Video walkthrough · Southeast Asia · Six countries
Where can foreigners buy property in Southeast Asia, and what do you actually own?
In all six countries the listing says the same word. Freehold. Behind that word you are buying six different things, and in one of them the certificate has somebody else's name on it.
So the ranking below is not about which country is nicest. It is about what your name ends up on when the money has moved, and what can take it away.
Disclosure before the list: I own two condos in Thailand, and Thailand finishes first here. Weigh that however you like. The reasoning is written out in full, so you can check it rather than trust it.
| Country | Tier | What your name ends up on | The limit |
|---|---|---|---|
| Thailand | S | The condo unit, freehold, no expiry | 49% of the building's floor area, foreign-owned |
| Malaysia | A | The land itself, in your own name | State consent in writing, plus a state-set price floor |
| Philippines | A | The unit outright, perpetual, on a CCT | 40% of the project, and never any land |
| Cambodia | B | A strata title in your name, first floor and up | 70% of the private units' floor area |
| Vietnam | C | The apartment, on a 50-year term, renewable once | 30% of the units in a building; land stays with the State |
| Indonesia | D | A right to use, or a lease. Never the land | Hak Milik is closed to foreigners outright |
Where these rules come from
Every limit above is a named statute, linked in its own section below: Thailand's Condominium Act section 19 bis, the Philippine Condominium Act and the 1987 Constitution, Vietnam's Housing Law 2023 and Land Law 2024, Indonesia's Basic Agrarian Law article 21(1), Cambodia's Law of 24 May 2010 with Sub-Decree No. 82, and Malaysia's National Land Code Act 828.
Rules change. Every figure here carries its source and its date so you can re-check it before you commit money.
The same ranking, on video
Nothing on this page depends on the video. Everything in it is written out above and below.
Indonesia: why is it bottom?
Because it offers the least ownership of any country on the list. A foreigner cannot hold Hak Milik, Indonesian freehold, and that is not a technicality a clever structure gets around. It is article 21(1) of the Basic Agrarian Law: only Indonesian citizens may hold it. A citizenship test, not a visa test.
What you get instead is a right to use or a lease, and there are four routes to it. All four leave you holding a right for a term, on ground that belongs to somebody else. That can work for years, provided you knew that was what you were buying.
Then there is the nominee arrangement, where a local person's name goes on the certificate and your protection sits in side agreements behind it. People do live happily in those houses. The thing to understand is what the certificate says, and what happens when the paperwork behind it is tested. Why a nominee structure is not ownership.
And the detail that says the most about the gap between the rules and the pitch: the licence that covers letting your villa, Pondok Wisata, is defined in the regulation as accommodation in a dwelling house occupied by its owner, where guests get the opportunity to interact in the owner's daily life. That is a description of a home with a spare room. It is a long way from a villa bought as an investment and run through an app from another country. The Pondok Wisata licence, in full.
Vietnam: real ownership with a timer on it
You genuinely own the apartment, in your own name, with a real certificate. You own it for fifty years, renewable once. Fifty years is a long time, and the phrase "renewable once" is doing a lot of quiet work in that sentence.
The land underneath stays with the State throughout, and foreigners can hold up to 30% of the units in any one building. Housing Law 2023 and Land Law 2024, both in force since 1 August 2024.
The part that catches people is not buying in. It is getting out. Ask who buys a fifty-year clock off you in year thirty-five, when what they are being offered is fifteen years for the money you paid for fifty. That is a C: real ownership, with a timer.
Cambodia: the friendliest cap on the board
Cambodia surprises people. You get a proper strata title with your name printed on it, and the foreign-ownership cap is the most generous here: more room than Thailand's 49% and well clear of Vietnam's 30%.
The exact figure is 70%, and two details about it are worth more than the number. It is 70% of the total floor AREA of the building's private units, not 70% of the number of units, so a building can sit at the legal cap with barely half its units foreign-owned. And it is not in the 2010 Law at all: the Law's article 6 only says a sub-decree will set the proportion. The figure lives in Sub-Decree No. 82, article 2, of 29 July 2010. Cambodia's 70% cap, and how to check a building against it.
Corrected on screen
In the episode I say the unit has to be on the second floor or above. The statute says first floor and up: article 6 of the Law of 24 May 2010 grants ownership "only from the first (1st) floor up", and bars the ground and underground floors. Cambodia counts the ground floor as level zero, so the physical level is the one I meant, but "second floor" is the wrong name for it. The video corrects this on screen.
There is one more condition on the foreign side, and it has teeth. A transfer that breaches article 6 is null and void, and units within 30 kilometres of a land border are out of reach except in special economic zones, important urban areas, and other areas the government designates. The land under the building is never yours: Land Law 2001, article 8, and it is article 8, not the article 44 half the internet cites.
