- None of the three countries lets a foreigner own land outright. In Bali a foreigner holds a long-term land lease (leasehold), in Thailand a registered lease of no more than 30 years or a condominium within the 49% quota, in Vietnam a 50-year right to a home with one extension.
- In Thailand, Supreme Court decision No. 4655/2566, widely applied since 2025, voided prepaid automatic renewals beyond 30 years. Proposals for 99-year leases and a 75% quota had not been enacted as of mid-2026.
- In Vietnam the new Housing Law and Land Law took effect on 1 August 2024: foreigner-to-foreigner resale is allowed, the 30% per building and 250 houses per ward caps remain.
- In Bali, since May 2026 new foreign companies are not registered under KBLI code 68111, so the working format for an individual is a leasehold with a fixed extension mechanism and stage payments for construction.
A foreigner with $150,000–300,000 for a villa in Southeast Asia in 2026 chooses between three countries, and each sells something different. In Bali it is a long-term land lease. In Thailand a 30-year lease or a condominium within a quota. In Vietnam a 50-year right to a home. We have already compared Bali with Phuket and Dubai on yield. This article has a different job: to work out what exactly you receive, for how long, how you exit, and what changed in the law in 2025–2026.
Three answers to “what do I actually own”
| Parameter | Bali (Indonesia) | Thailand | Vietnam |
|---|---|---|---|
| Land ownership for a foreigner | No (Hak Milik for citizens only) | No (Land Code s. 86) | No (all land is state-owned) |
| What an individual buys | Leasehold (Hak Sewa) on land with a villa, Hak Pakai with a residence permit | A condominium within the 49% quota of building area, or a lease of up to 30 years | A right to an apartment or house for 50 years with one extension |
| Term of the right | Market 25–30 years, DOMA projects 29+10+30 = 69 years | 30 years of registered lease, condominium indefinite | 50 years + 50 years |
| Villa with land | Yes, the main format | Only via land lease or a company | Limited: 250 houses per ward, only in open projects |
| Resale to a foreigner | Assignment of the remaining term through a notary | Condominium within the quota, lease with the owner's consent | Allowed since 1 August 2024 for the remaining term |
| Inheritance | Under the leasehold agreement | Condominium yes, lease renewal does not pass to heirs | For the remaining term |
| Ownership through a company | PT PMA, but code 68111 closed to new companies since May 2026 | Nominee companies under criminal prosecution since 2025 | Foreign-invested company, separate regime |
Bali: a land lease that lives as long as the contract says
A foreigner in Bali has two personal formats. The first and main one: leasehold, a long-term lease of land from an Indonesian owner with the right to build, live, rent out and assign. The second: Hak Pakai, a right of use in your own name, available with a residence permit. The third format, a PT PMA company holding HGB, has been closed to new companies since May 2026: the province does not register KBLI code 68111. Details: the closure of KBLI 68111 and can foreigners buy property in Bali.
The weak point of the Bali market is not the law but the contracts. The typical offer: 25–30 years and “a right of extension by mutual agreement”, which lawyers call zero protection. A working structure writes the extension into the contract from the start. In the projects DOMA represents: 29 base years, 10 years on a fixed scale and 30 years by formula, 69 years in total, with the owner's obligation, term and price fixed.
Exit: assignment of the remaining term through a notary. The market applies a 30–40% discount when fewer than 15 years remain, so the length of the contract is exit money. Legal letting requires a set of documents: KKPR, a PBG with commercial use, SLF, NIB under code 55193 and NPWPD. Since 1 August 2026 properties without it are removed from platforms.
Thailand: 30 years that courts no longer allow you to double
Land is closed to foreigners under section 86 of the Land Code, and circumventing it through nominees carries criminal liability. A condominium can be owned outright if foreigners hold no more than 49% of the building's area (Condominium Act). A villa with land can only be leased: the registered lease limit is 30 years under section 540 of the Civil and Commercial Code.
For years the market sold “30+30+30”, a lease with two prepaid automatic renewals. Supreme Court decision No. 4655/2566, widely circulated in 2025 and applied by lower courts in 2026, declared such renewals void. The first 30 years stand as a registered right, while a renewal is a personal promise of the current owner that does not pass to heirs or to a new landowner. A buyer of a “90-year” villa in Thailand legally holds 30 years.
What is being discussed but not enacted: extending leases to 99 years and raising the condominium quota to 75%. According to Bektu's review of 10 June 2026 both proposals remain drafts. In parallel, a campaign against nominee companies has run since 2025: Terms.Law's February 2026 review reports more than 46,000 such companies identified and 852 prosecutions. For a villa buyer this means the “Thai company owns the land” structure is no longer a grey area but a risk of losing the property.
