Property & Land

Overlapping deeds and destroyed registries

Land title rests on a mix of formal deeds, customary claims and possession. Decades of conflict destroyed or duplicated registry records, so competing valid-looking deeds over one plot are common.

Most urban and nearly all rural land is held under customary arrangements documented, if at all', by locally witnessed deeds. Formal registration coverage was low even before 2021. Land disputes are now largely handled by Emirate-appointed judges applying fiqh, and earlier restitution mechanisms for returning refugees have lapsed.

Registration-based ownership with unresolved restitution and legalisation

Ownership is registered with the State Cadastre Agency, and transfers require a notarial deed. Communist-era expropriation left a large body of restitution and compensation claims that continue to affect title.

Overlapping claims and informal construction mean title diligence should cover restitution files and legalisation permits, not just the cadastre.

State-dominated land ownership with concession rather than freehold for agriculture

The 1990 Land Orientation Law and the Civil Code govern property. Agricultural land is largely state-owned and held under long concessions, and foreign ownership of land is effectively excluded.

Algeria's socialist-era land settlement has not been unwound: most agricultural land remains state property, and Law 10-03 converted the previous perpetual usufruct into a 40-year renewable concession, which is transferable and mortgageable in limited ways but is not ownership. Anyone analysing agricultural investment must work from the concession, not from a title. Urban land registration is incomplete and a large stock of housing is held on unregistered or administratively regularised titles, with successive amnesty programmes attempting to formalise construction without permits. Foreign natural and legal persons are effectively barred from land ownership, so projects are structured around leases, concessions and Algerian-held vehicles.

Notarial title and communal cadastres rather than one land register

Real property is transferred by notarial deed before an Andorran notary, and holdings are recorded in the cadastres kept by each of the seven comuns. Non-residents may acquire property, subject to the foreign investment rules.

Because there is no single national land register, title diligence depends on the chain of notarial deeds and comú records rather than one searchable registry.

Lei de Terras with state ownership of land and transferable surface rights

The Lei de Terras (Lei 9/04) vests original ownership of land in the state, with private parties holding transferable surface rights (direito de superfície) and useful domain over urban land. Rural community land is recognised. Registration is with the Conservatória do Registo Predial.

The distinction between the state's original ownership and the private surface right is the operative one for any Angolan real-estate transaction: what is bought, sold and mortgaged is a right over land rather than the land itself, and the duration and renewal terms of that right determine its value.

Registered Land Act with the Barbuda communal exception

Antigua operates a registered title system under the Registered Land Act, so the register is the source of title and a transfer takes effect on registration. Non-citizens require a non-citizen land holding licence. Barbuda is the exception: land there has been held communally under the Barbuda Land Act 2007, and whether freehold title can now be issued depends on the contested 2018 amendments.

The two islands must be advised as if they had different property regimes, because a purchaser in Antigua can rely on a conclusive register while a purchaser in Barbuda faces an unresolved question about whether the land was capable of being sold at all. That distinction is the single most important due diligence point in this jurisdiction and is frequently missed by overseas investors.

Notarial deed plus registration in the provincial property registry

Real property transfers require a public deed (escritura pública) executed before a notary and then registered in the provincial real-property registry. Registration is declaratory as against third parties rather than constitutive of title, so the deed transfers ownership between the parties and registration protects it against competing claims. The Código Civil y Comercial governs ownership, and horizontal property (condominium) is regulated as propiedad horizontal.

The 45-day presentation window matters in practice: a deed registered inside it takes priority from the date it was signed, while a later filing takes priority only from presentation. Foreign buyers face restrictions in border security zones and, under Ley 26.737, on large rural landholdings, so a title search should confirm whether the parcel falls within either regime.

Unified cadastre registration with constitutional protection of ownership

The Civil Code governs ownership and the Law on State Registration of Rights to Property establishes a unified cadastre. Registration in the cadastre is what creates and proves title to immovable property.

Armenia completed comprehensive land privatisation in the 1990s and the cadastre is generally reliable, with electronic search available. Registration is constitutive: an unregistered transfer does not pass title. Foreign nationals may own buildings and lease land but cannot own agricultural land outright, a restriction that shapes foreign investment structuring. Mortgages must be registered to be effective against third parties. Expropriation for a public interest requires prior full compensation at market value, and the adequacy of compensation is justiciable.

Torrens indefeasible title layered over the Native Title Act 1993

Torrens title registration in every state, giving indefeasible title on registration, layered over native title recognised by the High Court in Mabo and administered under the Native Title Act 1993. Foreign purchasers need FIRB approval.

Registration under the Torrens system confers title that is indefeasible, subject to statutory exceptions including fraud, so the register itself is the source of title rather than evidence of it. Mabo v Queensland (No 2) in 1992 rejected the doctrine that Australia was legally unoccupied and recognised native title surviving at common law; the Native Title Act 1993 created the claims and future-act regime, and native title can coexist with some other interests but is extinguished by inconsistent freehold grants. Foreign persons generally require Foreign Investment Review Board approval before acquiring residential land, and acquiring established dwellings is largely prohibited.

Ownership through the Grundbuch, with a 3.5% real-estate transfer tax

The General Civil Code (ABGB) governs ownership, which passes only on registration in the land register (Grundbuch) following a notarised or certified contract. Standard real-estate transfer tax (Grunderwerbsteuer) is 3.5% of the consideration, with reduced rates for transfers within the family.

The constitutive nature of Grundbuch registration means the buyer is not owner until entry, and provincial approval rules can add a step for foreign buyers, especially for agricultural and secondary-residence property. Contracts are prepared by a notary or lawyer.

Registered title through the State Register of Immovable Property

The Civil Code governs ownership and the Law on the State Register of Immovable Property establishes registration as the basis of title. Foreign nationals cannot own land, though they may own buildings and hold long leases.

Registration in the State Register creates the right in immovable property; unregistered transactions do not transfer ownership. The Land Code divides land by category and permitted use, and change of category requires administrative approval. Foreign individuals and foreign-owned entities may not acquire freehold land, a restriction commonly addressed through long-term lease structures of up to 99 years. Mortgages require registration. Expropriation for state needs requires compensation, and the compensation methodology has been the subject of litigation particularly in connection with urban redevelopment in Baku.

Broad foreign freehold in designated areas

Foreign nationals may own freehold property in designated areas, and Bahrain's rules are among the more liberal in the Gulf.

Bahrain opened freehold to foreign buyers relatively early and the designated areas cover much of the developed coastal and urban property market, including Amwaj, Durrat and Seef, so the practical restriction is narrower than in Qatar or the UAE. RERA, created in 2017, brought developer licensing, escrow for off-plan sales and broker regulation into a single regulator after problems in the sector. GCC nationals can own in most areas. Registration at the Survey and Land Registration Bureau is what transfers title.

Foreign nationals effectively cannot own land

Bangladesh does not permit land ownership by foreign individuals. Foreign-owned companies may hold land for approved industrial purposes, and long leases are the practical route otherwise.

Title is deed-based rather than a guaranteed register, so diligence means tracing a chain of deeds, mutation records and rent receipts — a genuinely error-prone exercise, and fraudulent duplicate deeds are a known problem. The Vested Property Return Act addresses land taken from Hindu owners after 1965 and can cloud title decades later. Registration duty and gains tax on transfer are substantial.

Property Act conveyancing with a land tax on improved value

Barbados uses a deeds-based conveyancing system under the Property Act, Cap. 236, rather than full Torrens registration, so title is proved through a chain of registered conveyances at the Land Registry. Non-nationals may buy freely, but funds should be registered with the Central Bank so that sale proceeds can be repatriated. Land tax is charged annually on the improved value of the parcel.

The Central Bank registration step is the one non-resident buyers routinely omit, and it matters on exit rather than on purchase: without evidence that the acquisition funds came in through the banking system, repatriating the proceeds of a later sale becomes materially harder. Because title rests on the chain of deeds, a full search and an examination of the vendor's root of title remain essential.

State ownership of land with private ownership of buildings

Most land remains in state ownership and is held by citizens and companies under lifetime inheritable possession, lease or use rather than freehold. Buildings and apartments can be privately owned and are registered in the unified real property register.

Because land and building rights are separate, a purchase must confirm both the building title and the underlying land right, and the land right is the one that most often turns out to be a limited lease.

Property law recodified in 2021, with purchase taxes set by each Region

Book 3 of the new Civil Code entered into force on 1 September 2021, replacing rules that in part dated from 1804 and 1824 and unifying usufruct, emphyteusis and superficies into a single framework of real rights of use. Transfer of land requires a notarial deed, and the registration duty payable on purchase is a regional tax that differs substantially between Flanders, Wallonia and Brussels.

The regional split matters more than the code for anyone buying: the reduced rate for a sole and own home carries residence and timing conditions, and losing them triggers a supplement. Regional planning, energy-performance and soil-certificate obligations are also checked by the notary before the deed.

Torrens-style registered land alongside older deed titles

Belize is progressively converting from a deeds system to registered title under the Registered Land Act, which gives a Torrens-style guaranteed title. Two systems therefore coexist, and which applies depends on whether the parcel sits in a declared registration area.

Establish first whether the parcel is in a registration area, because the diligence required differs completely. For Toledo District purchases, customary claims must be investigated on the ground; the register will not disclose them.

Code foncier et domanial 2013 replacing the permis d'habiter with titled ownership

Loi n° 2013-01 created a unified land code and the Agence Nationale du Domaine et du Foncier. It aims to convert customary holdings and the colonial permis d'habiter into registered title, but conversion is incomplete, so unregistered customary tenure remains widespread in practice.

The 2013 Code's ambition is to make the Titre Foncier the only proof of ownership, extinguishing the layered colonial instruments. Because registration is expensive and slow relative to rural incomes, the intermediate instrument — the Attestation de Détention Coutumière — does most of the practical work, and disputes commonly turn on whether such an attestation was properly issued.

Foreigners cannot own land; thram registration governs title

Land ownership is restricted to Bhutanese citizens. Title is recorded in the thram register under the Land Act 2007, and there is a constitutional ceiling on how much land one person may hold.

The holding ceiling is twenty-five acres. Registration in the thram is the operative act of title, and the National Land Commission maintains cadastral records with reasonably good coverage for a country of Bhutan's terrain. Foreign-invested companies lease rather than own. Inheritance of rural land traditionally favoured daughters in much of the country, a matrilineal pattern that statute has not displaced.

Derechos Reales registration with INRA agrarian titling

Urban property transfers are executed by notarial deed and registered in Derechos Reales, the real-rights registry under the judiciary. Rural land is separately administered by the Instituto Nacional de Reforma Agraria (INRA), which conducted a nationwide saneamiento process to clear and retitle agrarian holdings, subject to the constitutional función económica social requirement.

The dual system matters: an urban title from Derechos Reales and a rural title from INRA are different instruments with different risks, and rural land can be reverted to the state if it fails the función económica social test. The Constitution also caps new individual rural landholdings at 5,000 hectares, approved by referendum in 2009.

Entity property law, land registers and post-war restitution

Property law and land registration are entity competences, with cadastres and land books maintained locally. Post-conflict restitution and the reconstruction of destroyed records remain live practical issues.

Land books and cadastres frequently disagree, and harmonisation projects are still ongoing, so dual verification is essential.

Tribal, state and freehold tenure with land boards allocating customary rights

Land falls into three categories: tribal land (about 70 per cent), state land and freehold. Tribal land is allocated by statutory Land Boards under the Tribal Land Act, not by chiefs personally, and a customary land grant can now be certified and in practice mortgaged. The Deeds Registry records freehold and long leases.

The 2018 Act completed a long shift of customary allocation from chiefly discretion to statutory boards, which was intended to make customary holdings bankable. The practical result is a three-tier system in which the security of a holding depends on which category the land sits in, and conversion between categories is an administrative act rather than a conveyance.

Title passes only on registration at the Registro de Imóveis

In Brazil ownership of real property transfers only on registration of the deed at the competent Registro de Imóveis; the contract alone creates personal obligations, not title. Transfers require a public deed before a notary above a statutory value threshold, and the municipal ITBI transfer tax must be paid before registration. Rural land purchases by foreigners are restricted.

The registration-constitutive rule is the single most important practical point: a buyer who signs and pays but does not register has no real right and is vulnerable to a later registered purchaser. A certidão de matrícula from the property registry is the authoritative record of the chain of title and of any liens, and should be obtained immediately before closing.

Land ownership limited to Bruneian citizens

Under the Land Code, only Bruneian citizens may hold land. Permanent residents and foreigners cannot acquire freehold or long leasehold title in their own right, and arrangements attempting to circumvent this — including trust and power-of-attorney structures — have been legislatively targeted. Most foreign commercial occupation is by shorter-term tenancy or through government-granted industrial sites.

Land ownership is restricted to Bruneian citizens under the Land Code. Titles are registered; the Land Department maintains the register. Strata title exists for apartment developments under the Land Code (Strata) Act. State land grants and Temporary Occupation Licences are the usual route for commercial sites. Nominee and trust workarounds for foreign purchasers are specifically legislated against — do not assume common-region structures transfer here. Verify citizenship status of the proposed titleholder before any transaction; it is dispositive.