The Philippines: a title that does not run out
Here it starts getting good. You own the unit outright. No lease behind it, no use right, no clock running anywhere, on a perpetual title with its own document: the Condominium Certificate of Title. What a CCT is, and how it differs from a TCT.
Two catches. Foreign ownership in a project is capped, so there is always a question about how much room is left in the building you like. And the second is absolute: no land, ever. You own the box in the sky permanently and never a square metre of the ground under it. Perfect if an apartment is what you wanted. Less so if you pictured a house with a garden.
The detail almost nobody checks: the 40% everyone repeats does not appear in the Condominium Act. What the Act writes down is a Filipino floor of 60%, and the 40 is simply what is left after it. When the number everyone quotes is not the number in the law, it is worth asking where the rest of the pitch came from. Where the 40% actually comes from.
Malaysia: the only one that will give you the land
Malaysia is the one worth arguing about. It is the only country here where a foreigner can own the ground itself, freehold, in their own name. That is genuinely unusual in this region, and it is why it ranks as high as it does.
Corrected on screen
It is never automatic. Section 433B of the National Land Code allows a non-citizen to acquire land only after the prior written approval of the State Authority, which may attach conditions and a levy, and section 433C makes a dealing without that approval null and void. A permission regime, not a right.
Then the catch, and it is money rather than structure. Each state sets a minimum purchase price for a foreign buyer. So in Malaysia the question stops being whether you are allowed to own the thing and starts being whether you can afford the entry ticket.
Corrected on screen
In the episode I say the floors start somewhere around a million ringgit. They do not start there. The published state floors run roughly RM400,000 to RM3,000,000: RM1,000,000 is the federal benchmark and the most common state figure, not the bottom of the range. Source: Bar Council Malaysia Circular 444/2024, table stated as at October 2024. Every state's floor, with its date and source.
Two states break the general rule outright, which is why "check the state" is not a throwaway line here. Selangor permits foreigners strata and landed-strata titles only, not landed individual titles. Perak has not permitted freehold to non-citizens since September 2023, limiting them to a 60-year leasehold bought direct from a developer.
So Malaysia lets you own more and asks more of you to get through the door. I put it just ahead of the Philippines, because owning the land is a different asset. If your budget does not reach the floor, the Philippines is simply the better answer for you. That is the one I genuinely went back and forth on.
Thailand: why is it first?
You get the condo unit, freehold, registered in your own name, with no clock on it anywhere. No fifty-year term, no use right, no lease to renegotiate in 2075. You own it the same way the Thai owner down the hall owns his. That is the cleanest structure on this board.
The catch is the number everybody has heard: a building can only be 49% foreign-owned by floor area, under section 19 bis of the Condominium Act. Everybody quotes it and almost nobody checks it, which is odd, because it is not a question about Thailand at all. It is a question about the one building you are standing in. Section 19 bis, in full.
And it is checkable in an afternoon. Ask the juristic office for the current figure, in writing, before you pay anything.
Land is the same answer as everywhere else here: not in your own name. The usual fallback is a 30-year lease, and the word carrying all the weight is registered. A lease longer than three years is enforceable for three years only unless it is written and registered. So an unregistered 30-year lease is a three-year lease with 27 optimistic years typed at the end of it. Why registration is the whole of a Thai lease.
What the ranking actually says
Thailand first, then Malaysia, the Philippines, Cambodia, Vietnam, and Indonesia at the bottom. The order matters less than the thing underneath it: all six are sold using the same word, and that word describes six different objects, from a title with no expiry, to a fifty-year term, to an arrangement resting on private agreements with someone else's name on the certificate.
Every one of these countries is buyable, and people do well in all of them. The trick is knowing which version you are buying before the money moves.
So the honest advice is short: work out the structure before you fall in love with the price. You can renegotiate a price later. You almost never renegotiate a structure.
What would move a country up this board?
A ranking you cannot argue with is a ranking nobody checked. So here is what would actually change each position, which is also the list of things worth watching.
Indonesia moves off the bottom the day a foreigner can hold something that is not a term on someone else's ground, or the day the letting licence stops describing a house the owner lives in. Neither is close. Vietnam moves up if the renewal of a fifty-year term becomes something a buyer can rely on in writing rather than hope for, because the whole C grade is about the exit rather than the entry.
Cambodia is held at B by depth rather than by law. The rules are the most generous on the board; what is thin is the evidence a buyer can check a price or a rent against. More published, verifiable market data moves it, and nothing else needs to change.
Malaysia and the Philippines are separated by a judgement, not a fact, and that is why the ordering is the thing to argue about. If the state price floors came down, or state consent became predictable rather than discretionary, Malaysia's lead would widen. If they rose, the Philippines takes the tier on access alone.
