European limitations on foreign property purchases
In Europe, no law prohibits foreign citizens from buying property but certain countries have put limitations on this right, often with regards to residency rights, property type or buyer category. For example, only residents can buy real estate in Liechtenstein. In Andorra, Hungary, Denmark, Iceland, Poland and Malta, foreign investors can only buy property after receiving approval from the local authorities.
Nevertheless, most major European countries (e.g., France, Germany, Italy, Spain and UK) allow overseas investors to buy residential and commercial real estate with the same rights as local citizens.
| Belgium | Italy |
| Bulgaria | Monaco |
| Czech Republic | Netherlands |
| France | Norway |
| Germany | Portugal |
| Great Britain | Spain |
| Ireland | Sweden |
Even minor limitations can deter buyers, even if they had their heart set on a specific country. Still, these restrictions can often be avoided by creating a legal entity, for example. The most important thing is to have a reliable guide to help you. This article by Yulia Kozhevnikova, Tranio’s leading real estate expert, is here to do just that.
Territorial restrictions
National security is an important motivation in some countries that have prohibited foreign citizens from buying property in certain regions. In Greece, non-EU/EEA citizens are not allowed to purchase real estate near military bases and state borders (e.g. near the Balkan borders, Dodecanese archipelago, Crete, and Rhodes). Similar bans are in place in Turkey and Estonia.
National preference is also a European reality and there are countries where whole districts are closed to foreign buyers. Austria is an excellent example as there are limitations on half of the country’s federal states: Burgenland, Vienna, Lower and Upper Austria, Salzburg, Carinthia, Tyrol and Vorarlberg. Switzerland is also a frontrunner for national preference. In addition to extremely strict rules on residency and citizenship, the country has a famously restrictive “Lex Koller” property law, which limits foreign purchases to resort property in specific cantons: Valais, Vaud, Graubünden and Ticino. In Finland, foreign citizens cannot buy property on Åland Islands.
Agricultural land is particularly vital to Europe’s less developed economies in the East and Southeast — particularly in the Balkans and Baltic states. Estonia, Hungary, Latvia, Lithuania and Slovakia have taken steps to prohibit non-EU/EEA citizens from buying farmland. Albania, Croatia, Macedonia and Serbia (who are working towards EU integration) have imposed these restrictions on EU/EEA citizens as well.
Construction and surface area restrictions have been imposed in popular countries where development opportunities are limited by the lack of space. These are embodied by laws prescribing the maximum floor space a foreign citizen may buy and how much surface area they may build on. In addition to that, it is not uncommon to need permission from local authorities. In Switzerland, foreign citizens cannot buy property over 200 sq m in size or land exceeding 1,000 sq m. In Montenegro, purchases of land for development may not exceed 5,000 sq m.
Restrictions on companies and individuals
Overcoming restrictions on individuals is often possible by registering property to a company or creating a legal entity to make the purchase.
Restrictions on corporate real estate purchases have been put in place by some states to prevent abuse. In Turkey certain types of legal entities (e.g., funds and associations) cannot purchase real estate, but others can. In Switzerland, foreign companies can buy real estate if they are listed on the Swiss stock exchange and less than 33% of their shares are held by a non-resident.
Restrictions by nationality are less common but do exist. Turkey bans nationals of Armenia, Cuba, Syria and North Korea from buying real estate — but they can buy it through a company.
The following table contains these and other limitations not mentioned above.