A deeds-based register with a notarial transfer requirement

Bulgaria keeps a personal-name deeds register rather than a full parcel-based title register, so searches run against owners and history. Transfers require a notarial deed executed before a notary in the district where the property lies.

Because the register is name-based, a title search must trace the chain of previous owners for the prescription period; skipping it is how restitution and forged-power-of-attorney claims surface years later.

Réorganisation agraire et foncière with state ownership and rural land law

Land is in principle part of the domaine foncier national held by the state. Loi n° 034-2009 created a rural land certificate (attestation de possession foncière rurale) recognising customary possession, administered through communal land services.

Burkina Faso's 2009 rural land law is notable for legitimising customary possession rather than requiring its extinguishment: the attestation records what a community already recognises and gives it a documentary form usable in court. Insecurity has since displaced large populations, generating a category of dispute — return to land vacated under duress — that the framework did not anticipate.

The 2011 Land Code over acute land scarcity and returnee claims

The Land Code of 2011 provides for registration and recognises customary occupation as convertible to title. The dominant legal problem is the restitution of land to refugees returning after decades of displacement, handled by a specialised commission whose decisions have been contentious.

Burundi has among the highest rural population densities in Africa, and successive waves of displacement mean that the same plot is frequently claimed by a returning refugee and by a family that has occupied it for thirty years. The land commission was created to resolve exactly this, and the legitimacy of its decisions — particularly after its powers were widened in 2014 — is itself a political fault line.

No foreign land ownership, but strata title above the ground floor

The Constitution reserves land ownership to Cambodian natural and legal persons. The 2010 Law on Foreign Ownership permits foreigners to own strata-title units from the first floor upwards, not the ground floor. The other structural issue is that a large share of land is held on possessory rights rather than hard title, following the destruction of records under the Khmer Rouge.

Foreigners cannot own land; they may own co-owned building units above the ground floor. Long-term leases up to 50 years, renewable, are the standard foreign structure. Hard title (registered) and soft title (commune-level possession) coexist, with very different security. Economic Land Concessions allow long-term state land use for agro-industrial projects. Soft title is common and cheaper but is not registered at the national cadastre — conversion to hard title before purchase is the standard recommendation. Cambodian-majority landholding companies are widely used by foreign investors, but the structure carries real control risk.

1974 land ordinances vesting untitled land in the state

The 1974 ordinances divided land into private property, public property and national land, with national land administered by the state. Registration confers an indefeasible title, but most rural holdings remain customary and unregistered, which is the root of most land conflict.

The 1974 reform declared all unregistered land national land, converting customary occupation into a permission rather than a property right. Obtaining a titre foncier is the only route to a secure interest, and the cost and complexity of that process mean the great majority of Cameroonian land is held without one.

Provincial land titles, with Quebec's cadastre and Aboriginal title distinct

Land is provincial jurisdiction. The western provinces and Ontario use a Torrens-style land titles system in which the register is conclusive as to ownership, while parts of the Atlantic provinces retain older registry systems that record deeds without guaranteeing title. Quebec runs a civil-law land register alongside its cadastre. Aboriginal title, recognised at common law and affirmed by section 35, exists independently of any of these registers.

Reserve land cannot be sold to a non-member and is held by the Crown for the band's use, so financing improvements on reserve requires structures such as designated leases rather than an ordinary mortgage. Tsilhqot'in Nation v British Columbia confirmed that Aboriginal title can be proven over a territory rather than only specific sites, and carries a right to decide how the land is used.

Registered private ownership with a functioning cadastre programme

Cabo Verde recognises private freehold ownership under the Código Civil, with registration through the Conservatória do Registo Predial. A national cadastre programme has substantially increased registration coverage.

Unlike most African states in this region, Cabo Verde has genuine private freehold rather than state ownership with use rights, and its island-by-island cadastre programme has produced comparatively reliable title records. Emigrant ownership is a distinctive feature: a large diaspora holds property at home, and succession disputes frequently involve heirs resident in Portugal, the United States or the Netherlands.

State-held land with customary occupation predominating

Land legislation vests untitled land in the state and provides for registration, but very little land is registered outside Bangui. Mining and forestry concessions are the economically significant land interests.

Artisanal diamond mining occupies a distinctive legal position: the Mining Code regulates artisanal collectors and buying houses, and the Kimberley Process suspension between 2013 and 2015 made compliance with that framework a condition of lawful export.

1967 land laws vesting untitled land in the state

The 1967 land statutes established registration and treated unregistered land as state domain. Customary tenure predominates outside the towns and pastoralist access routes are a persistent source of conflict with cultivators.

Chadian land law's most consequential feature is not the register but the regulation of transhumance: the legal treatment of pastoralist corridors under mid-century statutes governs recurring and often violent disputes between herders and farmers across the Sahelian belt.

Conservador de Bienes Raíces registration completes the transfer

Transfer of real property requires a notarial deed followed by inscription in the Conservador de Bienes Raíces for the commune where the property lies. Inscription is the tradición that actually transfers ownership under the Código Civil, so an unregistered buyer holds only a contractual claim. Title is traced through the registry's chain of inscriptions.

Andrés Bello's Código Civil of 1855 is the foundation of Chilean private law and was influential across Latin America, with Colombia and Ecuador adopting versions of it. Because inscription performs the tradición, Chilean practice places heavy weight on the registry study going back at least ten years to confirm an unbroken chain and the absence of prohibitions or mortgages.

All urban land is state-owned; buyers acquire time-limited use rights

Private ownership of land does not exist. Urban land belongs to the state and rural land to collectives. What is bought and sold is a granted land-use right, typically 70 years for residential use.

Grant terms are 70 years residential, 50 years industrial and 40 years commercial. The Civil Code provides that residential use rights renew automatically on expiry, but the fee payable on renewal is not settled, which is the single largest open question for long-horizon residential buyers. Buildings are owned separately from the land-use right beneath them. Foreign individuals may generally buy only one residential property for self-use and usually must show a period of study or work in the country first.

Public deed plus registration in the Oficina de Registro de Instrumentos Públicos

Real property transfers require a public deed before a notary and registration in the Oficina de Registro de Instrumentos Públicos, which maintains the folio de matrícula inmobiliaria for each parcel. Registration perfects the transfer. Colombia also operates significant land-restitution machinery under Ley 1448/2011 for property lost during the armed conflict.

The certificado de tradición y libertad drawn from the folio de matrícula is the essential due-diligence document, showing the chain of title and any encumbrances. Land restitution adds a distinctive risk layer: a parcel may be subject to a restitution claim by a displaced former occupant, and specialised restitution judges can reverse transfers, so checking the restitution registry is standard practice.

Registered title alongside strong matrilineal customary tenure

Land registration follows the French-derived régime foncier, but most land is held under customary arrangements. Comorian custom is substantially matrilineal, with the manyahuli land passing through the female line, which interacts awkwardly with Islamic succession and with registration.

Comoros is an unusually clear case of three tenure systems interacting: matrilineal manyahuli custom, Islamic succession rules that favour male heirs, and a French-derived register that recognises neither by default. Which system governs a given plot is frequently the substance of the dispute.

Equal ownership rights, but the maritime zone is different

Foreigners have the same property rights as nationals, and title is held in a reliable public folio-real registry. The major exception is the maritime-terrestrial zone: the first 50 metres from the high-tide line is inalienable public land, and the next 150 metres can only be held under municipal concession.

Verify the folio real and any plano catastrado before committing, and check whether the parcel touches the maritime zone — beachfront listings sold as freehold are a recurring source of disputes.

Land-registry title, notarised contracts and liberalised foreign acquisition

Ownership is transferred by contract plus registration in the land register, with the registry entry decisive. EU nationals may now acquire property on the same footing as Croatians, with agricultural land subject to specific rules.

The land register and the cadastre can disagree after decades of unrecorded transfers, so reconcile both before purchase.

Sale of homes legalised in 2011, with foreign ownership tightly limited

Decreto-Ley 288/2011 legalised the sale and gift of homes between Cuban residents for the first time since 1959, ending the era of permuta swaps as the only route. Ownership is registered in the Registro de la Propiedad, and a household is generally limited to one permanent home plus one holiday home. Foreign nationals may not usually buy residential property outright unless they are permanent residents, though foreign investors can hold real rights within approved projects.

The one-home-plus-one rule is the structural constraint that prevents an ordinary Cuban property market from developing, since accumulating residential property for rental or resale is not permitted for residents. Foreign participation is confined to real rights, typically surface or usufruct rights, granted within an approved investment project rather than freehold ownership of land.

Registered title under the Immovable Property Law with unresolved 1974 claims

The Immovable Property (Tenure, Registration and Valuation) Law, Cap. 224, governs ownership, and the Land Registry issues the title deed which is conclusive evidence of title. Property displaced by the 1974 division remains the subject of unresolved claims.

Title registration under Cap. 224 produces a title deed that is conclusive, and the register is reliable within the government-controlled area. Two features demand caution. First, the specific performance regime under the 2011 law allows a buyer to protect an unregistered contract of sale by deposit at the Land Registry, and the historic backlog of undelivered title deeds in developer sales is a well-known problem. Second, properties abandoned in 1974 in both directions remain legally contested: the Immovable Property Commission in the north offers a domestic remedy that the European Court of Human Rights has accepted in principle as one to be exhausted, while the Republic treats title as unaffected by the division.

Cadastre-based ownership with the superficies solo cedit rule restored

The 2014 Civil Code restored the principle that a building forms part of the land, reversing decades of separate ownership. Rights are registered in the cadastre of real estate, and registration is required for transfer to take effect.

The cadastre imposes a 20-day waiting period before registering a transfer, a deliberate anti-fraud measure that must be built into any completion timetable.

The 1973 Land Law vesting all land in the state

The Bakajika-derived 1973 General Property Law vests all land in the state and grants users concessions rather than freehold. Perpetual concessions are available to Congolese nationals; foreigners obtain ordinary long-term concessions.

Because the state owns all Congolese land outright, what is bought and sold is a concession, not the soil. That distinction structures every mining, forestry and urban development transaction in the country, and the interaction between registered concessions and unregistered customary occupation is the principal source of land conflict.

Fully digital land registration (tinglysning) without a notary

Denmark runs a fully digital land register at the Land Registration Court, so transfers are recorded electronically without a notary. Estate agents and banks usually handle the conveyance and mortgage registration.

Non-residents generally need permission to buy a Danish home unless they have lived in Denmark for five years, a rule that catches many foreign buyers.

State-dominated land holding with registered title and long leases

Land is largely state-held, with private rights taking the form of registered title in urban areas or long-term concessions. Registration follows the French cadastral model administered by the domain and land registry services.

Most land is in the state domain and private holding derives from grants, concessions or urban titles rather than from an unbroken chain of private ownership. In practice this makes the concession the central instrument for commercial development, particularly around the port and the free zones, where long leases rather than freehold underpin investment. Registered urban title does exist and can be mortgaged, which supports a limited mortgage market concentrated in Djibouti City. Customary pastoralist use rights over rangeland in the interior are socially real but weakly reflected in the register, so conflicts between formal grants and existing users are resolved administratively more often than judicially. Expropriation for public purpose is available to the state on compensation under the general civil-law framework.

Title by Registration Act with a state-guaranteed register

Dominica operates a Torrens-style system under the Title by Registration Act, in which the registered certificate of title is conclusive evidence of ownership. Transfers are effected by registered deed and take effect on registration, not on execution. Non-nationals acquiring land above a threshold require an alien landholding licence, and the citizenship by investment programme channels much foreign acquisition through approved real estate projects.

Because the register is conclusive, a purchaser who registers in good faith takes free of most unregistered interests, which makes a search of the register the decisive step in conveyancing rather than a chain of historic deeds. Overriding interests are narrow but real, and short leases and public rights of way can bind a purchaser without appearing on the title.

Ley 108-05 with a Torrens register and specialist land courts

Ley 108-05 on registro inmobiliario established a Torrens-style system in which the certificado de título issued by the Registro de Títulos is conclusive proof of ownership. Disputes are heard by specialised Tribunales de Tierras, divided between original jurisdiction for first registration and appellate jurisdiction. Foreign buyers face no general restriction on owning land, and the transfer tax is charged on the assessed value.

The critical distinction is between land already covered by a certificado de título, where the register can be relied on, and land still held under older possessory documents such as a carta constancia, where the boundaries and the extent of ownership may not be settled. Buying the latter without completing the deslinde survey and first registration process is the most common source of Dominican property litigation.

Registro de la Propiedad inscription completes the transfer

Ecuador follows the Chilean Bello tradition: a notarial deed followed by inscription in the cantonal Registro de la Propiedad performs the tradición that transfers ownership. Municipalities administer the registries and levy the alcabala transfer tax and a capital-gains style plusvalía charge on the increase in value.

Because registries are municipal under the COOTAD, procedures and fees differ between cantons, and the certificado de gravámenes must be obtained from the specific canton where the property sits. The plusvalía tax on the gain between purchase and sale prices is calculated by the municipality and, unlike the alcabala, falls on the seller.

Registered title plus a very large unregistered urban stock

Ownership and registration are governed by the Civil Code and the Real Estate Registration Law, but a substantial share of urban housing was built without permits and is held on unregistered contracts.