Vietnam: 50 years, a pink book and a cap on houses
All land in Vietnam belongs to the state, and a foreigner receives a right to housing confirmed by a certificate known as the pink book. The term is 50 years from issue with one extension of another 50 years. On resale the buyer receives the remainder, not a fresh 50 years.
Quotas: foreigners may hold no more than 30% of apartments in one building and no more than 250 houses per ward of roughly 10,000 residents. Purchases are allowed only in projects open to foreigners and outside defence and security areas. Since 1 August 2024 the Housing Law 2023 (No. 27/2023/QH15) and the Land Law 2024 (No. 31/2024/QH15) have been in force. The main change for an investor: foreigner-to-foreigner resale is expressly allowed, where previously sales were only to citizens. Mortgages for foreigners are largely unavailable, and a purchase confers no visa rights.
The practical profile of a Vietnamese purchase: an apartment in Ho Chi Minh City, Hanoi or Da Nang, occasionally a house in Phu Quoc. A villa with land in the Bali format is the exception here.
The difference between the three countries is not where foreigners are “allowed” but what exactly is protected: 30 registered years in Thailand, 50 years on a certificate in Vietnam, the text of the contract in Bali.
Money: entry, yield, taxes
| Parameter | Bali | Thailand | Vietnam |
|---|---|---|---|
| Entry for a villa with a pool | from $139,000 (Mirador, 2 bedrooms, 72 m², 2026) | condos from ~$100,000, villas noticeably more (our comparison, July 2026) | Phu Quoc villas $200,000 – $1 million, HCMC apartments ~$2,400/m² (Q1 2025) |
| Rental yield, dated data | Green Harmony 11.6–18.1% net in 2025, Mirador forecast 12–14% (not a guarantee) | Phuket 6–9% (our estimate, July 2026) | national average 3.16%, HCMC up to 4.5% (Q1 2025) |
| Market occupancy | DUVI, July 2026: 37% all Ubud listings, 60–65% active, 87% managed by partners | pronounced seasonality | long-term rental to expats, weak seasonality |
| Purchase costs | notary fees, no registration, no BPHTB on a leasehold | 2% transfer fee for a condominium, seller taxes depend on holding period | VAT 10%, registration 0.5%, maintenance fund 2%, 13–18% all-in with legal fees (JanusHermes, May 2026) |
| Rental tax | 10% on land and building rent, 10% local accommodation tax | progressive personal income tax | above VND 500 million a year: 5% income tax + 5% VAT (ExpatDen, July 2026) |
| Tax on sale | 2.5% on leasehold assignment | depends on holding period and seller status | 2% of the sale price |
Yield figures cannot be compared directly: Vietnam's number is long-term apartment rental, Bali's is short-term managed villa rental. Different product, different risk, different work. How to test a claimed yield: a developer's financial model under the lens. How net yield is calculated in Bali: villa yields in Bali.
What changed in 2025–2026
| Date | Country | Event | Meaning for a buyer |
|---|---|---|---|
| 1 August 2024 | Vietnam | Housing Law 2023 and Land Law 2024 take effect | Foreigner-to-foreigner resale allowed, quotas kept |
| 2025 | Thailand | Supreme Court decision No. 4655/2566 applied by courts | 30+30+30 unprotected, effective tenure 30 years |
| 2025–2026 | Thailand | Campaign against nominee companies | Holding land via a Thai company became a criminal risk |
| third week of May 2026 | Bali | Province closes KBLI code 68111 to new PT PMA | The “my company owns the villa” format is unavailable to new buyers |
| 10 June 2026 | Thailand | Status of 99-year and 75% proposals: not enacted | Calculate on current law, not on drafts |
| 1 August 2026 | Bali | Delisting of unlicensed properties from platforms | Legal letting requires the full document set |
| 17 August 2026 | Bali | 10-day land title transfers in Badung and Buleleng | The register updates faster, see our review of the reform |
How to choose: three scenarios
A villa for yourself for decades. Thailand gives 30 protected years, after that it depends on the owner. Vietnam gives 50 years plus an extension, but a villa with land is hard to find. Bali gives as much as the contract says: from zero protection with “extension by agreement” to 69 years with a formula. Reading the contract matters more here than choosing the country.
Rental income. Vietnam is long-term rental to expats at roughly 3–4.5%, stable and without operational load. Thailand and Bali are short-term rental to tourists with seasonality and a management company. In Bali the gap between the brochure and the market is the widest, so calculate on market occupancy rather than on a promise. How: the investor roadmap from search to rental.
