# Foreign Real Estate Purchase for Non-Residents: Rules, Taxes, Structures

> London, Italy, France, Portugal, Spain, Singapore, Bulgaria, Austria, the UAE, Greece, Cyprus: what non-residents need for a transaction, entry tax from 2% to 60%, whether purchase grants residency, and how to structure ownership.

Author: Maria Plotnikova — Lawyer, Family Office (https://wiki.private.law/en/authors/plotnikova)
Last modified: 2026-08-21T11:04:00.000Z
Canonical: https://wiki.private.law/en/foreign-real-estate-purchase
Topics: investments
Jurisdictions: global
Product tags: investment, tax-regime, residence-permit, company
Semantic tags: investment, tax-regime, residence-permit, company

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## Concept

Buying an apartment in London, a villa in Tuscany, and a condo in Singapore are three different legal worlds. In some places, a non-resident won't be asked a single question; in others, you'll need permission from a land commission; and in some, the entry tax is comparable to the price of the apartment itself. The main surprises usually lie not in property rights themselves, but around them: payment routes, annual non-resident taxes, inheritance under the law of the property's country.

This hub is a map of eleven jurisdictions our clients most often consider: United Kingdom \(London\), Italy, France, Portugal, Spain, Singapore, Bulgaria, Austria, the UAE, Greece, and Cyprus. For each country, there's a separate breakdown: who can buy, what's needed for the transaction, entry and ownership taxes, what status the purchase grants, and which structuring techniques actually work.

> 🍓 Three rules of the 2026 market: Europe's mass property-for-residency programs have wound down, but the route survives in four of the eleven jurisdictions; entry tax for non-residents ranges from 2% to 60%+; the most common deal-breaker is not the law, but the payment route and source of funds.

## Map: Eleven Jurisdictions

> 🔗 **Country Breakdowns**
> [London and England](https://wiki.private.law/en/london-property-purchase) · [Italy](https://wiki.private.law/en/italy-property-purchase) · [France](https://wiki.private.law/en/france-property-purchase) · [Portugal](https://wiki.private.law/en/portugal-property-purchase) · [Spain](https://wiki.private.law/en/spain-property-purchase) · [Singapore](https://wiki.private.law/en/singapore-property-purchase) · [Bulgaria](https://wiki.private.law/en/bulgaria-property-purchase) · [Austria](https://wiki.private.law/en/austria-property-purchase) · [UAE](https://wiki.private.law/en/uae-property-purchase) · [Greece](https://wiki.private.law/en/greece-property-purchase) · [Cyprus](https://wiki.private.law/en/cyprus-property-purchase)

Summary picture as of July 2026 — entry tax for non-residents, restrictions, and what status the purchase grants:

| Country | Entry Taxes \(non-resident\) | Purchase Restrictions | Grants Status |
| --- | --- | --- | --- |
| London | SDLT up to ~19% for a non-resident individual buying a second home \(scale up to 12% + 5% second home + 2% non-resident\); through a company — a flat 17% | none | no |
| Italy | 9% of cadastral base \(usually significantly below market\) | reciprocità for non-EU without residence permit — fulfilled for Russian citizens | no |
| France | ~7–8% total on resale | none | no |
| Portugal | from 01.09.2026 — flat 7.5% IMT for non-residents | none | golden visa for real estate dead since 2023 |
| Spain | ITP 6–13% depending on region | military zones for non-EU | golden visa abolished 03.04.2025 |
| Singapore | BSD up to 6% + ABSD 60% for foreigners | landed houses — only with LDAU permission | no |
| Bulgaria | ~4–7% total | land not for non-EU personally — solved through EOOD | residence permit for purchase from ~€307,000 |
| Austria | 3.5% + 1.1% + Grundverkehr permission | permit regime in each state | no |
| UAE | 4% DLD in Dubai, 2% in Abu Dhabi | designated freehold zones only | Golden Visa for 10 years from AED 2m |
| Greece | 3.09% \(24% VAT on new builds suspended to 31.12.2026\) | border zones for non-EU — committee permit with Defence Ministry vote | Golden Visa from €250,000 to €800,000 |
| Cyprus | transfer fees 3–8% halved; 19% VAT on new builds \(5% for a first home\) | Cap. 109 permit for non-EU: up to 2 properties or a plot of up to 4,014 sq m | fast-track PR from €300,000 + VAT |