The gap between formal title and actual occupation is the defining feature of Egyptian property practice. Registration is slow and costly enough that many transfers are documented by successive unregistered sale contracts, which are enforceable between the parties but do not convey registered title, so a buyer must trace a chain of contracts rather than consult a register. Rent control under the pre-1996 laws still governs a large legacy stock at frozen rents, and Law 4/1996 applies market terms only to tenancies created after it, producing two parallel rental regimes in the same building. Foreign natural persons face limits on the number and size of properties they may hold, and desert and border land, including Sinai, is subject to separate national-security restrictions.

Unified registry and cadastre, with an agricultural ownership cap

Title is registered at the Centro Nacional de Registros, which merged the property registry and the cadastre into a single institution, making El Salvador's land records comparatively reliable. The Constitution caps rural landholding at 245 hectares.

Order both the registry certification and the cadastral sheet, because legacy folios sometimes predate georeferencing. Transfer tax is 3% above a statutory threshold, and the notary withholds it on completion.

State ownership of untitled land with a registration system

Land legislation vests untitled land in the state and provides for registration of private title. Urban development in Malabo and Bata has driven expropriation and resettlement, and surface rights for hydrocarbon operations are separately regulated.

Because most land is untitled and vested in the state, and because oil revenue funded large-scale construction, expropriation and compensation have been the dominant property questions rather than conveyancing between private owners.

All land is state-owned under the 1994 Land Proclamation; holders receive usufruct

Land Proclamation 58/1994 vested all land in the state, replacing customary village tenure with allocated usufruct rights. Implementation has been uneven and demobilised service members were a priority allocation category.

The 1994 Proclamation was a deliberate break with the customary systems — diesa village rotation and tselmi lineage tenure — that had governed highland agriculture for centuries, replacing them with state ownership and individual usufruct allocated by administrative decision. The stated aims were to end fragmentation and to provide for demobilised fighters. Implementation has been partial and uneven across regions, and in many areas customary practice continued alongside or instead of the statutory scheme, so the position on the ground frequently differs from the proclamation. Usufruct is heritable but not saleable, which limits land as collateral and constrains any mortgage market. Urban housing allocation and the treatment of property of Eritreans abroad have both been contentious. There is no accessible register or case law to verify current practice.

Notarised transfers on a digital Land Register

Real-estate transfers must be notarised and are entered in the Land Register (kinnistusraamat). Estonia's e-notary and digital register make the process fast despite the notarial requirement.

Even with a mandatory notary, the digital register means title can often be updated within days of signing.

Swazi Nation Land held in trust by the King alongside title-deed land

Land divides into Swazi Nation Land, held by the King in trust for the nation and allocated through chiefs by khonta, and title-deed land held under Roman-Dutch ownership and registered in the Deeds Registry. Swazi Nation Land cannot be sold or mortgaged, which sharply limits its use as security.

The two-tier structure is the defining feature of Eswatini property law and the primary obstacle to rural credit: roughly 60 per cent of land is Swazi Nation Land, allocated by chiefly grant under khonta, held without registrable title, and therefore outside the mortgage market entirely.

All land is owned by the state and the people; you hold use rights, not title

Article 40(3) vests all land in the state and in the peoples of Ethiopia and forbids sale. Rural holders have use rights under Proclamation 456/2005; urban land is held on lease under Proclamation 721/2011.

This is the single most consequential feature of Ethiopian private law and it survived the change of economic policy after 1991 intact. Because land cannot be sold, what changes hands is a use right or a lease, and the security of that right depends on registration and on the terms of the municipal lease rather than on freehold title. Buildings can be owned outright and mortgaged, which creates the practical workaround: lenders take security over the structure and over the leasehold interest. Expropriation Proclamation 1161/2019 improved compensation, moving from a formula based on displacement costs toward one closer to replacement value, after sustained criticism that urban expansion around Addis Ababa was displacing holders for inadequate sums. Rural certification programmes have registered a large share of smallholdings, and the evidence is that certification meaningfully increased investment in the land, which is why the programme continued across governments.

About 88% iTaukei land, inalienable and leased through the TLTB

The defining feature of Fijian property law: roughly 88% of land is iTaukei (indigenous) land held communally and inalienable. It cannot be bought. It is leased, and only through the iTaukei Land Trust Board.

Land falls into three classes: iTaukei land vested in the landowning mataqali and administered by the iTaukei Land Trust Board, state land, and a small freehold remnant of roughly 8% created before the protective legislation. A foreign buyer is therefore almost always acquiring a LEASE, not a title, and that lease needs TLTB consent for each subsequent dealing. Two further traps: freehold residential purchases by non-residents are restricted, and agricultural tenancies under the Agricultural Landlord and Tenant Act carry their own renewal and compensation regime that does not follow ordinary lease logic. Verifying the class of land and the remaining lease term is the first step in any transaction, not the last.

Registration at the National Land Survey with a public purchase witness

Ownership is registered at the National Land Survey (Maanmittauslaitos), and a traditional property sale must be confirmed by a public purchase witness or completed through the electronic trading system.

Buyers of shares in a housing company (asunto-osakeyhtiö), the usual form for flats, acquire shares rather than land, so different rules apply than for a house.

Notarised transfers on a French-tradition register, open to foreign buyers

Sales of real estate are executed by a notaire and published at the service de publicité foncière; there are no nationality restrictions on buying. Notaire fees and transfer duties add substantially to the price.

The 10-day withdrawal period after the compromis is a key protection for private buyers and cannot be waived.

Torrens-style registration with extensive state ownership

Land is registered under a system derived from the French régime foncier, with unregistered land treated as state domain. Forest land, which covers most of the country, is allocated by concession under the Forest Code rather than sold.

In a country that is roughly 85% forest, the operative property regime for most of the territory is concession under the Forest Code, not freehold title. Community forest rights were recognised in the 2001 Code but their implementation has been slow.

State land and customary tenure under the Lands (Regions) Act, with leasehold the practical norm

Land is divided between State Lands in designated urban areas and customary land in the regions. The State Lands Act 1990 provides for leasehold grants in declared areas, while the Lands (Regions) Act governs customary tenure administered by District Authorities, and non-citizens generally require government consent to hold interests.

In areas declared State Lands under the State Lands Act 1990 — principally Banjul, Kanifing and parts of the West Coast Region — the state holds the radical title and grants leases, typically for 99 years, registered under the Land Registry. Outside those areas the Lands (Regions) Act preserves customary tenure, with land held by families and communities and administered by Alkalolu (village heads) and District Authorities, and dealings requiring their involvement. The Physical Planning and Development Control Act regulates subdivision and use. Non-citizens can generally acquire only leasehold and require ministerial consent. Overlapping customary and statutory claims, informal allocations by village heads and multiple sales of the same plot are the recurring litigation pattern, and the absence of a comprehensive cadastre has been repeatedly identified in reform proposals. Compulsory acquisition under the Lands Acquisition and Compensation Act requires a public purpose and compensation.

A fast, reliable public registry with restrictions on agricultural land

Ownership is governed by the Civil Code and registered with the National Agency of Public Registry. Registration is constitutive and can be completed within a day. Ownership of agricultural land by foreign nationals is constitutionally restricted.

Georgia's public registry is one of the fastest in the region, with same-day or next-day registration and full electronic search, and registration is what creates the right. The position on agricultural land has moved back and forth: the 2017 constitutional amendments established that agricultural land is a resource of special importance and may as a rule be owned only by the state, self-governing entities and Georgian citizens, and the 2019 law implements that. Non-agricultural real estate can be freely acquired by foreigners. Mortgages are registered and enforcement through the registry is comparatively quick.

A conclusive Grundbuch and the abstraction principle

Ownership is proved by the Grundbuch land register, which good-faith buyers can rely on. German law separates the sale contract from the transfer of title (the abstraction principle), and both need notarisation.

There are no nationality restrictions on buying, but buyers should budget notary, land-registry and Land-specific transfer-tax costs on top of the price.

Land Act 2020 consolidated the law and capped customary leaseholds for non-citizens

The Land Act 2020 (Act 1036) consolidated more than a dozen statutes. Around 80% of Ghanaian land is customary, held by stools, skins and families; the Constitution bars freehold grants to non-citizens and caps their leaseholds at 50 years, and the Act reinforces customary land secretariats and registration.

Act 1036 is a genuine consolidation, repealing the Conveyancing Decree, the Land Registry Act, the State Lands Act and others. It confirms the four customary tenure holders — stools, skins, clans and families — as allodial owners, with the state holding public and vested lands. Article 267(5) of the Constitution prohibits the creation of freehold interests in stool land, so even citizens generally take leaseholds; non-citizens are limited to 50-year leases under article 266. The Act requires customary land secretariats to keep records, provides for adjudication of boundary disputes, criminalises land guard activity, and sets out compulsory acquisition procedures with compensation at market value — an improvement on the previous regime. Registration operates through the Lands Commission, with title registration in designated districts and deeds registration elsewhere, and the persistence of two systems plus overlapping customary claims remains the main source of litigation.

Notarial transfers, the transition to a national cadastre and a lawyer-led diligence culture

Real-estate transfers require a notarial deed and registration, and Greece is completing a shift from the old mortgage-registry system to a modern national cadastre. Leases are governed by the Civil Code with specific commercial-lease rules.

Title chains can be long and fragmented, so a full lawyer's title search plus an engineer's certificate on planning compliance is standard practice.

Deeds and Land Registry Act with alien landholding control

Grenada uses a deeds registration system under the Deeds and Land Registry Act, so title depends on the chain of registered deeds rather than a conclusive state-guaranteed register. Conveyancing therefore requires a historic title search. Non-nationals must obtain an alien landholding licence before acquiring land, and much foreign investment in real estate is routed through approved citizenship by investment projects.

The difference between deeds registration here and the Torrens style register in Dominica or Saint Lucia is practical and expensive: a Grenadian purchaser buys the seller's title as it stands and must investigate the chain, so title insurance and thorough searches matter. Family land held in undivided shares among many heirs is common and frequently blocks development until a partition action is brought.

Registered title alongside unresolved indigenous land claims

Title passes by notarial deed registered in the Registro General de la Propiedad. Two structural issues dominate practice: a cadastre that is still incomplete outside surveyed zones, and collective indigenous landholding that the registry was never designed to record.

Always order a certificación registral and, where available, a cadastral report before purchase. Double registration and overlapping fincas are real risks in rural areas. Municipal transfer arbitrio and the 3% IVA or stamp charge apply depending on whether the seller is a habitual trader.

Code foncier et domanial 1992 with state ownership and weak registration

Ordonnance O/92/019 vests unregistered land in the state and provides for titling, but registration coverage is very low. Mining concessions granted over customarily occupied land are the main source of high-value land conflict.

Because most Guinean land is unregistered and legally vested in the state, bauxite concessions can be granted over land that communities have farmed for generations without any recorded interest. Compensation and resettlement therefore operate through mining conventions and IFC performance standards rather than through the land code, which is the practical reason those conventions are the documents that matter.

Lei da Terra 1998 vesting land in the state with customary use rights

Lei n° 5/98 vests all land in the state and grants private use rights (direito de uso privativo) rather than ownership. Customary tenure is recognised for rural communities, and concessions for cashew and mineral development are granted over community land.

Because the 1998 Land Act converts all holdings into use rights held from the state, there is no freehold to sell, and security of tenure depends on the administrative concession. The Act's recognition of customary tenure through community land commissions was progressive in design, but the commissions were never fully established across the country, leaving most rural tenure undocumented.

Dual Roman-Dutch transport and Torrens registration systems

Guyana operates two parallel land systems: the older Roman-Dutch conveyance by transport passed in open court under the Deeds Registry Act, and a Torrens-style title registration under the Land Registry Act operating in declared land registration areas. Which applies depends on where the land is, and the two require entirely different conveyancing.

The transport system is a genuine curiosity of Commonwealth property law: title passes when the transport is granted by a judge in open court after advertisement and the opportunity for opposition, a direct survival of Dutch colonial practice. Because the Torrens system applies only in declared areas, the first question in any Guyanese land transaction is which regime governs the parcel, as the searches, documents and timelines differ completely.

Code civil of 1825 with deeds registration and pervasive title insecurity

Property law follows the Code civil of 1825, closely modelled on the French code, with transfers effected by notarial deed and recorded at the Direction Générale des Impôts, which holds the registry function. There is no comprehensive cadastre covering the country, and overlapping claims, unregistered inheritances and informal occupation are widespread. Foreign nationals face limits on the size of land they may hold and require authorisation for larger acquisitions.

The absence of a national cadastre means that in Haiti a title search is a reconstruction exercise rather than a register check, and the same parcel may carry multiple notarial deeds from different chains. Acquisitive prescription is therefore not a marginal doctrine but a central mechanism by which possession hardens into ownership, and long undisturbed occupation is often the strongest evidence available.

Inalienable patrimony and extraterritorial properties in Italy

There is no private real-estate market inside the State; property belongs to the Holy See or the State and is administered by APSA. The Lateran Treaty also grants extraterritorial status and tax immunity to designated properties in Italy.

A lease of an extraterritorial building is still governed by canonical alienation limits, so private-law assumptions about landlord freedom do not apply.

