🇪🇸Mortgages for Non-Residents: LTV, Rates and Eligibility by Country

Mortgage finance is the question a non-resident buyer runs into before the transfer tax, and settles before choosing a property. What follows is the regulatory LTV ceiling in eleven jurisdictions — from Spain to Singapore — actual market figures for 2024–2026, named lender criteria where these are published, and a plain statement of where no bank publishes anything at all.

The concept

Any discussion of non-resident mortgages splits into three layers, and confusing them produces most of the mistaken expectations.

• The regulatory LTV ceiling — a central bank or macroprudential rule that binds the lender
• Bank practice for non-residents — internal credit policy, rarely published and changed without notice
• Barriers before the loan — the reciprocity condition, country blacklists, and a purchase tax that outweighs the deposit

The rate backdrop in August 2026

Every rate reference below is measured from a single point.

The level marks a turn: the current ECB rate sits a quarter of a point above the low of the cycle, while twelve-month Euribor has risen throughout 2026 — in January the index stood at 2.245%, and in August of last year at 2.112%.

In France, against that backdrop, the broker network CAFPI expects no fall in mortgage rates in September.

The regulatory ceiling across eleven jurisdictions

Actual market figures from the European Mortgage Federation (Hypostat 2025, reporting 2024 data) run well below the regulatory limits.

The Bulgarian rate is the lowest in the set. Outside these columns sit the fixed-rate share — 90% of originations in Spain and 99% in France — and the foreign-buyer share in Spain, 18% of transactions.

One line per jurisdiction

The two tables above answer different questions — what the regulator permits and what the market actually does — and a non-resident borrower needs them read together, with the affordability test that decides the size of the loan. All eleven on one line each.

Three things follow from reading the line rather than the column. First, the regulatory ceiling is almost never what limits the loan: in Spain, France, Italy, the United Kingdom and Austria there is no LTV cap at all, and the size of the advance is set by an income ratio or by the lender's own policy. Second, only three jurisdictions on this list have terms a non-resident can read before approaching a bank — the United Kingdom through Skipton's published expat scale, the UAE through the HSBC and Mashreq product pages, and Spain through Bankinter's FAQ; everywhere else the non-resident figure is credit policy rather than a published rule. Third, the cheapest money on the board is Bulgarian and the dearest is French, and the spread between them is wider than the difference any LTV negotiation will produce.

The UAE: regulatory limits and practice for non-residents

The Regulations Regarding Mortgage Loans (Circular 31/2013, in force since 28 December 2013) are addressed to banks, finance companies and other mortgage providers, and identify three categories of borrower: UAE nationals, GCC nationals and expatriates. “Expatriate” in the language of the regulation means a foreign national holding a residence visa. A non-resident without a UAE visa falls outside the regulation altogether, and their terms are set by the bank's internal policy.

Article (3) Important Ratios supplies the precise figures: the maximum LTV is set by borrower category and by the purpose of the property.

Maximum tenor: 25 years. Income multiples run to eight years' annual income for nationals and seven for expatriates. The debt burden ratio is 50% of gross salary, rising to 60% under government housing programmes.

Two widely repeated claims are contradicted by the regulation itself. The CBUAE sets no maximum age at the date of the final instalment: the rule expressly hands the question to lenders “in accordance with their risk management and lending policies”, so the figures of 65 and 70 that circulate in market commentary are not regulatory. The current 85/75 and 80/70 ratios are the product of a narrow amendment: board resolution 31/2/2020 of 8 April 2020 raised the first owner-occupied home ceilings by 5 percentage points for nationals and expatriates alike, while the limits on second and investment property (65% and 60%) were left untouched. The amendment carries no expiry date and is not described in its own text as a temporary measure.

Two of the banks publish their non-resident terms themselves. HSBC UAE lends a non-resident up to 60% of the property's value, for clients who hold or qualify for a Premier or Private Bank account, with a valuation fee of AED 2,625 including VAT. Mashreq finances a non-UAE resident up to 50% of the fair market value, up to AED 10 million, for a maximum tenor of 25 years. The rest of the picture comes from brokers and developers: Engel & Völkers (updated 21.09.2025) cites LTVs of 60–65% and names Emirates NBD, Mashreq, ADCB, HSBC and FAB, noting that each bank maintains its own list of eligible countries.

