while another jurisdiction nearby may be introducing additional limitations.
The mechanism determines what form of ownership is available and where. The direction of policy determines whether those conditions are likely to remain in place when the transaction takes place.
Foreign-buyer rules can also change after they are introduced. Canada, for example, narrowed aspects of its prohibition in 2023 following concerns raised by provincial and municipal authorities and industry participants about the breadth of the restrictions.
The recent changes in New Zealand and Saudi Arabia demonstrate that a market closed to foreign buyers today may not remain so indefinitely.
Before transferring funds for an overseas property purchase, confirm three points in writing: whether the transaction provides freehold ownership or only a lease or other limited right; whether foreign buyers are permitted to purchase the specific property and in that particular location; and whether the applicable rules are due to change.
If you're planning to obtain a residence permit, invest in a foreign country, or purchase real estate abroad, I invite you to book an individual consultation with me.
During a personal online meeting, we'll discuss your situation in detail, answer your questions, and develop a clear, step-by-step action plan tailored to your goals.
For cross-border purchasers, the headline classification of a market is only part of the picture. Two factors are particularly important: how foreign ownership is restricted and whether those restrictions are becoming tighter or more permissive.
Property markets range from jurisdictions offering unrestricted freehold ownership to those that effectively prohibit foreign residential purchases. Between these extremes are systems involving condominium ownership quotas, geographic exclusion zones, government approval requirements, additional taxes and duties, and property rights that expire after a fixed period.
The overview below examines major markets according to their current level of access for foreign buyers and recent policy direction. All figures and rules described were current as of August 2026.
Markets Where Foreign Buyers Generally Have the Same Ownership Rights as Locals
In the most open jurisdictions, holding a foreign passport does little to limit what a buyer can purchase.
The United States has no federal prohibition on foreign residential property ownership. Foreign buyers can purchase homes in any state and hold title in their own names.
There are, however, tax considerations. Under the federal Foreign Investment in Real Property Tax Act (FIRPTA), 15% of the sale price is generally withheld when a foreign owner disposes of U.S. real estate. Some states also impose transfer taxes on non-resident buyers.
The United Kingdom likewise permits foreign nationals to purchase residential property. In England and Northern Ireland, however, foreign buyers are subject to a 2% stamp duty surcharge in addition to the standard rates. This increases the cost of acquisition but does not prevent the purchase.
Most of Western Europe follows a similarly open model. Portugal, Italy, France and Ireland do not impose nationality-based restrictions on residential purchases, while Greece also allows foreigners to buy property on the same basis.
Recent policy changes in these countries have focused more heavily on immigration benefits than on ownership itself. Portugal removed real estate as a qualifying investment for its golden visa in 2023, while Greece increased the investment threshold for investor residency to €800,000 in Athens, Thessaloniki and the most sought-after islands.
As a result, foreigners can still purchase residential property in these markets, but using that investment as a route to residence has become more difficult or, in some cases, no longer possible.
Several markets outside Europe also maintain broad access. Japan does not generally restrict foreign ownership of residential property or land, placing it among the relatively few major Asian markets where foreign and domestic buyers are treated alike.
Georgia, Panama and Brazil likewise permit foreigners to acquire urban property on a freehold basis. Brazil's restrictions primarily concern rural and border areas.
Markets Where Foreigners Can Own Apartments but Not the Land
Another common model permits foreign ownership of individual residential units while reserving ownership of the underlying land for citizens. In these jurisdictions, both the ownership structure and the proportion of a building that foreigners can acquire become important.
Thailand is a prominent example. Foreigners may own condominium units outright and register title in their own names, but foreign ownership within a building cannot exceed 49% of its total floor area.
Once that quota has been reached, buyers generally have to consider alternatives such as a 30-year lease or a Thai corporate structure. Foreigners cannot directly own land, meaning villas are typically acquired through long-term lease arrangements or with ownership limited to the building rather than the land.