Instituto de la Propiedad registry and a coastal restriction

The Instituto de la Propiedad administers a unified registry covering land, commerce and intellectual property. Foreigners face a constitutional restriction on land within 40 km of coastlines and borders, with a narrow urban-plot exception.

Coastal purchases by foreigners are commonly structured through a Honduran company, but the structure must be genuine as simulation risks nullity. Order a full registry study, because overlapping titles from earlier reform programmes are common on the north coast.

A constitutive land register and strict farmland rules

Title passes on registration in the land register (földhivatal) rather than on the contract, so the deed is only the first step. Acquisition of arable land is confined largely to qualified Hungarian farmers, a regime repeatedly litigated before the Court of Justice.

The register shows a pending application as a marginal note, so always check for a widow's right of residence or an existing pre-emption note before paying the deposit.

Registration at the district commissioner with limits on foreign ownership

Real-estate transfers are registered with the district commissioner (sýslumaður). Ownership of land by non-EEA nationals is restricted and generally requires ministerial permission.

Restrictions on foreign land ownership have tightened after high-profile purchases of large rural estates, so non-EEA buyers should check current permission rules.

State-level land law, and RBI rules on who may buy

Land is a state subject, so registration and stamp duty differ by state. Non-resident Indians may buy residential and commercial property; other foreign nationals generally cannot without RBI permission, and nobody may buy agricultural land.

RERA 2016 was a substantial consumer reform: projects above a size threshold must register, deposit seventy percent of receipts in a dedicated escrow account, and face adjudication before state RERA authorities rather than ordinary courts. Title remains deed-based with no state guarantee, so encumbrance certificates and a thirty-year title search remain standard. Benami transactions are prohibited and property can be confiscated under the 1988 Act as amended.

Hak Milik for citizens only, with Hak Pakai for foreign residents

The Basic Agrarian Law of 1960 created a hierarchy of land rights in which freehold (Hak Milik) is reserved to Indonesian citizens. Foreigners with residence permits may hold Hak Pakai (right of use), and foreign-invested companies use Hak Guna Bangunan (right to build). Adat (customary) land rights are recognised and coexist with the registered system.

Hak Milik (freehold) is available only to Indonesian citizens. Hak Pakai is available to foreign residents, now for terms up to 30 years extendable. Hak Guna Bangunan runs up to 30 years, extendable by 20 and renewable, and is the standard PT PMA right. Adat land held by customary communities is recognised under Article 3 of the Basic Agrarian Law. Nominee arrangements where a citizen holds Hak Milik for a foreigner are void and unenforceable — a recurring source of total loss. Always verify whether land is registered and whether adat claims exist; the two systems overlap in many regions.

Deed registration, and a constitutional bar on foreign land ownership

Title is registered with the Deeds and Properties Registration Organisation. Foreign nationals cannot generally acquire land, and acquisitions by foreign entities require government approval.

Registration is constitutive for immovable property, and the registered deed (sanad) is the primary evidence of title. The Civil Code's property provisions are a codification of Shi'a jurisprudence rather than a reception of French law, though the drafting shows French influence. Restrictions on foreign ownership are significant: acquisition by non-Iranians is subject to approval and is generally confined to residential property for those with residence rights. Endowment property (waqf) is a large category, administered separately and effectively inalienable, which surprises parties who expect a single unified register to answer the ownership question.

Registered title, restricted foreign ownership, and unresolved displacement claims

Title is registered with the Real Estate Registration Directorate under the Civil Code and the 1971 registration law. Foreign ownership of land is tightly restricted, and property claims arising from displacement remain a major unresolved issue.

The Civil Code of 1951, drafted under the influence of Abd al-Razzaq al-Sanhuri, is one of the most admired codifications in the Arab world and blends French technique with Islamic law and the Ottoman Mejelle. Registration is constitutive. Foreign natural persons generally cannot own land, with narrow reciprocity exceptions. The Property Claims Commission handles confiscations and forced displacements from 1968 onward, and successive waves of displacement since 2003 and 2014 have generated a very large backlog of competing claims, secondary occupation and destroyed records that the formal register cannot resolve on its own.

Solicitor-led conveyancing moving fully onto the Land Registry

Residential purchases are handled by solicitors, with title registered at Tailte Éireann as the older Registry of Deeds system is phased out. Stamp duty applies on the price.

Gazumping is possible because there is no binding commitment until contracts are exchanged, so buyers move quickly to contract.

Most land is state-owned and held on long lease

Approximately 93 percent of land in Israel is owned by the state, the Jewish National Fund or the Development Authority, and is administered by the Israel Land Authority. What is transacted is usually a long lease, typically 49 or 98 years, rather than freehold.

The dominance of state land ownership is the single most important structural fact. Basic Law: Israel Lands prohibits transferring ownership of state land, so long leasehold is the norm and lease terms, renewal and capitalised payments to the Israel Land Authority are central to any transaction. The Land Law of 1969 replaced Ottoman and Mandate land law with a modern registration system, and registration in the Tabu is what perfects title, though many rights remain recorded only in Israel Land Authority or company records pending registration. The Sale (Apartments) Law gives off-plan purchasers strong protections including mandatory guarantees against developer insolvency.

Notarial transfers, land registers and regulated residential leases

Transfers of real estate are executed by notarial deed and recorded in the property registers, with the notary responsible for checks and taxes. Residential leases follow statutory models under Act 431/1998, including a controlled-rent option.

Cadastral and building-compliance irregularities are a frequent deal-breaker, and an unregistered lease is unenforceable and exposes the landlord to penalties.

Rural land law of 1998 requiring certificates convertible to title within a statutory window

Loi n° 98-750 reserves rural land ownership to Ivorian nationals and required customary holders to obtain a certificat foncier convertible into a Titre Foncier. The original ten-year window proved unworkable and has been repeatedly extended.

The 1998 rural land law is inseparable from the ivoirité conflict: by reserving rural ownership to nationals it unsettled decades of Burkinabè and Malian farming in the west, and land disputes were a proximate cause of violence there. Successive extensions of the certification deadline reflect both administrative incapacity and the political impossibility of enforcing dispossession at scale.

Torrens title registration under the Registration of Titles Act

Jamaica operates a Torrens system: the register is the title, and a registered proprietor takes free of unregistered interests apart from limited exceptions such as short leases and fraud. The Registration of Titles Act governs transfer, mortgage and caveat, and the National Land Agency maintains the register. Older land held under common-law conveyancing still exists and must be brought onto the register before it can be dealt with in the ordinary way.

The practical work in a Jamaican conveyance is confirming that the vendor is the registered proprietor and that no caveat or unsatisfied mortgage sits on the title, because the register is conclusive. Where land is still unregistered, the first registration process requires proof of a chain of title and is materially slower, which is why development land is often registered well before it is sold.

Freehold open to foreigners, but registration is not conclusive

Foreign nationals may own land and buildings on the same terms as citizens, with no residence requirement. Registration gives priority against third parties but is not a state guarantee of title.

Land and the building on it are distinct pieces of property with separate registers, so a sale can involve one without the other. Registration determines priority between competing claims rather than proving ownership, so title investigation remains necessary. The Act on Land and Building Leases gives strong protection to tenants of ordinary leases, making recovery of possession difficult, which is why fixed-term business leases are drafted with care. Japan's large stock of vacant akiya houses has prompted municipal transfer schemes with renovation obligations.

A reliable Torrens-influenced register, with reciprocity-based foreign ownership

Title is registered with the Department of Land and Survey under a system of registered title. Foreign nationals may own property subject to Cabinet approval and reciprocity with their home state.

Jordan's land register is among the better-maintained in the region, with cadastral survey coverage that makes title searches genuinely informative. The 1976 Civil Code follows the Sanhuri model, blending French structure with Islamic law. Foreign ownership operates on reciprocity: nationals of states that permit Jordanian ownership may acquire, subject to Cabinet approval, with residential holdings generally permitted and agricultural land restricted. The 2019 consolidation simplified procedures. Waqf property is administered separately by the Ministry of Awqaf and is effectively outside the market.

Private ownership of buildings, but agricultural land closed to foreigners

The Land Code permits private ownership of land for citizens and Kazakh legal entities. Foreign nationals may own buildings and hold land on long lease, but not own agricultural land.

Foreign individuals and foreign-controlled entities are barred from owning agricultural land, a restriction reaffirmed after public protests, and long leases to foreigners over farmland were also curtailed. Residential and commercial property may be owned outright, including by foreigners, though a residence permit is needed in practice for some transactions. Land-use rights for industrial projects are typically granted by lease of up to 49 years. Mortgages are registered and enforceable, with a notarised or judicial route to sale.

The 2012 land statutes, replacing a fragmented colonial regime

The Land Act, Land Registration Act and National Land Commission Act of 2012 replaced several colonial-era statutes with a single framework. Land is classified as public, community or private, community land was given statutory form in 2016, and non-citizens may hold land only on leases of up to 99 years.

The 2012 reforms were mandated by the 2010 constitution and dismantled a system in which several parallel registration regimes coexisted. The most consequential innovations were the constitutional cap on foreign leasehold at 99 years, which converted existing freeholds held by non-citizens into leases, and the Community Land Act's creation of registrable community title for land previously held as trust land by county councils.

Customary native land, inalienable to non-citizens, with a Lands Court

Land is customary native land held under the Native Lands Ordinance and administered through the Lands Court, and it cannot be sold to non-citizens. Scarcity is extreme and worsening with erosion.

Native land is held under custom by family groups, with entitlement recorded in registers maintained since the colonial period and determined by the Magistrates Court sitting in its lands jurisdiction. Non-citizens cannot own it; the state leases land for public and commercial purposes and sublets. Two special regimes sit alongside: Banaba, whose phosphate lands were mined out and whose community was resettled in Fiji, retains distinct statutory treatment, and the Christmas Island group has its own arrangements reflecting later settlement. The physical dimension is acute — total land area is roughly 811 square kilometres of low atoll, and coastal erosion and saltwater intrusion are removing usable land and freshwater, which makes land law inseparable from climate adaptation.

Real property ownership closed to most foreign nationals

Foreign nationals other than GCC citizens generally cannot own real property in Kuwait. This is the most restrictive position in the Gulf.

The restriction is the defining feature and it is a genuine prohibition rather than a licensing hurdle: non-GCC foreign nationals cannot buy residential or commercial land, with narrow exceptions for Arab nationals meeting residence and reciprocity conditions and for diplomatic premises. There is no designated freehold zone equivalent to Dubai's or Doha's. Foreign businesses therefore lease, and long leases are the standard structure. GCC nationals have limited ownership rights that are still not equivalent to Kuwaiti nationals. Anyone extrapolating from UAE or Qatari practice will reach the wrong answer here.

Citizens only for agricultural land; foreigners lease instead

The Land Code allows private ownership, but agricultural land may be owned only by citizens. Foreign nationals and foreign entities may own buildings and hold land under lease.

Agricultural land is restricted to citizens, with leases to foreigners limited in term, and pasture is managed collectively by pasture committees rather than individually owned. Residential and commercial buildings may be owned by foreigners outright, and apartment ownership is common. Registration is constitutive of the right, so an unregistered transfer does not bind third parties. Mortgage is available and enforced by notarised sale or court order.

All land is owned by the national community; only rights are held

Under the Land Law, land belongs to the national community with the State as administrator. Lao citizens hold land use rights that function much like ownership, but foreigners and foreign entities cannot. Foreigners may lease state land for up to 50 years, and the 2019 Land Law introduced a limited route for foreign individuals to hold rights over residential units against an investment threshold.

Land is nationally owned; citizens hold transferable and inheritable land use rights. Foreigners and foreign entities may lease state land, generally up to 50 years, extendable. Concessions for large projects are granted under the Investment Promotion Law. Land titles are registered, but a large proportion of rural land remains untitled. Untitled land held by customary use is common; acquiring rights over it carries significant risk of competing claims. Village and district authorities must certify many transactions, which adds real time to transfers.

Corroboration in the Land Register through sworn notaries

Ownership is established by corroboration in the Land Register (zemesgrāmata) kept by the district courts, with sworn notaries authenticating transactions. A stamp duty applies on registration.

Latvia's Land Register is regarded as reliable, and corroboration gives strong protection to a registered good-faith owner.

A French-influenced register, and foreign ownership by decree above a size threshold

Title is registered under the 1926 land registration decrees. Foreign acquisition requires a Council of Ministers decree above defined area thresholds and is capped as a proportion of each district.

The land register created under the French Mandate is well-organised in principle, with cadastral survey covering most of the country. Law No. 296 of 2001 liberalised foreign acquisition, permitting up to 3,000 square metres without a decree and larger holdings with Council of Ministers approval, subject to a cap of 3 per cent of the area of any district — a provision with a clear confessional-demographic purpose. Shared ownership of buildings is governed by a distinct 1983 condominium law. Records in areas affected by the civil war and by the 2020 port explosion present practical difficulties that the register alone does not resolve.

All land vested in the Basotho Nation, allocated as leases under the Land Act 2010

Land is vested in the Basotho Nation and held in trust by the King. Private interests take the form of leases granted under the Land Act 8 of 2010, administered by the Land Administration Authority. Allocation in rural areas involves chiefs and Community Councils, and the 2010 Act notably allowed women to hold allocated land in their own right.