The developer Grovy (03.07.2026) publishes its own set of reference figures.

None of these figures rests on a rule: what binds is the bank's own published offer and the terms of the individual approval.

The United Kingdom: the expat lender as a market of its own

There is no regulatory LTV ceiling in the United Kingdom, so the criteria of individual lenders are what matter. Skipton International (Guernsey) publishes its own in full in its UK buy-to-let criteria; LTV is set in bands by loan size.

Minimum income for an employed applicant is £50,000 individually or £80,000 jointly; for the self-employed, above £75,000 and £100,000 with at least two years' trading; pension income is assessed against the same pair of thresholds, £50,000 and £80,000. Income is accepted in local currency and must not be taxable in the United Kingdom.

Portfolio landlords — those with four or more mortgaged properties — must meet 125% rental cover stressed at 7.24% across all buy-to-let borrowing. Portfolio limits: no more than five buy-to-let mortgages with Skipton itself, no more than ten properties in total and no more than three within a single postcode district, with an EPC rating of A–C, or D where it can be upgraded. The applicant must be resident outside the United Kingdom; a restricted-country list applies, alongside a separate exclusion — the bank does not lend to Chinese nationals residing in mainland China.

A broker view of the wider market (published 12.06.2026 and flagged as marketing) puts the typical ceiling at 75%, with some lenders reaching 80%, a premium of 0.5–1.5 percentage points over resident pricing, and trackers opening 0.3–0.6 points below fixed rates; EUR and USD income is accepted without a material premium, while AED and THB income is discounted. The principal players are Skipton International, NatWest International and HSBC Expat (Jersey), and Lloyds Bank International.

The tax layer shapes the ownership structure more decisively than the interest rate does. Section 24 of the Finance (No. 2) Act 2015 — the correct citation; the commonly seen “Finance Act 2015” is wrong — inserted sections 272A and 272B into ITTOIA 2005: relief for mortgage interest on residential buy-to-let was tapered across 2017/18 to 2020/21 and, from 2020/21, replaced by a tax reducer at the basic rate, that is 20% (PIM2054, updated 21 May 2026). The restriction does not touch companies carrying on a property business, nor commercial property; the carve-out for furnished holiday lettings ran until 5 April 2025, after which the FHL regime was abolished.

Hence the logic of holding through a limited company — and the counter-argument on SDLT. The non-resident surcharge of 2% applies to dwellings in England and Northern Ireland for transactions with an effective date on or after 1 April 2021 (s. 75ZA and Schedule 9A of the Finance Act 2003, guidance at SDLTM09850A, updated 26 May 2026), sits on top of every other residential rate, and catches certain UK-resident companies controlled by non-residents.

The test is 183 days of presence in the United Kingdom in the 12 months before the purchase; on a joint purchase one buyer's non-residence taints all of them, while spouses count as resident if either one meets the test. The surcharge can be reclaimed by amending the return within two years, on reaching 183 days in any continuous 365-day period around the transaction date.

The base residential SDLT scale, on top of which the surcharges are charged.

The additional dwelling surcharge has been 5% since 31 October 2024. Companies pay a flat 17% on dwellings above £500,000 (since 31 October 2024, previously 15%); where a relief applies — for a property rental business, for instance — the ordinary scale plus 5% plus 2% is charged instead, and the effects stack.

France: debt as an IFI instrument

France imposes no regulatory LTV ceiling; the HCSF constraints operate on debt service instead, with taux d'effort capped at 35% and the term at 25 years (D-HCSF-2021-7 of 29 September 2021). The derogation quota is 20% of new lending, and it is nearly exhausted: in Q1 2026 the share of loans breaching the norms reached 17.5%, against 15.7% a year earlier, and the HCSF nonetheless resolved to leave the existing rules in place. A French peculiarity on security: of secured new lending, 70% is backed by a caution (Crédit Logement and its peers) and only 19% by a registered mortgage.

Article 974 CGI: which debts are deductible

Here the mortgage more often exists for the sake of the IFI. Article 974 I CGI allows deduction of debts existing on 1 January, borne by members of the foyer fiscal and relating to taxable assets, on a closed list: acquisition of property, repair and maintenance, improvement and reconstruction, taxes on the taxable property, and acquisition of company interests au prorata de la fraction imposable. Mixed use yields a deduction only in proportion to the taxable share (BOI-PAT-IFI-20-40-10 of 08.06.2018).

