Buying a home does not mean the same thing everywhere. What you hold, whether you can hold it as a foreigner, and the moment it legally becomes yours all differ. The last point matters most off-plan, when you often pay long before you hold title.
Pick the market you know and the one you're looking at to see them side by side. These are the closest equivalents, not exact matches, because the law behind each term differs by country.
United Kingdom
- Freehold
- Leasehold
- Commonhold
Freehold means owning the property and its land. Leasehold means owning for a fixed term, usually with a freeholder above you and ground rent and service charges to pay. Flats have usually been leasehold.
Watch for: A short remaining lease can deter lenders and buyers. The government has proposed moving new flats to commonhold, which is not yet law.
Source: UK Government, draft Commonhold and Leasehold Reform Bill
Dubai
- Freehold
- Leasehold
- Title deed
- Oqood
Foreigners can own outright in designated freehold zones. Off-plan purchases are recorded on the interim register, known as Oqood, and converted to a title deed at handover.
Watch for: Until the title deed is issued, your interest rests on the sale contract and the Oqood registration.
Source: Dubai Law No. 13 of 2008, Interim Real Property Register · Dubizzle, property handover in Dubai
Malaysia
- Freehold
- Leasehold
- Strata title
Homes are freehold or leasehold. In a condominium, each owner holds a strata title to their own unit and a share of the common property.
Watch for: Foreign buyers must meet minimum prices that vary by state and title type, often from RM1 million. Vacant possession is not the same as receiving your title.
Source: EdgeProp, minimum prices for foreign buyers · Conventus Law, foreigners acquiring property in Malaysia
Georgia
- Registered ownership
- NAPR (Public Registry)
Ownership is created and transferred only by registration with the National Agency of Public Registry. Foreigners can buy apartments and houses.
Watch for: Foreigners cannot buy agricultural land, and a "villa" on such land may fail to register. Off-plan, you are generally not the registered owner until the building is accepted and your unit is registered.
Source: Chambers, Real Estate 2026: Georgia · Global Property Guide, buying in Georgia
Serbia
- Cadastre registration
- Clausula intabulandi
Ownership is acquired by registration in the cadastre, after a contract certified by a public notary. The clausula intabulandi is the seller's consent to that registration.
Watch for: Foreign ownership depends on reciprocity with your home country. Lawyers advise contract guarantees, such as a bank guarantee or pledge, until a unit under construction is registered.
Source: Stojković Attorneys, buying in Serbia · Stojković Attorneys, buying under construction
Egypt
- Law 230 of 1996
- Registered title
Law 230 of 1996 is the main framework for foreign ownership of homes, and your protection depends heavily on whether the property is properly registered.
Watch for: Law 230 limits foreigners to two homes of up to 4,000 m² each and bars resale for five years. The government has announced lifting the number limit, but we could not confirm it has been enacted, so ask a lawyer.
Source: Andersen Egypt, can foreigners own property · Lex Council, buying in Egypt as a foreigner
Greece
- Notarial deed
- Hellenic Cadastre (Ktimatologio)
Title passes by a notarial deed that is then registered with the land registry or cadastre. A private agreement alone does not transfer ownership.
Watch for: Order a cadastre extract to confirm the owner, boundaries, charges and any disputes.
Source: Global Law Experts, off-plan vs completed in Greece · Global Law Experts, transferring property in Greece
Cyprus
- Title deed
- Contract of sale
- Specific performance
New-build buyers often hold a contract of sale before a separate title deed exists. Depositing that contract at the Land Registry protects the buyer, and specific performance is a court order compelling the transfer.
Watch for: Non-EU buyers need Council of Ministers permission, so make the contract conditional on it. Title deed delays are a known issue, and a 2025 reform targeted trapped buyers. North Cyprus needs separate specialist advice.
Source: Zeno Legal, Cyprus conveyancing 2026 · Kyprianou, Cyprus legal process, costs and VAT · Cyprus Mail, reform for trapped buyers
Ethiopia
- Proclamation No. 1388/2025
- Leasehold land
Foreigners can own a home under Proclamation 1388/2025, with a minimum of USD 150,000 in Addis Ababa, including lease value, and reportedly lower thresholds elsewhere. You can register the building, but the land stays under the state leasehold system.
Watch for: The law allows ownership only on leased land allocated by public bidding, so have a lawyer confirm how the plot was allocated. Some nationalities and border areas can be excluded. Foreigners are generally limited to one home and cannot use Ethiopian loans or other domestic finance. The law requires a Ministry permit first, and a 2026 directive holds funds, reportedly converted to birr, in a blocked account until release is authorised. Foreign nationals of Ethiopian origin and licensed investors have different terms.
Source: Proclamation No. 1388/2025 (gazette) · LEX Africa, Ethiopia's ownership rulebook · Birr Metrics, ownership thresholds
Last checked 4 November 2026. Many sources are law firms and property guides rather than official texts, and rules change. This is general information, not legal or tax advice, so confirm the details for your purchase with a qualified local adviser.
Ask an adviser
Comparing two markets? Tell us your budget and what you're weighing up, and an adviser will reply.