There is no freehold in Lesotho. Every private interest is a lease from the nation, and the 2010 Act's removal of the bar on women holding allocated land was one of the more consequential gender reforms in Southern African property law.

The Land Rights Act 2018 recognised customary land as private community property

The Land Rights Act 2018 is one of Africa's more far-reaching land reforms: it classifies land as public, government, customary or private and recognises customary land as the collective private property of communities, requiring community consent for concessions. Article 22 restricts ownership to citizens, and citizenship to persons of Negro descent.

Historically most rural land was treated as public land subject to state disposal, with communities holding only usufruct — the legal foundation of large rubber and mining concessions. The Land Rights Act 2018 changed that by recognising customary land as owned by the community as private property, whether or not surveyed or deeded, and requiring formal community self-identification, boundary harmonisation and the establishment of a Community Land Development and Management Committee. Concessions on customary land require the community's free, prior and informed consent, and women must be represented in community governance structures. The Liberia Land Authority Act 2016 created a single land agency replacing the Land Commission and the deeds registry functions. The constitutional restriction in article 22, read with the article 27(b) citizenship rule, means non-citizens cannot own land and may only lease, typically for terms up to fifty years renewable. Implementation — surveying and formalising thousands of communities — is the central practical challenge.

Unresolved Gaddafi-era confiscations over a civil-law property base

The Civil Code of 1954 supplies the law of property, but Law 4/1978 confiscated most private rental property and redistributed it, and the resulting competing claims have never been comprehensively resolved.

Law 4/1978 is the central fact in Libyan property law: it transferred ownership of rented residential property to occupiers and abolished most private landlordism, generating two sets of claimants to the same assets. Partial restitution and compensation measures followed in the 1990s and after 2011 but no comprehensive settlement was reached, so title investigation in Libya means tracing pre-1978 ownership, the redistribution, and any subsequent restitution decision. Registry records were damaged or lost in some areas during the conflict, and displacement has produced further layers of occupation without title. Foreign ownership of land is restricted, and long leases through Libyan vehicles are the practical route for projects.

Ownership through a land register, with tight limits on foreign buyers

Property law follows the Austrian civil-law tradition, with ownership passing on entry in the land register (Grundbuch). Acquisition of real estate is closely restricted, particularly for non-residents and foreigners, reflecting the scarcity of land in a very small state.

Buying property is difficult without residence and a demonstrated need, which keeps the market small and largely closed to outside investors. Transactions run through the land register with official authorisation.

Notarised transfers registered at the Centre of Registers

Real-estate sales under the 2001 Civil Code are notarised and registered in the Real Property Register kept by the Centre of Registers. Registration gives the transfer effect against third parties.

Acquisition of agricultural land faces area limits and priority rights, so rural purchases need extra checks beyond an ordinary home.

Napoleonic ownership, notarial deeds and registration transfer duties

Property law follows the Civil Code in the French tradition: ownership transfers by contract, but the transaction is executed by notarial deed and made enforceable against third parties through the mortgage registry. Buyers pay registration and transcription duties on acquisition.

The notary handles verification, duties and registration, and the main-residence tax credit is a significant relief that buyers should claim. Very high property values make duties a material cost to budget for.

2005-2006 land reform recognising local certificates alongside titled land

The 2005 land policy and Loi 2006-031 broke with the French presumption of state ownership of untitled land, recognising private untitled occupation and creating communal guichets fonciers that issue certificats foncierscheaper and faster than a full title. Foreign nationals cannot own land outright and use long leases instead.

The 2005-2006 reform is one of the most studied land reforms in Africa because it abandoned the presumption of domanialité — that untitled land belongs to the state — and decentralised recognition of occupation to elected communes, making certification achievable for smallholders who could never have obtained a full title.

Land Act 2016 recognising customary estates and abolishing freehold conversion

The Land Act 16 of 2016 and the Customary Land Act 19 of 2016 restructured tenure, creating the registrable customary estate administered by Land Committees and Traditional Land Management Areas. Public land, private land and customary land are the three categories, and the Acts provided for the conversion of remaining freehold to leasehold.

The 2016 reform's central innovation is the customary estate: a registrable, inheritable and mortgageable interest held under customary law, which was intended to bring the majority of Malawian land into a system where it can secure credit without extinguishing customary administration.

Torrens title, with state consent and price floors for foreign buyers

Peninsular Malaysia uses a Torrens system under the National Land Code 1965, where registration confers indefeasible title. Foreign acquisition requires state authority consent and is subject to minimum purchase price thresholds that vary by state, generally RM 1 million or above. Malay Reserve Land cannot be transferred to non-Malays at all.

Registration under the National Land Code confers indefeasible title. Foreign purchase requires state consent and meets a minimum price threshold set by each state. Malay Reserve Land is inalienable to non-Malays. Sabah and Sarawak have separate land ordinances and their own consent regimes. Minimum purchase thresholds for foreigners differ materially between states — check the specific state, not a national figure. Real Property Gains Tax applies on disposal at rates that step down with holding period, and is higher for foreign owners.

Constitutional ban on foreign freehold, with a narrow reclaimed-land exception

Foreign ownership of land is constitutionally prohibited. A 2015 amendment permitted freehold for very large investments involving substantial land reclamation, but the ordinary route remains long leasehold.

The 2015 amendment allows freehold where an investment exceeds one billion US dollars and at least seventy percent of the relevant area is reclaimed from the sea — a threshold so high that it has not reshaped ordinary practice. Maldivians hold land under state grants recorded by the relevant council. For commercial purposes, what is traded is a leasehold interest plus the right to operate, and lenders take security over the lease and revenues.

Code domanial et foncier 2000 with state ownership and an agricultural land law

Ordonnance n° 00-027 vests untitled land in the state and provides for titling. The 2017 Loi sur le foncier agricole recognises customary agricultural rights and creates village-level land commissions.

The 2017 agricultural land law was significant for creating village land commissions with authority to record customary rights, giving farmers a document short of full title. In central Mali those commissions have become entangled in the farmer-herder conflict, because recording cultivation rights over transhumance corridors intensifies precisely the dispute the commissions were meant to settle.

Notarial deeds, the Land Registry and restrictions on non-resident purchases

Property transfers are executed by notarial deed, with the notary responsible for searches and tax. Acquisition by non-residents can require an AIP permit outside designated areas, and long emphyteusis remains a common tenure.

Registration is still being rolled out area by area, so many titles rely on the notarial deed chain rather than a registered title.

Inalienable customary land held through matrilineal bwij, no freehold sale

Almost all land is customary and cannot be sold. Rights are layered between the iroijlaplap, the alap and the dri jerbal, and disputes go to the Traditional Rights Court.

Land is the central institution of Marshallese law. Rights are held by the bwij, a matrilineal lineage, and descend through the mother's line. Three interests coexist in the same parcel: the iroijlaplap holds paramount title, the alap is the lineage head managing the land, and the dri jerbal are the workers with rights of use and residence. None of these can be extinguished by sale, and the constitutional protection of traditional rights in article X means legislation cannot simply override them. Practically, every outside project is a lease negotiation with all interest-holders, and identifying who must consent is the hard part. The Traditional Rights Court determines customary questions and its findings carry substantial weight with the High Court. The nuclear testing legacy adds a further layer: displaced communities from Bikini and Enewetak hold claims and trust arrangements distinct from ordinary tenure, and the Nuclear Claims Tribunal made awards exceeding two billion dollars that remain largely unpaid because the Compact fund was exhausted.

Land reform of 1983 abolishing traditional tenure in favour of state grants

Ordonnance n° 83-127 declared land the property of the nation and abolished the traditional tenure system, providing for individual concessions. Implementation in the Senegal River valley displaced Afro-Mauritanian farming communities and remains contested.

The 1983 land ordinance is inseparable from Mauritania's ethnic politics. By abolishing traditional collective tenure and requiring individual application for concessions, it enabled reallocation of fertile Senegal River valley land during the period in which tens of thousands of Afro-Mauritanians were expelled in 1989-1990. Restitution for returnees remains an unresolved grievance.

French Civil Code ownership with a torrens-style register and restrictions on non-citizens

Property law is governed by the Code Civil Mauricien, derived from the Code Napoléon, so ownership, servitudes and the hypothèque follow French concepts. Transcription in the Registrar-General's office gives effect against third parties. Non-citizens may acquire residential property only within approved schemes such as the IRS, RES and PDS.

This is the clearest illustration of the Mauritian hybrid: the substantive law of ownership is French and the deeds are drawn by notaries in the civil-law manner, while the conveyancing overlay and the investor-scheme regime are statutory and Commonwealth in style.

The restricted zone and the fideicomiso workaround

Article 27 of the Constitution bars foreigners from direct ownership of land within 100 km of a border or 50 km of the coast. In practice foreign buyers hold coastal residential property through a bank trust, the fideicomiso, or through a Mexican company for non-residential use.

Always obtain a certificate of no liens and confirm the property is not ejido before paying a deposit. Notaries are strictly territorial, so use one in the state where the land sits.

Constitutional bar on non-citizen land ownership, tenure governed by state law

Article XIII prohibits acquisition of land by non-citizens. Tenure itself is customary and governed state by state, so outside use proceeds by lease.

Article XIII, section 4 provides that a non-citizen, or a corporation not wholly owned by citizens, may not acquire title to land or waters, which is a constitutional prohibition rather than a policy that could be relaxed by ordinary legislation. Everything foreign investors do therefore rests on leasehold, and lease terms are limited and regulated differently in each state. Underlying tenure is customary and varies substantially: Yap retains strongly hierarchical estate and clan structures, Pohnpei has both customary and some registered individual holdings following German-era reforms, Kosrae has more individualised title, and Chuuk remains predominantly lineage-based. Registration is incomplete everywhere, so ownership is frequently proved by evidence of custom and genealogy before a state land commission rather than by a title certificate. Identifying every consenting interest-holder is the recurring practical difficulty.

A unified cadastre with restrictions on farmland for foreigners

Real property rights are recorded in the cadastre maintained by the Public Services Agency, and registration is required for the right to arise. Foreign citizens and companies may not acquire agricultural or forest land and must dispose of any inherited plot.

Property in Transnistria cannot be reliably registered or transferred under Moldovan law, and any transaction there is outside the cadastre and effectively unenforceable in Chişinău.

Open to foreign buyers, executed by notary, in one of the priciest markets

Property law follows the French civil-law tradition, and there are no nationality restrictions on buying real estate. Transactions are executed by a notary and registered, with registration and notarial fees on the price, in what is among the most expensive property markets in the world.

The notary is central to verifying title and handling duties, and buyers should budget substantial transaction costs. Because owning does not automatically confer residence, buyers pursuing residency must still meet the carte de séjour conditions.

Citizens only for land ownership; foreigners take use rights

Land may be owned only by Mongolian citizens. Foreign individuals and companies may hold land-use or possession rights for defined terms, and may own buildings outright.

Possession rights run for up to 60 years and are renewable once for up to 40 years; shorter use rights are also available. Buildings are treated separately from land, so a foreign company can own an office building while holding only a use right in the plot. Every citizen has a one-time entitlement to a free plot for family housing. Pasture land is held in common and cannot be privatised, which matters for any project affecting herding routes.

Cadastre-based ownership with broad rights for foreign buyers

Ownership is acquired on registration in the real-estate cadastre, and foreign natural and legal persons may generally acquire property on the same terms as nationals, with limits on agricultural and border land.

Illegally constructed buildings are widespread on the coast, so verify building and use permits, not just cadastral entry.

Three coexisting land regimes: registered, unregistered melk, and collective

Land is held under the Torrens-style registered system, under customary melk title evidenced by adoulaire deeds, or as collective tribal, habous or guich land, each with different transfer rules.

The registered system confers title that is definitive and effectively unchallengeable once immatriculation is complete, which makes registration status the first question in any Moroccan property transaction rather than a formality. Unregistered melk land is transferred by notarial or adoulaire deed and carries genuine title risk, because the chain rests on documents rather than on a register. Collective land, historically inalienable and held by ethnic communities under the supervision of the Ministry of Interior, was opened to privatisation by Law 62-17 in 2019, which is a significant and recent change to a category covering millions of hectares. Foreign nationals may not acquire agricultural land, and long leases are the standard workaround.

All land owned by the state, with DUAT use rights that cannot be sold

The Constitution and the Lei de Terras (Lei 19/97) provide that all land is the property of the state and cannot be sold, mortgaged or otherwise alienated. Private parties hold a DUAT — direito de uso e aproveitamento da terra — a use right acquired by state grant, by occupation in good faith for ten years, or by customary occupation. Buildings and improvements can be owned and transferred, and a DUAT transfer requires state authorisation.

This is the most restrictive land regime covered in the atlas. Because land itself is inalienable, Mozambican real-estate finance is built on mortgaging the buildings and the DUAT's transferable value rather than the land, and customary occupation is a recognised original mode of acquiring a DUAT — meaning a community can hold a legally protected right without any document at all.

No foreign land ownership; long leases through investment permits

The Transfer of Immovable Property Restriction Act bars foreigners from owning land or taking leases beyond one year. The route for investors is a Myanmar Investment Commission permit allowing leases of up to fifty years plus two ten-year extensions.