Proposals have been made to increase the condominium ownership ceiling to 75% and extend lease terms to 99 years. Neither proposal had become law by August 2026.
The Philippines operates under a comparable framework. Its Condominium Act prevents a unit from being transferred to anyone other than a Filipino citizen or a corporation that is at least 60% Filipino-owned. Foreign nationals are also prohibited from owning land.
Vietnam revised its foreign property ownership framework through the 2023 Housing Law and 2024 Land Law. Under the resulting rules, foreigners can own apartments for renewable 50-year periods.
The ownership limits remain specific: foreign buyers can hold no more than 30% of the units in a building and no more than 250 houses within a single ward. Ownership of the underlying land-use right does not pass to the foreign buyer.
Countries With Geographic Restrictions on Foreign Purchases
Some jurisdictions permit foreign ownership generally but impose special restrictions on particular areas.
Mexico provides a clear example. Foreigners can directly acquire property throughout most of the country, including Mexico City and inland areas.
The constitutional restriction applies within the so-called restricted zone: land located within 50 kilometres of the coast or 100 kilometres of an international border. Direct foreign ownership is prohibited there. Instead, foreign purchasers can acquire coastal or border property through a fideicomiso, a bank trust that holds legal title on their behalf, or through a Mexican company.
Turkey also allows foreign buyers to purchase property across much of the country and offers a citizenship route for those investing $400,000 in real estate. Certain military and security areas remain off-limits, while individual foreign buyers are subject to a 30-hectare ownership limit and a 10% ceiling at district level.
Turkey abandoned its previous reciprocity-based system in 2012 and replaced it with a list of eligible countries. Nationals of certain countries remain prohibited from purchasing property. Consequently, a transaction that is permissible in Istanbul may not necessarily be available to the same buyer in another part of the country.
Markets Where Approval or Higher Costs Create an Additional Barrier
Some countries allow foreign purchases but place another hurdle between the buyer and the transaction, either through formal government approval or through additional costs substantial enough to affect demand.
Switzerland applies some of the strictest rules. Under the federal Lex Koller framework, most non-resident foreigners cannot freely acquire residential property, and the number of holiday homes that can be sold to foreigners is also subject to annual limits.
In April 2026, the Federal Council launched a public consultation on draft measures that would tighten the framework further. In general, foreigners can purchase a Swiss home only after obtaining Swiss residence.
Singapore takes a different approach. Foreigners can purchase condominiums, but residential acquisitions are subject to a substantial financial surcharge: an additional buyer's stamp duty of 60%.
Purchasing landed residential property requires government approval, which is rarely granted outside the Sentosa Cove area. U.S. nationals and citizens of certain treaty countries receive local treatment for the purposes of the duty.
Malaysia uses a minimum purchase price as a principal restriction. Foreign buyers generally must purchase property above a specified threshold, commonly one million ringgit, although the amount differs between states. Most transactions also require approval from the relevant state authorities.
South Korea has introduced an additional requirement based on how the property will be used. Rules that came into force on August 26, 2025 require foreign purchasers to obtain a permit before buying property in Seoul, 23 cities and counties in Gyeonggi Province, and seven districts of Incheon.
Once approved, buyers must move into the property within four months and retain ownership for at least two years. The designation was initially scheduled to remain in force through August 25, 2026, although it can be extended. Its status should therefore be checked before entering into a transaction.
India bases access largely on the buyer's status. Non-resident Indians and holders of Overseas Citizen of India cards can freely acquire residential and commercial property.
Foreign nationals without Indian origin generally cannot purchase a home without approval from the country's central bank, while nationals of several neighboring states face outright restrictions.
Markets That Restrict Most Foreign Residential Purchases
At the most restrictive end are countries where foreign buyers generally cannot purchase residential property at all.
Canada introduced a prohibition on residential purchases by foreign nationals and foreign-controlled entities at the beginning of 2023 and subsequently extended it through January 1, 2027.