The in fine loan looks like the ideal instrument, and article 974 II CGI defuses it. The provision imposes an amortissement fictif: the deductible amount is the total loan less that same amount multiplied by the number of years elapsed and divided by the total term. The BOFiP worked example: a loan of €1,000,000 over 15 years granted on 30 June 2018 gives a deduction of €1,000,000 for IFI 2019, €933,333 for IFI 2020 and €66,667 for IFI 2033. The borrower owes the bank the full million throughout, while deducting a shrinking fiction — the tax effect of an in fine loan is levelled with that of an ordinary amortising one.

A loan with no fixed term is treated as a twenty-year loan repaid on a straight line: the deduction loses one twentieth each year and reaches zero after twenty. The rule is aimed squarely at Lombard facilities and revolving lines repayable on demand.

Article 974 III CGI closes off intra-family funding: loans from the taxpayer, a spouse, a PACS partner or minor children are non-deductible outright; those from ascendants, descendants, siblings or a controlled company are non-deductible unless the terms are shown to be normal. That is established through actual payments on schedule, a documented date, a genuine term and a market rate.

Article 974 IV CGI constrains large estates: where taxable property exceeds €5,000,000 and deductible debts exceed 60% of that value, the excess counts only by half. The mechanics in illustration: assets of €9m and debts of €6m give a deduction of €5.4m plus half of the €0.6m excess, €5.7m in place of €6m. There is an escape clause: the restriction falls away where the taxpayer shows the debts were “non contractées dans un objectif principalement fiscal”.

Spain: who pays the costs of completion

There were two reforms, on different dates, and collapsing them into “the 2019 reform” produces an error for loans completed between the two.

From 10 November 2018 Real Decreto-ley 17/2018 amended article 29 TRLITPAJD: the lender became the taxpayer for AJD on the mortgage deed. At the same time a new paragraph m) in article 15 LIS placed that AJD among the expenses that cannot reduce the corporation tax base.

From 16 June 2019 article 14.1.e) of Ley 5/2019 allocated the remaining gastos: gestoría, notarial fees on the mortgage deed and registration of the security fall on the lender, valuation of the property on the borrower, and copies of the deed on whoever requests them.

The official FAQ issued by the Ministry of Consumer Affairs on 4 March 2021 confirms the allocation and gives a limitation period of five years for reclaiming improperly charged gastos, while noting that the Supreme Court had not at that point settled when the period begins to run. The wave of reclaims follows the CJEU judgment in joined cases C-224/19 and C-259/19 (CY and Others v Caixabank and Banco Bilbao Vizcaya Argentaria, 16 July 2020).

Article 17 of Ley 5/2019 prohibits ventas vinculadas with an exception for insurance: the bank may require a policy securing performance of the obligations and buildings insurance over the mortgaged property, but must accept alternative policies from any provider on equivalent terms and cover, without charging for assessing them.

Article 23 caps early repayment compensation, and the cap depends on the rate type.

The absolute limit is the bank's actual financial loss: the fee “en ningún caso podrá exceder del importe de la pérdida financiera que sufra el prestamista”.

The average rate on new residential mortgages was 2.98% in May 2026, on an average advance of €174,866 across 42,213 registered residential mortgages (Estadística de Hipotecas, published 20 July 2026) — an upward turn tracking Euribor. The ceiling a bank itself publishes for a non-resident sits at 70%: Bankinter states in its mortgage FAQ that the loan “will only cover at most 70% of the price of the property”, with debt service capped at 35% of income and every document translated by a sworn translator at the borrower's cost. That squares with the EMF data, where the market average LTV is 63%, first-time buyers typically take 80%, and second homes “max out at 70%”.

Portugal: new rules from 1 August 2026

The revised macroprudential recommendation of the Banco de Portugal (Recomendação Macroprudencial n.º 1/2026) was announced on 2 July 2026 and applies to creditworthiness assessments from 1 August 2026.

It tightens several parameters at once.

The Portuguese LTV ceiling attaches to the purpose of the loan. The borrower's residence status does not affect it: a non-resident buying anything other than an own permanent residence falls into “outras finalidades” with an 80% ceiling. The actual market average LTV is 69%.