The 2016 Condominium Law permits foreign ownership of up to 40 percent of units above the sixth floor of a registered condominium, but registration of qualifying buildings has been slow, so the practical stock is small. Land titling is incomplete and overlapping claims are common, particularly where customary tenure meets statutory classification, and the 2018 amendment to the Vacant, Fallow and Virgin Land Law criminalised unauthorised occupation of land many communities had farmed for generations. Since 2021 land dispute resolution has been unreliable and military-linked expropriation risk is material. Verified title searches are difficult to obtain.

Deeds registration over freehold with communal land under land boards

Freehold land is held under Roman-Dutch ownership and registered in the Deeds Registry. Communal land, which covers much of the north, is administered under the Communal Land Reform Act through Communal Land Boards that issue customary land rights and leaseholds. Commercial agricultural land is subject to a state right of first refusal on sale.

Namibia's land question is structurally about the boundary between the two systems: registered freehold concentrated in the commercial farming areas, and communal tenure elsewhere, with the state's preferent right the main instrument of redistribution rather than expropriation.

Fractional customary ownership and land destroyed by phosphate mining

Land is customary and cannot be sold to non-Nauruans. Ownership is fragmented into fractional shares among many family members, determined by the Nauru Lands Committee, and much of the interior is mined-out wasteland.

Nauruan land tenure is unusual in that customary ownership is individual but fractional: a single portion may be owned in undivided shares by dozens of people through generations of inheritance, so obtaining consent to any dealing can be practically impossible. The Nauru Lands Committee determines ownership and succession, with appeal to the Supreme Court. Non-Nauruans cannot own land at all. Overlaying this is environmental devastation — strip mining of phosphate left roughly 80% of the island as pinnacled limestone unfit for habitation or agriculture. Nauru sued Australia in the International Court of Justice over rehabilitation, settling in 1993, and the Rehabilitation Corporation continues work intended to make the interior habitable.

Foreign individuals cannot own land; approved companies can

Foreign natural persons may not own land in Nepal. A company registered in Nepal with approved foreign investment may hold land needed for its industry, and long leases are otherwise used.

The 2017 Civil Code consolidated property, contract and family law into one code, replacing the old Muluki Ain — a major recodification that renumbered much of Nepali private law, so older citations are frequently stale. Land ceilings apply by district and land type. Title is registered at the Land Revenue Office and mutation is the operative step; guthi (religious trust) land carries restrictions that can defeat an apparently clean transfer.

Notarial transfer, a public Kadaster register, and a low transfer tax for owner-occupiers

Ownership of immovable property passes by a notarial deed of transfer registered in the Kadaster, the public land registry, which gives the system its reliability. Transfer tax (overdrachtsbelasting) is 2% for a home the buyer will occupy, with a starters' exemption for qualifying young first-time buyers, and 10.4% for investment property.

The 2% owner-occupier rate and the starters' exemption both require the buyer to actually live in the property, and misuse is checked; the value cap for the exemption is adjusted each year. Apartment ownership is held through a mandatory owners' association (VvE).

Land Transfer Act 2017 Torrens title with a two-year bright-line test

Torrens title under the Land Transfer Act 2017 with electronic conveyancing, restrictions on foreign buyers of residential land, and a bright-line test taxing short-term residential gains.

Registration confers indefeasible title, and conveyancing is fully electronic through Landonline, so settlement is typically same-day. Since 2018 residential land is classified as sensitive under the Overseas Investment Act, and overseas persons generally cannot buy existing homes — Australian and Singaporean citizens are exempt by treaty. Māori freehold land is governed by Te Ture Whenua Māori Act 1993 and administered by the Māori Land Court; it is subject to alienation restrictions and preferred classes of alienee designed to keep land within the owners' whānau, so it cannot be dealt with as ordinary freehold.

Registered title over an unresolved confiscation legacy

Title is registered in the Registro Público de la Propiedad Inmueble. Two overlapping problems dominate: unresolved claims from the 1980s reform-era confiscations, and post-2018 seizures of property belonging to closed NGOs, universities and exiled critics.

Commission a full historical chain search rather than a current-folio certificate. Property connected to confiscated entities carries a title defect that no amount of registry formality cures, and international claims remain open.

Rural Code of 1993 with commissions foncières recording customary rights

Ordonnance n° 93-015 established the Principes d'Orientation du Code Rural, creating a network of commissions foncières that record customary land and water rights, including transhumance corridors, rather than requiring conversion to title.

Niger's Rural Code is widely cited as an African innovation because it records pastoral as well as agricultural rights, mapping transhumance corridors and water points to reduce farmer-herder conflict, and the 2010 pastoral ordinance recognises mobility itself as a protected right. Implementation is uneven, but the model has been studied across the Sahel.

The Land Use Act vests all land in state governors and replaced ownership with rights of occupancy

The Land Use Act 1978 vested all land in each state in the Governor, held in trust for the people. Private parties hold statutory or customary rights of occupancy rather than freehold, and the Governor's consent is required for any transfer, mortgage or sublease — the central friction in Nigerian conveyancing.

The Land Use Act is entrenched by s.315(5) of the Constitution, so it cannot be amended by ordinary legislation. It vests all land in the state in the Governor, who grants statutory rights of occupancy in urban areas while local governments grant customary rights of occupancy elsewhere. Section 22 requires the Governor's consent for alienation, and without it a transaction is inchoate — the Supreme Court in Savannah Bank v Ajilo confirmed the consequences. Certificates of Occupancy evidence title but are not conclusive. Compulsory acquisition for overriding public interest is permitted under s.28 with compensation limited largely to unexhausted improvements rather than market value of the land itself, which is the standing criticism of the regime. Perfection of title therefore involves consent, stamping and registration, and the delay and cost of the consent process is a well-documented constraint on the mortgage market.

No private land ownership; housing held by allocation

All land is owned by the state or by cooperatives. Housing is allocated administratively rather than bought, though an unofficial market in occupancy rights is widely reported.

Because ownership is not private, what changes hands in practice is a use or occupancy entitlement, transferred informally and without enforceable registered title. Published civil law recognises personal property in household goods and some produce. There is no mortgage market and no mechanism by which a foreign person could acquire land. Reporting on the informal housing market comes from defector testimony and satellite analysis rather than official statistics, so it is indicative rather than verified.

Cadastre registration with reciprocity limits on foreign ownership

Ownership of real estate is acquired on registration in the real-estate cadastre maintained by the Agency for Real Estate Cadastre. Foreign persons may acquire property subject to reciprocity, with agricultural land restricted.

Cadastral digitisation is comparatively advanced, so online verification of title and encumbrances is usually possible.

Registration in the land register (grunnboka) at Kartverket

Ownership is recorded in the land register (grunnboka) maintained by the Norwegian Mapping Authority. Transfers are registered without a notary, and a document duty applies.

Many Norwegian homes are cooperative shares rather than directly owned property, so buyers must check which regime applies before bidding.

Foreign freehold limited to integrated tourism complexes

Non-GCC foreign nationals can own freehold only within Integrated Tourism Complexes. Elsewhere ownership is restricted to Omanis and, more narrowly, GCC nationals.

The ITC model is the whole of foreign freehold in Oman: designated integrated resort developments such as Al Mouj and Muscat Bay where foreign buyers take freehold and, above a value threshold, residence. Outside them a non-GCC foreign national cannot buy land, and long lease or usufruct is the alternative. GCC nationals have wider but still not equivalent rights. This makes Oman more restrictive than Bahrain and the UAE and less restrictive than Kuwait, and the distinction between an ITC and an ordinary development is the first thing to establish in any transaction.

Provincial land law, deed registration, and no general bar on foreign ownership

Land law is provincial. Transfer is governed by the Transfer of Property Act 1882 and registration by the Registration Act 1908; foreign nationals may generally own property, subject to restrictions in cantonment and border areas.

Punjab and Sindh have computerised land records, which has materially reduced tampering, but title remains deed-based and diligence still means tracing the mutation chain and checking for attachment or litigation. Housing-society allotment letters are widely traded and are not title. Stamp duty and capital value tax vary by province, and cantonment board land carries separate restrictions and transfer procedures.

Citizens only may own land, with matrilineal clan title and a Land Court

The Constitution restricts land ownership to Palauan citizens. Much land is clan-held through matrilineal descent, and title claims are determined by the Land Court.

Article XIII, section 8 confines land ownership to citizens, and because citizenship requires Palauan descent the restriction is durable rather than transitional; a corporation must be wholly citizen-owned to hold land. Foreign use is by lease, and statute caps lease duration, so long-horizon investment is structured around renewal risk. Underlying tenure is substantially customary: land is often held by a clan and controlled through matrilineal descent, with senior women holding decisive voices in clan land decisions, which surprises advisers who assume chiefly authority is exclusively male. A large body of Land Court litigation arises from the return of lands taken during Japanese and Trust Territory administration, where claimants prove entitlement through genealogy and customary evidence rather than documentary title. Determining who can validly grant a lease is consequently the central diligence question in any Palau transaction.

Ottoman categories, incomplete registration, and Israeli land administration in Area C

Land law rests on Ottoman categories carried through Mandate and Jordanian legislation. Registration is incomplete across much of the West Bank, and Area C land administration is exercised by Israeli authorities.

Ottoman categories — mulk, miri, waqf, matruka and mawat — still determine what rights exist, and the distinction matters because Israeli authorities have used the mawat and unregistered miri categories to declare land state property in Area C. Title settlement under the Mandate and Jordanian programmes was never completed: roughly a third of the West Bank was systematically registered before 1967, and settlement was frozen thereafter, so most holdings rest on tax records, unregistered deeds and possession. This evidentiary weakness, not the substantive law, is the practical heart of most Palestinian land disputes.

Foreign ownership permitted, with a coastal and border limit

Foreigners may own titled property on the same terms as nationals, and Panama has a reliable public registry. The constitutional restriction is narrow: land within 10 km of a national border cannot be foreign-owned, and islands and coastal areas are subject to concession regimes and to rights of possession that are not the same as title.

Insist on a registry certificate and a survey before paying anything for rights of possession — buying unconverted posesorio is the single most common way foreign buyers lose money in Panama.

About 97% customary land, unregistered and inalienable

Roughly 97% of PNG's land is customary land held by clans under custom, outside the registered title system entirely. Only about 3% is alienated land available for ordinary dealing.

The 97% figure is the single most important fact in PNG property law. Customary land cannot be sold to non-citizens and is generally not registered, so ownership is proved by genealogy and custom rather than by a title search — which makes competing clan claims a routine feature of project work. Access is achieved through mechanisms such as lease-leaseback, where the State leases land from customary owners and leases it back to a developer, and through Incorporated Land Groups under the 1974 Act. The lease-leaseback route was heavily abused in the Special Agricultural and Business Leases affair, which a commission of inquiry found had transferred vast areas without genuine landowner consent; several were cancelled. Any land transaction here demands verification of both the group's authority and the history of the instrument.

Escritura pública and Dirección General de Registros Públicos inscription

Real property transfers require a public deed before a notary and inscription in the Dirección General de Registros Públicos, which perfects the right against third parties. Foreigners face restrictions on rural land within 50 kilometres of the border under Ley 2532. Land tenure disputes and informal occupation of rural land remain significant practical issues.

The border security zone restriction bars foreign nationals of neighbouring countries from owning rural land within 50 kilometres of the frontier, a rule aimed principally at Brazilian ownership in the eastern border region and subject to executive exemption. Title verification should also check the cadastral records of the Servicio Nacional de Catastro, since discrepancies between registry and cadastre are common in rural areas.

SUNARP registration and large-scale urban titling through COFOPRI

Ownership of real property is transferred by contract under the Código Civil, but registration in SUNARP's Registro de Predios is what makes the right effective against third parties. Peru ran an internationally studied urban land-titling programme through COFOPRI, formalising millions of informal settlement plots. Foreigners cannot own land within 50 kilometres of the border without authorisation.

Peru is one of the clearest examples of consensual transfer combined with a priority-by-registration rule: as between two buyers from the same seller, the one who registers first prevails even if the other contracted earlier. The COFOPRI programme is frequently cited in development literature for converting informal possession into registered, mortgageable title at scale.

Constitutional bar on foreign land ownership, with condominium units permitted

Only Filipino citizens and corporations at least 60 percent Filipino-owned may own land. Foreigners may own condominium units where foreign ownership in the project stays within 40 percent, and may lease land long-term.

Foreigners may acquire land only by hereditary succession, and former natural-born Filipinos may acquire limited areas for residence or business. Investors may lease private land for fifty years renewable by twenty-five under the Investors' Lease Act. Because title fraud and double titling are real risks, a certified true copy of the title from the Registry of Deeds plus a tax declaration and tax clearance check are standard. Agrarian reform imposes retention limits and requires DAR clearance for conversion of agricultural land, which frequently delays development projects. Estate and donor's taxes were flattened to 6 percent by the TRAIN Act, simplifying family transfers considerably.

Land and mortgage registers with public faith protection

Ownership is recorded in the land and mortgage register (księga wieczysta), which enjoys a presumption of accuracy and protects a good-faith purchaser. Transfers of real property require a notarial deed to be valid.

