For international real estate investors, understanding what you truly own is just as critical as the location or price of the property. In some countries, you may hold full ownership; in others, you're granted a long-term lease. Then there’s the complexity of land rights, co-ownership, and communal title structures. This guide compares property documentation across key global markets.

Why Title Matters

• Proof of Ownership: Valid title documents establish your legal rights.

• Transaction Clarity: Secure titles prevent fraud and disputes.

• Resale Value: Buyers demand verified documentation.

• Bank Financing: Mortgages depend on clean title registration.

Types of Ownership Structures

1. Freehold – Complete ownership of land and buildings indefinitely.

2. Leasehold – Right to use property for a set number of years (usually 30–99).

3. Strata Title – Common in condominiums; individual unit ownership with shared common areas.

4. Right to Use (Hak Pakai, Usufruct, etc.) – Long-term use rights are often available to foreigners.

Country-by-Country Title Overview

Thailand

• Chanote Title: Best form—fully transferable, with land surveyed by GPS.

• Nor Sor 3 Gor / Nor Sor 3: Legal but less precise; can be upgraded to Chanote.

• Leaseholds: Up to 30 years, often used by foreigners.

• Company Ownership: Allowed, but risky if used to circumvent foreigner restrictions.

Portugal

• Land Registry (Registo Predial): All properties must be registered for legal ownership.

• Simple, Transparent System: Freehold ownership is common.

• Public Notary Involvement: Required for validating the sale.

UAE (Dubai)

• Title Deed (Oqood or Title Certificate): Issued by the Dubai Land Department.

• Freehold Zones: Foreigners can obtain full ownership.

• Pre-Registration: Off-plan properties have temporary titles until full transfer.

Türkiye

• Tapu (Title Deed): Official document showing ownership—issued by the Land Registry.

• Individual or Joint Ownership: Allowed.

• Military Clearance: Sometimes needed near restricted zones.

• Citizenship Properties: Must be held for 3 years post-purchase.

Spain

• Escritura Pública: The official notarised deed.

• Registro de la Propiedad: Title must be registered to be enforceable.

• Nota Simple: Summary document used for due diligence.

Indonesia (Bali)

• Hak Milik (Freehold): Not available to foreigners.

• Hak Pakai (Right to Use): 25–30 years, renewable.

• Nominee Structures: Risky and often illegal.

• PT PMA: Foreign-owned company structure that can hold Hak Guna Bangunan (Right to Build).

Greece

• National Cadastre: Central registry introduced for clarity.

• Freehold Ownership: Standard.

• Lawyer Involvement: Mandatory for due diligence and title transfer.

USA

• Warranty Deed: Offers full protection of ownership rights.

• Quitclaim Deed: Transfers interest with no guarantee—risky.

• Title Insurance: Strongly recommended.

• County-Level Recording: Titles recorded at the county level.

Key Terms in Title Documents

• Parcel Number: Unique identifier for a piece of land.

• Encumbrance: Any claim or lien on the property.

• Easement: Legal right for others to use part of the property.

• Zoning Information: Details on permitted use.

• Property Boundaries: Clearly defined and registered.

Red Flags to Watch For

• Unregistered Properties

• Disputed Ownership

• Incomplete Survey Maps

• Old Inheritance Claims

• Pending Legal Cases or Liens

How to Secure a Property Title

1. Hire a Local Real Estate Attorney: Essential for contract review and due diligence.

2. Use a Notary (Where Required): Many countries require notarised contracts.

3. Conduct a Title Search: Verify seller’s rights and check for encumbrances.

4. Get Title Insurance (If Available): Extra protection against fraud or error.

5. Register immediately: Ensure the transaction is formally recorded.

Tips for Foreign Buyers

• Avoid Nominee Agreements: These often breach local laws.

• Consider Leasehold as an Alternative: Especially in restricted ownership zones.

• Use Official Translators: Never rely on verbal explanations alone.

• Understand Inheritance Laws: Title rights can be lost or disputed after death.

Final Thoughts

Title documentation is more than paperwork—it’s your legal security in an unfamiliar market. Knowing the local terminology, procedures, and red flags will protect your investment and provide peace of mind. Don’t just trust what’s on paper—verify, register, and ensure your rights to what could be your most valuable asset abroad.