Three different figures on term are worth separating explicitly: the EMF records an actual average of 31 years for 2024, the former BdP recommendation steered banks towards 30 years, and the new grid sets 40 or 35 depending on age.

The buyer statistics tell a story of their own: 93.7% of 2024 purchases were made by Portuguese tax residents, up 16.2% year on year. The Banco de Portugal itself notes that the figure understates the role of foreign buyers, since many of them have acquired tax residence. A foreign national who becomes a tax resident borrows on resident terms — which is the cheapest route to a higher available LTV.

The role of the NIF, the need for a representante fiscal, the size of the spread, imposto do selo on the loan and on the mortgage, and the current status of the temporary waiver of early repayment fees on variable-rate loans are settled before an application against portaldasfinancas, eportugal.gov.pt, diariodarepublica.pt and the Banco de Portugal's own materials.

Singapore: the mortgage in the shadow of ABSD

On paper the terms look welcoming: the LTV ceiling is set by the number of outstanding housing loans.

The 5-point reduction across the individual categories has applied since 6 July 2018. TDSR has been 55% since December 2021, MSR is 30% for HDB flats and executive condominiums bought from a developer, the maximum loan tenure is 35 years, and the minimum cash downpayment on a second or subsequent loan is 25%. Reduced limits of 55 / 25 / 15% apply where the tenure exceeds 30 years or runs past age 65; the MAS page notes the existence of the lower limits in the text without setting them out in a summary table.

The binding constraint for a foreign buyer is ABSD, in force since April 2023; the rate depends on the buyer's status.

On a SGD 2m property the ABSD comes to SGD 1.2m against a deposit of SGD 500,000 at 75% LTV. The mortgage becomes a technicality against that, and purchase planning starts from the tax.

Greece, Cyprus, Austria, Bulgaria: the frame without the bank practice

Greece introduced borrower-based measures from 1 January 2025 by Bank of Greece decision 227/1/08.03.2024: LTV of 90% for first-time buyers and 80% for everyone else, DSTI of 50/40%. The rate for 2024 was 4.06%, falling to 3.69% in Q1 2025, with 70.4% of new lending fixed. The demand backdrop: foreign direct investment in real estate of €2.5bn in 2024, amounting to 41% of the country's total FDI, and, on the ministry's monthly data as summarised by Greek Reporter in June 2025, 3,477 Golden Visa applications in the first four months of 2025 — a quarter more than a year earlier, notwithstanding the higher thresholds introduced in August 2024.

Cyprus applies a binding CBC decision of 9 November 2020, in force from 19 March 2021: 80% on a primary residence and 70% on everything else, with banks going down to 60% on investment property. No debt-to-income limit is set by the regulator — the ESRB notification is confined to LTV — and banks apply their own 30–40%. The variable rate for house purchase was 4.7% at the end of 2024 against 5.2% a year earlier. Meanwhile 51% of all 2024 transactions involved non-residents, with 37% of the total going to non-EU buyers. A market that is half foreign lends to foreigners on terms ten to twenty LTV points worse.

Austria is the only country in the set to have removed its ceiling. The KIM-Verordnung lapsed on 30 June 2025 and was not extended; its parameters had been LTV ≤90%, a Schuldendienstquote ≤40% of net income, a term ≤35 years, and exemptions for loans below €50,000 (€100,000 for couples) and for bridging finance. In its place the FMA issued a non-binding Rundschreiben in June 2025: a bank may depart from those criteria and set its own standards, provided it stays within the requirements for sound lending practice, while the FMSG expects the former parameters to be observed voluntarily. Practice is in any event more conservative than the rule that was abolished: LTV around 50% and rarely above 75%, a rate of 3.89%, terms of 25–30 years.

Bulgaria, by a decision of the BNB Governing Council of 11 September 2024 applying from 1 October 2024, set LTV at 85%, DSTI at 50% and a maximum term of 30 years. Rates are the lowest in the set: 2.53% in BGN and 2.95% in EUR at the end of 2024, on an average LTV of 70–80% and an actual term of around 25 years. The currency question has been closed administratively: from 1 January 2026 the country adopted the euro at the irrevocable rate of BGN 1.95583 to EUR 1 (Council of the EU decision of 8 July 2025), and a market with 96% of loans in leva and 99% on floating rates shed its currency risk overnight.