Check the register online by its number before paying anything; entries in section III and IV reveal claims and mortgages that a seller may not mention.

Land registration, notarial or lawyer-certified deeds and controlled urban leases

Ownership and charges are recorded in the Land Registry, and transfers are made by public deed or by a lawyer- or solicitor-certified private document. Urban tenancies are governed by the Urban Lease Act as amended by successive housing reforms.

Check the caderneta predial and the licence of use as well as the registry certificate; irregular licensing is a common obstacle to sale.

Designated freehold zones for foreign buyers

Foreign nationals may own freehold in designated areas including the Pearl and Lusail, and leasehold of up to ninety-nine years elsewhere.

Law 16 of 2018 widened foreign ownership considerably, taking the designated freehold areas from three to around ten and creating usufruct rights for up to ninety-nine years in a further set of areas. Ownership above a value threshold carries residence entitlement, which is the main practical driver of foreign purchase. Registration is constitutive rather than evidential, so an unregistered sale does not transfer title however complete the contract. Qatari nationals and GCC citizens are treated differently from other foreign nationals, and GCC treatment is not identical to national treatment.

State-held land with a 2004 registration reform

The 2004 land laws restructured tenure and registration, recognising customary occupation as a basis for converting to registered title. Most land nonetheless remains unregistered and held under customary arrangements.

The 2000–2004 reforms were unusual in explicitly acknowledging customary tenure as a route into the register rather than treating it as a nullity, though the administrative cost of conversion has limited take-up.

A land book system still in the middle of systematic registration

The Civil Code of 2011 makes registration in the land book constitutive of title, but only in areas where systematic cadastral registration has been completed, so in much of the country the old contract-based transfer still applies transitionally.

Restitution claims from the communist era still surface, so an extract for information plus the litigation history of the plot matters as much as the current land book entry.

A unified state register where registration creates title

The unified state register of real property (EGRN), maintained by Rosreestr, merged the cadastre and the rights register in 2017. Registration is constitutive, and the register entry rather than the contract is what proves ownership.

The 2023 privacy change means a buyer can no longer confirm the owner's identity from a public extract, so an extract obtained by the seller personally has become a standard due diligence requirement.

Universal land registration completed, with all land leasehold from the state

The 2013 land law vests land in the state, with private holders having emphyteutic leases of up to 99 years. Rwanda completed a nationwide systematic land registration programme between 2009 and 2013, registering over ten million parcels — the first African state to achieve near-universal coverage.

The systematic land registration programme is Rwanda's most cited legal-administrative achievement: using local adjudication committees and low-cost demarcation, it registered essentially all land in the country in four years and issued titles recording spousal co-ownership by default, which substantially strengthened women's land rights in practice rather than only on paper.

Title by Registration Act with separate Nevis land administration

Land title is registered under the Title by Registration Act, with the register conclusive as to ownership. Land is a matter on which the Nevis Island Administration has competence, so Nevis land administration and its alien landholding policy operate separately from Saint Kitts. Non-nationals require an alien land holding licence in either island, and property purchase is a qualifying route under the citizenship by investment programme.

The federal structure means a Nevis purchase must be checked against Nevis requirements and licences rather than the Basseterre process, and the two islands have at times applied different policies to foreign acquisition. Citizenship by investment real estate purchases carry a minimum holding period before resale, which should be built into any exit plan.

Land Registration Act with civilian property concepts

Saint Lucia completed a systematic land adjudication and registration programme, and title now rests on the register maintained under the Land Registration Act, supported by the Land Adjudication Act. Substantive property concepts, however, come from the Civil Code, so usufruct, emphyteusis and civilian servitudes appear on titles. Non-nationals require an alien landholding licence to acquire land.

The register is the source of title, so the older deed chains matter only for interpreting what was adjudicated. The civilian overlay is the practical difference from neighbouring states: a usufruct registered against a parcel gives the holder enjoyment for life without ownership, and acquisitive prescription can perfect a possessory claim in a way that the common law of adverse possession would not.

Deeds registration with alien landholding control

Saint Vincent and the Grenadines uses a deeds registration system administered by the Registrar of the High Court, so title depends on the chain of recorded deeds rather than a conclusive register, and a historic title search is essential. Non-nationals require an alien landholding licence before acquiring land, which is particularly relevant to villa and yacht-related development in the Grenadines. Adverse possession can perfect title after twelve years.

The Possessory Titles Act provides a statutory route to convert long possession into a declared title, which is important because undivided family land is widespread and often blocks sale or development. In the Grenadines, high-value transactions frequently uncover defective chains, so title investigation should begin well before exchange rather than during it.

About 81% customary land, constitutionally inalienable

Roughly 81% of Samoa is customary land held under fa'a Samoa and constitutionally protected from alienation by article 102. It cannot be sold. The Land and Titles Court, not the Supreme Court, decides customary entitlement.

Article 102 prohibits the alienation of customary land, with a narrow exception permitting leases and licences authorised under statute — so a development on customary land proceeds by lease granted with ministerial authorisation, never by purchase. Entitlement to customary land and to matai titles is determined by the Land and Titles Court applying custom, and its jurisdiction is exclusive: the Supreme Court cannot substitute its own view of who holds a title. The 2020 reforms restructured that court and gave it its own appellate tier, which was the central controversy of the constitutional debate. Freehold exists as a small colonial remnant and is registered conventionally.

Registered title with restrictions on acquisition by non-residents

Property is transferred by notarial deed and recorded in the land and cadastral registers. Acquisition by foreign nationals and non-residents is subject to authorisation and quantitative limits.

Because the territory is tiny and supply fixed, the authorisation regime is used deliberately to restrain non-resident acquisition.

Sharia-based ownership with restricted foreign acquisition

Real property is registered and protected, but foreign ownership is restricted and acquisition in Mecca and Medina is subject to particular limits.

Before 2023 the rules on sale, possession and transfer of land were derived from fiqh reasoning; the Civil Transactions Law now supplies them in enacted form, which makes title analysis considerably more tractable. Foreign ownership is permitted for licensed investment purposes and for residents in defined circumstances, but it is a licensing question rather than a freely exercisable right, and the restrictions on non-Muslim ownership in the two holy cities are absolute rather than administrative. Waqf endowments hold a substantial share of urban land and property subject to waqf is effectively inalienable, which is a common and expensive surprise in transactions.

Loi sur le domaine national 1964 vesting most land in the state

Loi n° 64-46 placed unregistered land in the domaine national, administered by rural councils that allocate use rights. Titling is possible but limited, and urban land pressure in Dakar drives most litigation.

Because the 1964 Act vested roughly 95 per cent of Senegalese land in the state as domaine national, most occupation rests on administrative allocation rather than ownership, and the decentralisation of allocation to local councils made those councils the decisive actors in land disputes. Large agricultural concessions granted over allocated land have generated sustained conflict in the Senegal River valley.

Registration-based ownership with notarised contracts and reciprocity for foreigners

Ownership of real estate is acquired on registration in the real-estate cadastre. Sale contracts must be solemnised by a notary, and acquisition by foreign natural and legal persons is subject to reciprocity rules.

Notaries submit registration applications directly, and legalisation of unregistered buildings remains a widespread practical issue.

French Civil Code ownership with land registration and sanction for non-citizen purchases

Property law rests on the Civil Code of Seychelles, derived from the Code Napoléon, with ownership and the hypothèque following French concepts. Registration is under the Land Registration Act. Non-citizens require government sanction to acquire immovable property, and an immovable property tax applies to non-citizen owners.

The Civil Code of Seychelles Act 2020 was a significant modernisation, replacing the 1976 code and restating French-derived private law in English in a single contemporary statute — a rare instance of a mixed jurisdiction deliberately re-codifying its civil-law half.

A dual land system: freehold in the Western Area, customary tenure in the provinces

Land law divides territorially. In the Western Area land may be held in freehold and is registered under the general law; in the provinces land is vested in communities and administered by Paramount Chiefs, and non-natives historically could obtain only leasehold. The Customary Land Rights Act 2022 reformed provincial tenure.

The Western Area, as a former colony, operates a general-law system with freehold estates, conveyancing and deeds registration under the Registration of Instruments Act. The provinces, as former protectorate, are governed by the Provinces Land Act, under which land is held by chiefdom communities and a non-native could not acquire freehold, only a lease with the consent of the chiefdom authority — the source of long-running disputes over large agricultural concessions. The Customary Land Rights Act 2022 and the National Land Commission Act 2022 are the major reform: they recognise customary land rights as equivalent in security to statutory rights, require the free, prior and informed consent of landowning families for large-scale acquisitions, provide for spousal and community consent, prohibit acquisitions in ecologically sensitive areas, and create a National Land Commission with district structures to record rights. Implementation is at an early stage, so practitioners must check both the new Acts and the surviving provisions of the Provinces Land Act.

Torrens title, 99-year leases and Additional Buyer's Stamp Duty on foreigners

Most land is registered under the Land Titles Act, and the state is the dominant landowner. Foreigners face a 60 percent Additional Buyer's Stamp Duty on residential purchases and need approval to buy landed property.

Registered title under the Torrens system is guaranteed by the state, so the register is conclusive subject to fraud and statutory exceptions. Private residential leases are commonly 99 years, and freehold is a minority of stock. The Residential Property Act bars foreigners from buying landed residential property or vacant land without Land Dealings Approval Unit consent; apartments and condominium units are generally open. ABSD for foreign buyers reached 60 percent in April 2023, on top of Buyer's Stamp Duty, and Seller's Stamp Duty applies to disposals within three years. HDB flats are effectively closed to foreigners other than as tenants.

Cadastre registration with separate building and land ownership

Ownership is registered in the cadastre of real estate and passes on registration. Unlike Czechia, Slovakia retained the possibility of separate ownership of a building and the land beneath it, a frequent source of practical complication.

Standard registration takes 30 days, but an expedited fee reduces it to 15, and until registration completes the buyer has only a contractual claim.

Constitutive land registration with notarised contracts

Ownership passes on entry in the land register, which is fully electronic. Contracts must be notarially certified to be registrable, and leases of residential property are regulated by the Housing Act.

Land-register filings are made electronically by notaries or lawyers, and priority runs from the moment of filing.

About 87% customary land; only citizens hold perpetual estates

Roughly 87% of land is customary land outside the register. Registered land is held as a perpetual estate, which by law only Solomon Islanders may hold — foreigners are limited to fixed-term estates.

The perpetual estate is reserved to citizens, so a foreign investor or spouse can hold only a fixed-term estate — a rule that catches many buyers who assume they are purchasing freehold. Customary land is held by lineages under custom and is not registered; converting it into registered form requires a statutory acquisition process, and disputes over who holds the customary right go first to chiefs, then to Local Courts, with appeal to the Customary Land Appeal Court rather than through the ordinary civil hierarchy. Logging agreements executed without proper identification of the customary owners are a recurring source of litigation and cancelled licences.

Competing claims under statute, custom and religion after decades of dispossession

Pre-1991 legislation nationalised land and records have largely been destroyed or falsified. Claims now rest on a mixture of old titles, customary occupation, Islamic principles and possession, and urban land disputes are pervasive.

The 1975 Agricultural Land Law vested land in the state and granted leasehold, and it was used before 1991 to transfer productive riverine land away from minority agricultural communities, particularly in the Shabelle and Juba valleys. Collapse of the state in 1991 was followed by widespread forcible occupation, destruction of registries and the creation of fraudulent titles, so multiple parties frequently hold apparently valid documents for the same parcel. Urban land in Mogadishu is among the most contested property anywhere, with returning diaspora claims, displaced-person settlement, and evictions from informal settlements. Dispute resolution runs through a mixture of municipal authorities, sharia courts, xeer elders and, in some areas, al-Shabaab courts, which are widely reported to be used because they are fast and enforce their decisions. No verifiable unified tenure system exists.

Deeds registration with a constitutional expropriation clause and strict eviction rules

Ownership is proved by registration in a deeds registry under the Deeds Registries Act 47 of 1937, a negative but highly reliable system in which transfer is effected by a conveyancer and registration confers real right. Section 25 of the Constitution protects property while expressly permitting expropriation for a public purpose or in the public interest, including land reform, against just and equitable compensation.

Two facts dominate practice. First, no eviction of an unlawful occupier from land or a home is lawful without a court order made after considering all relevant circumstances — PIE reversed the common-law position decisively, and the courts require that the availability of alternative accommodation be canvassed. Second, the Expropriation Act 13 of 2024 replaced a 1975 statute that predated the Constitution; it sets out factors for just-and-equitable compensation and provides for nil compensation only in narrowly specified circumstances, and its practical operation is still being tested.

The jeonse lump-sum lease, and registration that does not guarantee title

Ownership is registered, but Korean law gives the register no public warranty: a buyer must verify the chain of title. The distinctive jeonse tenancy takes a large refundable deposit instead of monthly rent.

Because registration is not conclusive, transactions rely on careful title investigation and, increasingly, insurance. Under jeonse the tenant pays 50 to 80 per cent of the property value as a deposit, recoverable at the end of the term, and the landlord keeps the investment return. Tenants secure priority for the deposit by registration or a dated endorsement plus occupation, and the Housing Lease Protection Act gives a minimum two-year term and a right to renew once. Deposit-return failures during price falls are a recurring source of litigation.