The prohibition applies only to properties located within a census metropolitan area or census agglomeration, leaving certain smaller communities and rural areas outside its scope. There are also exceptions for some students, temporary workers and refugee claimants, as well as buildings containing four or more units.
Australia took a different route by suspending foreign purchases of established residential housing in April 2025. The federal budget announced in May 2026 extended the measure through June 2029, significantly beyond its original March 2027 expiry date.
Foreign buyers can still access newly built housing subject to the required approval. This maintains Australia's established policy of directing foreign investment toward additional housing supply rather than existing residential stock.
China is also highly restrictive for most foreign purchasers. In general, a foreign national may acquire only one residential property for personal use and must first have lived, worked or studied in the country for at least one year.
Indonesia does not permit foreigners to hold freehold title. The strongest form of ownership, Hak Milik, is reserved for Indonesian citizens. Foreign buyers can instead use rights of use, leases or Indonesian corporate structures, none of which provides outright ownership of the land.
New Zealand has also belonged to this group since 2018, when it introduced a broad prohibition on foreign residential purchases. Recent reforms, however, demonstrate that these restrictions are not necessarily permanent.
Where Foreign Property Access Is Expanding
The long-term trend toward tighter foreign-buyer restrictions is no longer consistent across markets. Some governments are now creating targeted exceptions or reopening selected categories of investment.
New Zealand's 2018 restrictions already contained exemptions for Australians, Singaporeans and purchasers of new apartments. In 2025, Parliament approved further amendments allowing holders of an Active Investor Plus visa to purchase homes valued at NZ$5 million or more.
The reform took effect in March 2026 following an earlier delay. It preserves the broader restrictions on foreign residential ownership while creating a specific pathway for high-value investors.
Saudi Arabia has also expanded access. A new law that came into effect in January 2026 allows foreigners to purchase property in designated areas. Foreign residents can own one home, while additional restrictions apply in Makkah and Madinah.
The new framework replaced a previous system under which independent property purchases were largely limited to people holding Saudi Arabia's premium residency.
The policy direction is not uniformly toward greater access, however. Spain continues to permit foreigners to purchase property, but ended its golden visa on April 3, 2025.
The Spanish government has also proposed a tax of up to 100% for non-EU, non-resident buyers. The proposal stalled in Parliament due to insufficient support and, as of March 2026, had not been debated.
This leaves Spain formally open to foreign property ownership while policymakers pursue measures that could make the market less attractive to the same category of international buyers being targeted elsewhere.
Why the Legal Mechanism Matters More Than the Label
Foreign property markets cannot always be meaningfully divided into simply "open" and "closed" categories. The legal mechanism behind the restriction can make a substantial difference.
Two countries may both appear open to foreign buyers, for example, while offering very different ownership rights. One may provide unrestricted freehold title, while another may impose acquisition taxes or other costs that materially affect the transaction.
The same applies to restrictive markets. A country classified as closed may already be moving toward greater access, while another jurisdiction nearby may be introducing additional limitations.
The mechanism determines what form of ownership is available and where. The direction of policy determines whether those conditions are likely to remain in place when the transaction takes place.
Foreign-buyer rules can also change after they are introduced. Canada, for example, narrowed aspects of its prohibition in 2023 following concerns raised by provincial and municipal authorities and industry participants about the breadth of the restrictions.
The recent changes in New Zealand and Saudi Arabia demonstrate that a market closed to foreign buyers today may not remain so indefinitely.
Before transferring funds for an overseas property purchase, confirm three points in writing: whether the transaction provides freehold ownership or only a lease or other limited right; whether foreign buyers are permitted to purchase the specific property and in that particular location; and whether the applicable rules are due to change.
If you're planning to obtain a residence permit, invest in a foreign country, or purchase real estate abroad, I invite you to book an individual consultation with me.
During a personal online meeting, we'll discuss your situation in detail, answer your questions, and develop a clear, step-by-step action plan tailored to your goals.