Thailand only loses the top if the structure changes, and the structure is the reason it is there: a unit, freehold, your name, no expiry. A tighter quota would not move it. A term limit would.
Where the video corrects itself, and why
The episode ships with the audio exactly as filmed, and four red-asterisk cards correct the record on screen where a spoken line does not match the statute. Nothing was re-recorded to hide a mistake. The same four corrections are stated above, in the country sections they belong to.
- Cambodia is first floor and up, not second floor and up. Ground is level zero there.
- Cambodia's cap is 70% of floor area, set by Sub-Decree No. 82, not by the 2010 Law.
- Malaysia's floors run about RM400,000 to RM3,000,000 by state. A million ringgit is the federal benchmark, not the bottom of the range.
- Malaysian land needs the State Authority's written approval. Without it the dealing is null and void.
How do you check the cap before you pay?
Every country here has a step that takes a day and settles the question. Almost nobody does it, which is why the caps get discussed as trivia rather than as the gate they are.
In Thailand, ask the juristic person for the building's current foreign share in writing, before any deposit. In the Philippines, read the master deed and the project's foreign-ownership position rather than the sales office's summary of it. In Vietnam, ask for the certificate and check the term's start date, not just its length: a term that started before you arrived is shorter than the brochure implies.
In Cambodia, the strata title itself carries each unit's surface proportion of the building, because Sub-Decree No. 82 article 3 requires the cadastral authority to write it there. In Malaysia, the question is asked of the state: the written approval either exists or the dealing is void. In Indonesia, the honest check is to ask whose name appears on the certificate and what happens to your position if the arrangement behind it is ever tested.
None of that requires a lawyer to start. It requires asking for one document before the money moves rather than after.
What this ranking deliberately leaves out
It ranks ownership structure, and nothing else. It is not a ranking of prices, rents, taxes, transaction costs, lifestyle or how a place feels to live in. A country can sit at the top of this board and still be the wrong purchase for you on every other axis.
Two of those axes move real money and are worth separating out. Purchase costs and holding taxes differ enormously between these six, and they are set out per country in the research pages linked below rather than compressed into a letter grade here. And the return on any individual unit is a building-level question, not a country-level one: the spread between two buildings in one city is routinely wider than the gap between two countries on this board.
So use the board for what it is. It tells you what you would own. It does not tell you whether the specific thing in front of you is worth owning.
What document proves it, country by country?
Every ranking above rests on a named document. If you cannot name the one you are buying, you do not yet know what you are buying.
- Thailand: the chanote, with the juristic office's quota letter showing the building's current foreign share.
- Philippines: the Condominium Certificate of Title, and the project's master deed for the foreign share.
- Vietnam: the certificate people call the pink book, carrying the term and its start date.
- Cambodia: the strata title, which under Sub-Decree No. 82 article 3 carries each unit's surface proportion of the building.
- Malaysia: the individual or strata title, plus the State Authority's written approval.
- Indonesia: whatever certificate the structure actually produces, which for a foreigner is never Hak Milik.
Why is a cap a question about one building?
Thailand's 49%, Cambodia's 70% and Vietnam's 30% all sound like country rules. They are not. They are building rules, and they are consumed by whoever bought before you.
A building at its cap is closed to you, whatever the national figure says. That is why the only useful version of the question is the specific one: how much room is left in this building, today, in writing. In Thailand that is the juristic office. In Cambodia the cadastral authority writes each unit's proportion onto the certificate itself, so the arithmetic is on the paper in front of you.
Note also what the cap is measured in. Thailand and Cambodia both measure floor area, not unit count. Vietnam counts units. A rule of thumb built on the wrong unit of measurement will mislead you at exactly the moment it matters.
Which of these is the hardest to sell again?
Ownership is only half the question. The other half is who buys it from you, and what they are allowed to buy.
Vietnam is the clearest case: a term that shortens every year you hold it, sold on to a buyer who is inside the same 30% cap you were. The Philippines and Thailand both hand on a perpetual title, so the term never shortens, but a building at its foreign cap can only be sold to a domestic buyer. In Malaysia your buyer pool is limited by the same state price floor you cleared, and a foreign buyer needs their own state approval. In Indonesia you are assigning a right with a term, which is a different negotiation again.
None of that is an argument against any of them. It is an argument for knowing the answer before you buy rather than after.
Where to read the underlying work
Country by country, with the statute behind each rule: Thailand, Malaysia, the Philippines, Cambodia, Vietnam and Indonesia. All six side by side in one free table: the ownership map.
All six countries, side by side. One free table.
Free. One email. Instant download.
- What your name actually ends up on — unit, right to use, lease or term, country by country.
- The cap, the term and the ceiling — with the statute behind each one.
- Where the land is available — and the five countries where it never is.
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