Capital preservation and exit. The most liquid resale to a foreigner is a condominium within the quota in Thailand: an indefinite right and a clear market. In Vietnam resale to a foreigner has been allowed since August 2024, but the buyer receives the remaining term. In Bali the exit price is set by the remaining lease, the documents and the income history: selling a leasehold before expiry.
For an Australian buyer, and Australians remain Bali's largest source market by arrivals (1,171,531 in January–August 2026), there is a tax layer on top: foreign rental income is declared in Australia. See Australian tax on a Bali villa and Bali vs the Gold Coast.
Bottom line: in 2026 none of the three countries gives a foreigner land, so the comparison is not “where is it allowed” but what exactly the law and the contract protect. Thailand after the Supreme Court ruling is 30 years of lease or a condominium within the quota, Vietnam is 50 years on a certificate with quotas and low yields, Bali is a leasehold whose strength depends entirely on the contract text and the permit set. If your scenario is a villa with a pool and short-term rental, Bali remains the only one of the three markets where that product is legally available to an individual in the mass segment, provided the contract and documents are checked before the deposit. Write to us and we will run your scenario along these axes.
This material is for information only and is not legal, tax or financial advice. We are not lawyers, tax advisers or financial advisers. Thai and Vietnamese rules are given per dated open reviews and must be verified with a local lawyer before any deal. Yield forecasts are not a guarantee.
Sources: Siam Legal on Thai Supreme Court decision No. 4655/2566, Bektu, 10.06.2026 on the status of the 99-year and 75% proposals, Terms.Law, February 2026 on Thai law and the nominee crackdown, ExpatDen, 24.07.2026 and JanusHermes, 04.05.2026 on Vietnam (Housing Law 27/2023/QH15, Land Law 31/2024/QH15, taxes, Q1 2025 prices and yields), Betterplace management reports on Green Harmony for 2025, the DUVI index (issue 1, July 2026), Bali arrivals statistics for January–August 2026, Mirador project documents (PBG dated 06.08.2026).
FAQ
Where can a foreigner own land outright: Bali, Thailand or Vietnam?
In none of the three. In Indonesia Hak Milik is for citizens only, in Thailand section 86 of the Land Code bars foreigners from owning land, in Vietnam all land belongs to the state. What differs are the derived rights: leasehold in Bali, a 30-year lease or a condominium within the 49% quota in Thailand, a 50-year right to a home in Vietnam.
What happened to the 30+30+30 scheme in Thailand?
Thai Supreme Court decision No. 4655/2566, widely circulated in 2025 and applied by lower courts in 2026, declared prepaid automatic renewals beyond 30 years void. The first registered 30 years remain valid, and renewal depends on the landowner's goodwill when the term ends. Such promises do not pass to heirs or to a new landowner.
How does a Bali leasehold differ from a Thai lease?
In the extension format and market practice. In Thailand the registered lease limit is 30 years under section 540 of the Civil and Commercial Code, and courts do not protect renewals beyond it. In Bali the typical market sells 25–30 years with extension “by agreement”, while in the projects DOMA represents the extension is written into the contract: 29 years plus 10 on a fixed scale plus 30 by formula, 69 years in total.
Can I buy a villa rather than an apartment in Vietnam?
Yes, with limits: no more than 250 houses per ward of roughly 10,000 residents, only in projects open to foreigners, and outside security areas. The right runs 50 years with one 50-year extension. Most foreign purchases in Vietnam are apartments in Ho Chi Minh City, Hanoi and Da Nang.
Where are rental yields higher?
By dated data: in Vietnam the national average yield is 3.16%, up to 4.5% in prime Ho Chi Minh City districts (Q1 2025 data). In Bali, managed Green Harmony villas returned 11.6–18.1% net in 2025, and the 12–14% forecast for Mirador is not a guarantee. For Thailand we found no fresh consolidated data in open sources, our July comparison put Phuket at 6–9%. Calculate for a specific property at market occupancy.
What matters to an Australian buyer in all three countries?
Three things: Australian tax residency means declaring worldwide income including foreign rent, the income currency differs from the expense currency, and the exit depends on the remaining term of the right. We covered Australian tax on a Bali villa in a separate article. We are not tax advisers, check the numbers with an accountant in Australia.
Which country is easier for a remote purchase?
In Bali the deal runs through a notary with a power of attorney and funds transferred to the notary's account, in Vietnam you need to enter the country and obtain the pink book in your name, in Thailand a condominium purchase requires proof of foreign currency inflow. Remote purchase is possible everywhere, but the paperwork and the lawyer's role differ. See our guide to buying a Bali villa remotely.