In these four jurisdictions the regulatory frame is the only public layer: which banks lend to a non-resident, at what LTV, at what rate and to what maximum age is decided in each bank's credit policy rather than in a published scale.

Currency risk and the barriers before the loan

Article 23 of Directive 2014/17/EU (the MCD) requires member states to ensure that foreign currency loans carry either a consumer right of conversion or other arrangements limiting the risk. The alternative currency is either the currency in which the consumer primarily receives income or holds assets, or the currency of the member state in which the consumer was resident at the time of the agreement or is resident now; the choice is left to the member state. The creditor must warn the borrower regularly whenever the total amount payable or the instalments vary by more than 20% from what they would be at the exchange rate applying at the date of the agreement, and where the risk is not limited within that 20% the ESIS must include an illustration of the effect of a 20% swing.

EU banks resolve the question more bluntly: they lend to non-residents in euro only. The currency risk stays with the borrower as a risk on their own income, and the transaction falls outside article 23 as a formal matter. The cost of getting this wrong is shown by C-260/18, Kamil Dziubak and Justyna Dziubak v Raiffeisen Bank International AG (Third Chamber, 3 October 2019) — a Polish mortgage indexed to the Swiss franc, and the wave of claims that followed. The historical exception is Austria, where Fremdwährungskredite made up around 11% of the mortgage book in Q1 2019.

Italy raises a barrier ahead of the mortgage. Article 16 of the disposizioni preliminari al codice civile admits a foreign national to the rights of an Italian citizen “a condizione di reciprocità”; the reciprocity check is mandatory before the transaction, and D.P.R. 394/1999 (article 1) names the Ministry of Foreign Affairs as the competent authority. The Consiglio Nazionale del Notariato review works through country-by-country scenarios, Switzerland among them. That review does not itself state the consequence of a purchase completed without confirmed reciprocity, so the point is best closed with the notary before signing.

Italy sets no regulatory LTV ceiling; the rate on long-term fixings at the end of 2024 was 3.03% against 4.03% a year earlier (short fixings ran at around 4.2%), the actual average term is 25.3 years, and variable-rate lending has shrunk to 6.5% of new originations from 33.7%.

A Lombard facility secured on a securities portfolio removes precisely the barriers listed above: the valuation, the local account, the tax number and the compulsory insurance. Advance rates and margin-call mechanics on such lines are set in each bank's own facility terms rather than in a published scale, so the angle that can be settled in advance is the tax one: for French IFI purposes a Lombard line with no fixed term falls under the one-twentieth rule in article 974 II CGI, while article 974 I requires the debt to relate to taxable assets — the use of the funds has to be traced through documents, failing which no deduction is available at all.

Popular, and it ends badly

The eleven countries in summary: no regulatory LTV ceiling in Spain, Italy, the United Kingdom or France; abolished in Austria on 30 June 2025; tied to loan purpose in Portugal (90% own permanent residence / 80% other); 90/80% in Greece; 80/70% in Cyprus; 85% in Bulgaria; 80/70/60% in the UAE for visa-holding residents only; 75/45/35% in Singapore.

Actual lending runs below the rule almost everywhere: 63% in Spain, 69% in Portugal, 60.9% in Greece, around 50% in Austria. The August 2026 rate backdrop is turning upward — the ECB deposit rate at 2.25% since 17 June, 12-month Euribor near 2.92% and rising through the year, Bank Rate at 3.75%, and the French 10-year OAT reaching 4% for the first time since 2009.

Bank-published terms for non-residents exist in three jurisdictions: the Skipton International scale from 75% down to 50%, with a £50,000 income threshold and 125% rental cover stressed at 7.24% for portfolio landlords; HSBC's 60% and Mashreq's 50% in the UAE, where no rule stands behind them; and Bankinter's 70% of the price in Spain.

From 1 August 2026 Portugal has cut DSTI to 45% and the exceptions quota to 10% of half-yearly volume. The barriers before the loan often weigh more than the loan itself: the Italian condizione di reciprocità, 60% ABSD in Singapore, 2% SDLT and 17% for companies in the United Kingdom, and the country blacklists of offshore lenders.