Country |
Limitations on purchase of land |
Limitations on purchase of property |
Territorial limitations |
Limitations on companies and individuals |
|---|---|---|---|---|
Foreign citizens cannot buy agricultural lands but can lease it for 99 years |
— |
— |
— | |
Land buyers meet one of the criterion: — EU citizen — Austrian residence permit — land purchase in the name of a company registered in the EU—local authority permission There are exceptions to these rules that depend on the property |
Property buyers meet one of the criterion: — EU citizen — Austrian residence permit — land purchase in the name of a company registered in the EU — local authority permission There are exceptions to these rules that depend on the property |
— |
— | |
Foreign citizens cannot buy agricultural land, unless they create or buy it through a Croatian company |
Foreigners are required to obtain permission to purchase real estate from local authorities, though the procedure is a formality. If real estate is purchased by a legal entity, permission is not required. |
— | — | |
Non-EU/EEA citizens must request permission from the Council of Ministers of Cyprus to purchase real estate. Permission is easily obtained for property or plots under 3 donums (4,014 sq m). | Non-EU/EEA citizens cannot own more than one property. The second property can be purchased by a relative. | — | Only legal entities registered in Cyprus can buy commercial real estate there. | |
— | Foreigners can only buy property as their permanent residence or place of business if they meet one of the conditions: — foreigner previously lived in Denmark for at least five years; — EU citizen who works in Denmark; — citizen of a non-EU country who holds a valid residence or business permit in Denmark;. | — | — | |
Only Estonian, EU and EEA citizens can buy agricultural and forest land. In order to purchase more than 10 hectares, permission from the authorities is required | — | Non EU/EEA citizens cannot buy property near state borders. This land can only be owned, with permission from the authorities, by Estonian, EU and EEA citizens, as well as legal entities | — | |
— | — | Foreign citizens cannot buy real estate on Åland Islands. It is possible only with Åland right of residence, which is given to children of native residents and citizens of Finland | — | |
— | — | Non-EU/EEA citizens cannot purchase real estate close to military bases and state borders, in particular, on the East Aegean islands, on Dodecanese archipelago, in some areas of North Greece, Crete and Rhodes | — | |
Non-EU/EEA citizens cannot buy agricultural land, but can purchase houses with plot of up to 1 hectare | Foreigners should obtain permission to buy real estate from local authorities. Foreign citizens cannot purchase military and strategic objects, national monuments and objects located in reserves. | If the object is located on the territory of the Balaton, Heviz resorts, the authorities may not give permission for the purchase. | If the purchase is made by a company registered in Hungary, permission is not required. | |
Non-EU/EEA citizens cannot purchase agricultural and forest lands | — | Foreign citizens cannot purchase lands in border areas, in reserves, lands in the dune protection zone of the Baltic Sea and the Gulf of Riga, in the protective zones of water bodies, with the exception of areas where development is envisaged; lands on the territory of deposits. | — | |
Non-EU/EEA citizens cannot purchase agricultural land. Land can be leased from the state for 99 years or purchased through a legal entity registered in Lithuania. | — | — | — | |
Macedonia (FYROM) | Foreign citizens cannot purchase agricultural land in Macedonia but can lease it for up to 99 years with permission of the Ministry of Justice | — | — | — |
— | Special permission from the authorities: Acquisition of Immovable Property Act (AIP Permit). Property value cannot exceed the minimum annual value designated by the National Statistics Office — 137 000 euros for an apartment and 236 000 euros for a house in 2020. Foreigners cannot buy more than one property per family in Malta (except in Special Designated Areas). | AIP Permit is required for property purchases in all areas, except Special Designated Areas | — | |
Foreign individual can buy up to 5,000 sq m of land with a building; otherwise the land must be purchased in a company name | — | Foreigners cannot own plots of land in national parks, real estate at a distance of less than 1 km from the state border, objects on the islands, as well as objects of strategic importance. | — | |
Permission from the Ministry of Internal Affairs of Poland is required for the purchase of agricultural land with an area of more than 1 hectare. | Non-EU/EEA citizens have to obtain permission from the Ministry of Internal Affairs of Poland for buying a house with a plot. It is issued to those who can prove their connection to Poland (e.g,. temporary or permanent residence permit, Polish origin, marriage with a Polish citizen). Permission is not required for buyers of apartments. | For buying real estate located in the border area, it is necessary to get permission. | — | |
Agricultural land property purchase by non-EU/EEA citizens is regulated by international agreements on the basis of reciprocity | — | — | — | |
Foreign citizens and companies with more than 50% of foreign share capital cannot purchase agricultural land | — | Foreign companies and individuals cannot buy land near state borders and within the territory of a port | — | |
Foreign citizens cannot buy agricultural and forest land or property close to the land owned by the military | — | — | — | |
Foreign citizens cannot buy agricultural and forest land, except for EU citizens with Slovakian residence permits who have used this land for three years | — | — | — | |
Limitations on agricultural land | Non-EU citizens cannot buy real estate in Slovenia. Legal entities registered in Slovenia are allowed to buy real estate or land there. | — | — | |
Foreign citizens cannot buy land for construction. The maximum size of land with a building is 1,000 sq m | Foreign citizens need permission to buy resort property and cannot buy property for investment. Non-residents can only purchase one property for family; the floor space of property cannot exceed 200 sq m | Foreign citizens can buy property in certain cantons and according to available quota | Foreign companies cannot purchase real estate in Switzerland, however the purchase can be made in a Swiss company's name. Such company must be listed on the Swiss stock exchange and a non-resident cannot own more than 33% of its capital | |
Foreign citizens cannot buy more than 30 hectares of land | Non-residents can purchase real estate in Turkey the total area of which does not exceed 25,000 m² | Foreign citizens cannot buy or rent property on the territory of military bases. Foreign citizens cannot own more than 10% of real estate in one district or town | Foreign funds and associations cannot buy property in Turkey. Citizens of Armenia, Yemen, Cuba, Nigeria, Syria and North Korea are also prohibited from buying property — but can buy it via a legal entity |
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