The pattern is simple: the more liquid the market, the freer the entry and the higher the taxes \(London, Singapore\). The stricter the housing protection policy, the more administrative filters \(Austria, partly Spain and Portugal\). The UAE stands apart: cheap entry, zero ongoing taxes, and a purchase that converts directly into status. Together with Bulgaria, Greece and Cyprus, those are the four of the eleven where real estate produces residency.

## What's Needed Before the Transaction

Almost everywhere, the first step is not choosing the property, but obtaining a local tax number: NIE in Spain, NIF in Portugal \(for non-residents from third countries — together with a tax representative\), codice fiscale in Italy. In the UK and Singapore, nothing is needed for the purchase itself — numbers appear later when tax arises. Bulgaria requires BULSTAT registration after the transaction, Austria — permission before it.

The second universal block is source of funds. The bank, notary, and agent check the origin of money, each according to their own rules, and the package should be assembled before making a deposit: tax returns for 2–3 years, asset sale agreements, dividend resolutions, statements showing accumulation. The longer and clearer the chain, the faster the transaction.

The third block is presence. In all eleven jurisdictions, the transaction can be closed remotely by power of attorney: apostilled notarial POA plus sworn translation. Apostille on Russian documents is placed in Russia \(Ministry of Justice\), not at the consulate.

> ⚙️ The critical path is almost always opening a local account, not the legal part: allocate more time for the bank than for the notary.

## Payment Route: Sanctions Layer

For a buyer with a Russian passport, the main question in an EU transaction is not "can I buy," but "how to pay." There is no ban on purchasing real estate in the EU for Russian citizens: it was discussed since 2022 but never entered any sanctions package \(individual countries — Finland, Latvia — introduced national bans; none in our list have such bans\). A different restriction applies — Article 5b of Regulation 833/2014: an EU bank cannot hold more than €100,000 in accounts of a Russian citizen or Russian resident. Exception — EU/EEA/Switzerland citizens and residence permit holders in these countries: they are completely excluded from the ban.

Therefore, transactions are structured around the payment route: money comes from the buyer's account in the EU/EEA \(if there's a residence permit\), from a friendly jurisdiction, or through notarial escrow — the European Commission explicitly states that payment of the price through a notary's account is not prohibited in itself, but should not circumvent 5b. In the UK, a similar threshold — £50,000 for Russian citizens living in Russia \(UK visa holders are excluded\).

From the Russian side, the road has cleared: since December 8, 2025, the Central Bank removed the $1 million per month limit on transfers abroad for Russian citizens. The restriction is now not legal, but infrastructural — a SWIFT payment in EUR/USD from a non-sanctioned Russian bank can be made, but the European receiving bank will likely reject it for compliance reasons. The practical standard is to pay from a foreign account that has been reported to the Federal Tax Service. Where part of the price is funded with debt, another layer appears — a [non-resident mortgage](https://wiki.private.law/en/non-resident-mortgage) with its own LTVs, rates and document pack, and the bank's approval timeline usually runs longer than the notary's.

## What Purchase Grants: Residency

The era of "apartment = golden visa" is over. Portugal removed real estate from the golden visa back in October 2023, Spain completely abolished the program on April 3, 2025, the UK closed the investor visa in 2022. In Italy, France, Austria, and Singapore, real estate never granted status.

What remains. First, [Greece](https://wiki.private.law/en/greece-property-purchase): after the 2024 reform the threshold rose to €800,000 in Attica, Thessaloniki, Mykonos, Santorini and islands above 3,100 inhabitants, and €400,000 elsewhere, with a minimum of 120 sq m and a ban on short-term letting. Second, Bulgaria: ownership of housing from 600,000 BGN \(≈€307,000, payment through a Bulgarian bank\) grants a renewable residence permit, after five years — permanent residence. Third, [Cyprus](https://wiki.private.law/en/cyprus-property-purchase): fast-track permanent residence under Regulation 6\(2\) with an investment from €300,000 plus VAT and verified annual income from abroad of at least €50,000. Fourth, real estate as support for "passive" visas: Spanish NLV \(from €2,400/month income\), Portuguese D7 \(from €920/month\), French visiteur, Italian residenza elettiva \(from ~€31,000/year\) — everywhere your own property covers the housing requirement and strengthens the dossier, but doesn't replace income. Fifth, for all other scenarios, the Schengen 90/180 regime works — since 2025, Bulgaria is also in Schengen, and its days count toward the general limit.

## Ownership Structures

There's no universal answer to "register through a company or personally" — the logic is opposite across countries.

Wrapper helps: in France, SCI solves inheritance issues and gradual gifting of shares to children \(€100,000 per child every 15 years tax-free\); in Bulgaria, a local EOOD is the only legal way for a non-EU citizen to own land under a house; in the UK, a company is justified for a rental portfolio \(interest deduction, corporate rate\).

Wrapper harms: in London, residential property in a company means 17% SDLT on entry, annual ATED, and since 2017, transparency for inheritance tax; in Singapore, purchase through a company or trust — ABSD 65% instead of 60%; in Austria, share deal with a "real estate company" since July 1, 2025, is taxed at 3.5% of market value — loophole closed; in Spain and Portugal, a company from the blacklist of jurisdictions pays penalty rates \(3% per year of cadastral value in Spain, IMI 7.5% and IMT 10% in Portugal\). Everywhere, add beneficial owner registers: UK Register of Overseas Entities is public, in the EU access is restored for "legitimate interest."

For a Russian tax resident, any foreign company for property is also a [CFC](https://wiki.private.law/en/kik): notifications, reporting, and if profit exceeds the threshold — tax.

## Ownership, Exit, Inheritance

The annual burden for a non-resident consists of local property tax \(from symbolic amounts in Bulgaria and Austria to noticeable Council Tax and the upcoming mansion tax in London from 2028\), rental income tax \(from 10% in Bulgaria to 24% of gross revenue in Spain for non-EU\), and — in France — wealth tax IFI on property over €1.3 million. Spain adds imputed income tax even on vacant apartments.

On exit, the range is equally wide: Singapore doesn't tax capital gains at all \(but penalizes sale before 4 years — SSD up to 16%\), Bulgaria takes 10%, Spain — 19%, France — 19% plus social charges decreasing to zero over 22–30 years of ownership, UK — up to 24%, Austria — 30% flat. Italy releases without tax after five years of ownership.

Inheritance is a separate discipline: real estate almost always follows the law of the country where it's located, with local forced heirship and local tax — from zero in Austria to 40% IHT in the UK and 45% in direct line in France. How to plan for this — in the breakdown of [foreign real estate succession](https://wiki.private.law/en/foreign-real-estate-succession) and [succession planning hub](https://wiki.private.law/en/succession-planning).

## Common Mistakes

**Buying "for residency" based on 2019 memory**

The client expects a golden visa that no longer exists. Check the program status as of the transaction date, not from five-year-old articles: of the eleven jurisdictions, Bulgaria, Greece, Cyprus and the [UAE](https://wiki.private.law/en/uae-property-purchase) grant direct status.

**Deposit before payment route**

Advance paid, but money for completion cannot go through: the seller's bank has a 5b limit, the buyer has no EU account. Money route is agreed before signing, otherwise the deposit is forfeited.

**Company "for confidentiality"**

There's no anonymity anymore — beneficial owner registers disclose the owner, and the wrapper triggers penalty rates: ATED in London, 65% ABSD in Singapore, 3% in Spain. A company is a tool for a specific purpose, not the default.

**Forgotten ownership taxes**

Spanish imputed income tax, French IFI, London ATED come every year regardless of whether you live in the apartment or not. Calculate the cost of ownership for 10 years ahead, not just entry.

**Transaction without checking purchase eligibility**

Land in Bulgaria, any property in Austria without Grundverkehrskommission approval, landed house in Singapore without LDAU — such transactions are void or remain unexecuted. First clearance, then contract.

**Inheritance "later"**

The form of ownership chosen at purchase determines the inheritance scenario for decades. Changing the structure later means a second entry tax; choice of law under [Regulation 650/2012](https://wiki.private.law/en/succession-applicable-law) and will are executed together with the transaction.

> 🍓 The correct order of work on a transaction: country and property → right to buy → payment route → form of ownership with an eye to rental, exit, and inheritance → and only then contract and deposit.

## Q/A

### The deposit is paid but the completion money cannot go through. Why?

Because the payment route was not agreed before signing. Article 5b of Regulation 833/2014 bars an EU bank from holding more than €100,000 in the accounts of a Russian citizen or Russian resident; EU, EEA and Swiss citizens and residence-permit holders in those countries are excluded from the ban entirely. Payment of the price through a notary's account is not prohibited in itself but must not circumvent 5b. The UK threshold is £50,000.

### The Central Bank lifted the transfer limit. Can I pay from a Russian bank?

Legally yes, in practice almost never. Since 8 December 2025 the USD 1 million per month cap on transfers abroad by Russian citizens is gone, so the obstacle is no longer legal but infrastructural: a SWIFT payment in EUR or USD from a non-sanctioned Russian bank can be sent, but the European receiving bank will most likely reject it on compliance grounds. The practical standard is to pay from a foreign account reported to the tax authority.

### What happens if you buy without the land commission's permission?

The transaction is void or hangs unexecuted. Any property in Austria without Grundverkehrskommission approval, a landed house in Singapore without LDAU permission, land in Bulgaria held personally by a non-EU citizen — each is a condition of validity, not a formality; land under a house in Bulgaria is lawfully held through a local EOOD. Clearance first, then contract and deposit.

### The entry tax is paid. What arrives every year after that?

Local property tax, tax on rental income and, in some countries, a tax on ownership itself. Spain charges imputed income tax even on a vacant apartment, France levies IFI on property above €1.3 million, and in London a property held in a company carries annual ATED. Rental income runs from 10% in Bulgaria to 24% of gross revenue in Spain for non-EU owners. Cost of ownership is modelled ten years ahead.

### Isn't buying through a company confidentiality and a saving?

Neither by default. Beneficial owner registers disclose the owner: the UK Register of Overseas Entities is public and in the EU access is restored for "legitimate interest". And the wrapper triggers penalty rates: in London residential property in a company means a flat 17% SDLT on entry plus ATED, in Singapore ABSD of 65% instead of 60%, in Spain 3% a year of cadastral value for a company from the blacklist.

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## Factual claims

- Summary picture as of July 2026 — entry tax for non-residents, restrictions, and what status the purchase grants:
- From the Russian side, the road has cleared: since December 8, 2025, the Central Bank removed the $1 million per month limit on transfers abroad for Russian citizens.
- Inheritance is a separate discipline: real estate almost always follows the law of the country where it's located, with local forced heirship and local tax — from zero in Austria to 40% IHT in the UK and 45% in direct line in France.
- Buying "for residency" based on 2019 memory
- Advance paid, but money for completion cannot go through: the seller's bank has a 5b limit, the buyer has no EU account.
- There's no anonymity anymore — beneficial owner registers disclose the owner, and the wrapper triggers penalty rates: ATED in London, 65% ABSD in Singapore, 3% in Spain.

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