Land belongs to the people, administered through communities under the 2009 Land Act

The Land Act 2009 vests land in the people of South Sudan and recognises community land alongside public and private categories. Customary tenure governs most holdings, and displacement has made competing claims widespread.

The 2009 Act is unusually explicit in recognising community land as a full category rather than treating custom as a residue, and it requires community consultation and consent for acquisitions affecting community holdings. That drafting choice reflects the pre-independence experience of large concessions granted over occupied land. In practice, repeated displacement since 2013 has produced overlapping claims: people return to find land occupied, boundaries between communities are contested, and cattle-related conflict interacts with grazing access. Registration coverage is minimal, so proof of right is normally testimonial and mediated by traditional authorities rather than documentary. Large agricultural leases granted around independence attracted criticism for inadequate consultation. Given displacement and the absence of a functioning register, current tenure security cannot be described with confidence.

Notarial deeds, the Land Registry and strong regional variation in leases

Ownership passes by contract and delivery, but the notarial deed plus entry in the Property Registry is what secures the buyer against third parties. Urban leases are governed by the Urban Leases Act, with important regional and municipal overlays.

Always obtain a nota simple from the registry before purchase: it reveals charges, mortgages and whether the seller is the registered owner.

Roman-Dutch land law, with foreign freehold effectively closed

Land law is Roman-Dutch in substance, with notarially executed deeds registered under the Registration of Documents Ordinance. Foreign nationals and foreign-controlled companies cannot acquire freehold title; the 2014 prohibition channels them into leases of up to 99 years instead. Title registration under the Bim Saviya programme is being rolled out gradually alongside the older deeds system.

Conveyances must be executed before a notary public to be valid. Foreign persons and companies with foreign shareholding above the threshold are barred from freehold; leases up to 99 years are permitted. Prescriptive title can be acquired by ten years' adverse possession under the Prescription Ordinance. Condominium units are governed by the Apartment Ownership Law. Deeds registration is not title registration — a chain-of-title search back at least 30 years is standard practice. Whether a parcel has been converted to Bim Saviya title changes the search entirely, so check its status first.

Registered title over a minority of land, with unregistered land vested in the state

The Land Settlement and Registration Act 1925 established registration, and the Unregistered Land Act 1970 vested all unregistered land in the state. Customary holdings across much of the country therefore lack formal title, which is central to the Darfur conflicts.

The 1970 Act is the historically decisive instrument: by declaring all unregistered land to be state property it converted customary holdings across the west and south into occupation without title, and the resulting insecurity is directly implicated in the land and grazing conflicts in Darfur and Kordofan. Registration under the 1925 regime was concentrated in the Nile valley and the irrigated schemes, so the map of formal title tracks the historical centre of the state rather than the distribution of population. Hawakeer, the customary tribal land administration in Darfur, has no clean statutory equivalent, and successive peace agreements including the 2020 Juba Agreement promised land commissions and restitution mechanisms that were not established before the current war. Given mass displacement and the destruction of records, current land administration cannot be verified.

Registration by notarial deed with state land and grondhuur tenure

Property transfers require a notarial deed registered with the Glis (Grondregistratie en Land Informatie Systeem). Much land is state-owned and held under grondhuur, a long-term leasehold, rather than freehold. Indigenous and tribal collective land rights have been the subject of binding Inter-American Court judgments against Suriname.

Grondhuur is the practically dominant tenure and is granted by the state by resolution, so the security of a Surinamese land interest often depends on administrative allocation rather than a private purchase chain. The Inter-American Court's judgments in Moiwana, Saramaka and Kaliña and Lokono require Suriname to recognise and demarcate collective indigenous and tribal territory, an obligation that remains substantially unimplemented in domestic legislation.

Registration of title (lagfart) at Lantmäteriet, without a notary

Real-estate transfers are completed by written contract and registered as title (lagfart) with the mapping and land-registration authority Lantmäteriet. No notary is required.

Most Swedish apartments are bostadsrätt memberships rather than owned real estate, so different rules and association approval apply to their transfer.

Ownership through a public land register, with real limits on foreign buyers

The Civil Code governs ownership, which passes on entry in the cantonal land register (Grundbuch) after a public deed. A distinctive feature is Lex Koller, the federal law restricting the acquisition of Swiss real estate by persons abroad, which requires authorisation for many purchases by non-residents.

Lex Koller is the decisive issue for foreign buyers: holiday-home quotas are limited and vary by canton, and buying without required authorisation makes the transaction void. Land-register and notary practice is organised at cantonal level.

The Civil Code 1949, destroyed records, and the contested Law No. 10 of 2018

Property law rests on the Civil Code of 1949 and land registration legislation. Destruction of records, mass displacement and Law No. 10 of 2018 on redevelopment zones have made housing, land and property rights a central transitional issue.

The 1949 Civil Code, drafted with Sanhuri's involvement, is a respected codification. The problems are evidentiary and political. Land registry offices in several cities were damaged or destroyed, and an estimated large minority of holdings were never formally registered even before 2011. Decree 66 and Law No. 10 of 2018 allow the designation of redevelopment zones in which owners must present documentary proof of title within short periods to receive shares in the redeveloped area — a mechanism widely criticised as effectively expropriating displaced people who cannot safely return or produce documents. Housing, land and property restitution is now a core element of any transitional settlement.

State land ownership with concessions following the plantation redistribution

Most land was nationalised after independence from the former roça plantation estates and remains state-owned, with private use granted by concession or long lease. Registration is with the Conservatória do Registo Predial. Redistribution programmes have granted smallholder titles from former estate land.

The roça estates — large colonial cocoa plantations — were nationalised at independence, and the subsequent redistribution to smallholders is the origin of most current São Toméan land holdings, which is why concession and allocation records rather than deeds are often the operative documents.

All land is state property; only use rights can be held

The Constitution vests all land in the state. Nobody, citizen or foreigner, owns land — what exists is a perpetual or fixed-term land-use right, which since 2012 is transferable.

Tajikistan is the clearest case in the region of land remaining wholly state-owned. The 2012 amendments made land-use rights alienable, mortgageable and inheritable, which created a functioning market in the right without privatising the land itself. Buildings can be owned outright, including by foreigners. Agricultural reform converted collective farms into dehkan farms holding use rights, and the security of those certificates is the central rural legal issue.

All land is public land vested in the President as trustee

The Land Act and Village Land Act of 1999 vest all land in the President as trustee for the citizens. What is held is a right of occupancy — granted for up to 99 years, or customary in the villages — and freehold does not exist. Non-citizens may hold land only for investment purposes.

Tanzanian land law is the clearest African example of a deliberate refusal of freehold: the 1999 statutes preserved the socialist-era principle that land belongs to the nation, and gave customary rights of occupancy in villages the same legal status as granted rights in the towns. For an investor, the practical consequence is that land is obtained by derivative right through the Tanzania Investment Centre, never bought outright.

Foreigners cannot own land, but may own up to 49 percent of a condominium building

The Land Code prohibits foreign land ownership save for narrow investment exceptions. Foreigners may own condominium units outright, subject to a 49 percent cap on foreign ownership of the total floor area of each building.

Common workarounds each have limits: a thirty-year lease is enforceable but renewal promises bind only contractually and have failed in litigation; a Thai company holding land for a foreign beneficiary risks nominee findings; and usufruct or superficies rights give use rather than ownership. Buildings can be owned separately from the land they sit on, which is a genuine and underused route. Condominium purchases require evidence that funds were remitted from abroad in foreign currency. Transfer taxes comprise a 2 percent transfer fee, stamp duty or specific business tax, and withholding tax, usually split by negotiation.

International Persons Landholding Act with a Torrens-style quieting regime

Foreign buyers are governed by the International Persons Landholding Act 1993, which allows a non-Bahamian to acquire a single residential property of up to five acres for personal use by registering the purchase with the Investments Board, while larger or commercial acquisitions need a permit. Title is deeds-based, and the Quieting Titles Act allows a claimant to obtain a court-certified title where the chain of documents is defective. Property tax is charged annually under the Real Property Tax Act.

Because title depends on the chain of deeds and much Bahamian land has a long and imperfect documentary history, including generational and commonage land, a quieting action is a normal part of development rather than an exceptional remedy. A buyer who relies only on an abstract of title without investigating adverse possession and boundary history takes a real risk.

Unresolved title from successive colonial and occupation regimes

Land tenure is the most contested area of Timorese law. Portuguese-era titles, Indonesian-era titles and customary claims frequently overlap on the same parcel. The Special Regime for the Definition of Ownership of Immovable Property of 2017 established a process for adjudicating these competing claims.

The 2017 law is the key instrument. It provides for the collection and public display of claims, an administrative decision on ownership, and recourse to the courts where claims conflict. Where a Portuguese title and an Indonesian title compete, the law establishes rules of priority; where neither exists, long-standing possession and customary occupation can found title. Foreign nationals cannot own land outright under the Constitution, so foreign investment typically proceeds by long lease. Anyone advising on Timorese land should treat the register as incomplete rather than determinative.

Code foncier et domanial 2018 unifying a fragmented land regime

Loi n° 2018-005 consolidated colonial-era and post-independence land instruments into a single code, recognising customary rights and providing for their conversion to registered title through a defined procedure.

Before 2018 Togolese land law was spread across French colonial decrees, a 1974 ordinance and later instruments that did not fit together, producing competing claims to the same parcel. The 2018 Code's contribution is consolidation and an express procedure for recognising customary holdings, though the backlog of overlapping historic claims in and around Lomé remains substantial.

All land is Crown land; it cannot be sold, only leased

Clause 104 of the Constitution vests all land in the Crown and makes it inalienable — it may not be sold to anyone, Tongan or foreign. Interests are hereditary estates, allotments and registered leases.

This is the most restrictive property regime in the atlas. There is no freehold and no sale of land in any form. Nobles hold hereditary estates, tofi'a, and Tongan male subjects are entitled on application to a tax allotment of about 8.25 acres and a town allotment, held for life and passing by a statutory line of succession that historically favoured male heirs. Everyone else, including all foreigners and companies, must take a registered lease with Cabinet consent. Because supply of allotments has not kept up with population, many Tongans hold no allotment despite the entitlement, and informal occupation arrangements are widespread — which makes verifying the registered position essential before any transaction or development.

Dual registration under the RPA and the older common-law deeds system

Trinidad and Tobago runs two parallel systems: land brought under the Real Property Act holds a certificate of title with Torrens-style protection, while older land remains under common-law conveyancing recorded by deed at the Registrar General. Which system applies determines the searches required and the strength of the buyer's position. The Land Tribunal, established under the Land Tribunal Act 2000, hears land disputes.

For unregistered common-law land the buyer takes only what the vendor can prove through the chain of deeds, so a full title search going back many years is unavoidable, whereas an RPA certificate can largely be relied on. Converting common-law land to the RPA is possible and is often done before a sale, because it materially reduces the buyer's investigation and cost.

Registered title under the Code des Droits Réels, with restricted foreign purchase

The 1965 Code of Real Rights governs ownership and registration through the Conservation de la Propriété Foncière. Foreign acquisition of agricultural land is prohibited and other purchases need approval.

Tunisia has a substantial registered estate but also large areas of unregistered and collectively held land, and the immatriculation process that converts one to the other runs through a dedicated land court rather than the ordinary courts. Foreign nationals cannot own agricultural land at all, and acquisition of non-agricultural real property by non-residents requires authorisation from the governor, which is a genuine gate rather than a formality; long leases of up to 40 years are the standard structure for foreign-operated agricultural projects. Habous (waqf) land was largely abolished and absorbed into state or private ownership after independence, which distinguishes Tunisia from Morocco and Egypt where the category remains significant.

Title through the Land Registry with reciprocity limits for foreigners

The Civil Code governs ownership and the Land Registry Law provides for registration, which is constitutive of title. Foreign nationals may acquire real estate subject to reciprocity, area limits and military zone restrictions, and property acquisition above a threshold supports citizenship.

Registration in the Tapu creates the right; a notarised sale contract alone does not transfer ownership. Foreign individuals may own up to 30 hectares nationally and no more than 10 percent of the area of any district, and acquisitions in designated military and security zones require clearance, which is a genuine practical obstacle in some coastal areas. Condominium ownership under Law No. 634 governs apartment blocks and is the basis of most urban residential title. The Condominium and pre-sale regime, together with the 2012 urban renewal law on buildings at seismic risk, dominates development practice.

Land ownership for citizens only, in limited forms

The Land Code allows citizens to own land for housing and specified agricultural purposes. Foreign nationals and foreign entities may not own land, and may use it only by lease.

Private ownership exists in a narrow form for citizens, mainly household plots and housing, while most agricultural land remains state-owned and allocated for use under lease with production obligations. Foreign entities working on projects hold land by lease from the state. Housing demolition and relocation programmes in Ashgabat have been documented by human rights bodies as proceeding with limited compensation or remedy, which is the main practical property risk recorded for individuals.

Almost all land is customary kaitasi land, held by extended family

Land is overwhelmingly customary, held by the kaitasi — the extended family group — under the Native Lands Act, and cannot be sold to non-Tuvaluans. Leases are the only route for outsiders.

Land is held by the kaitasi, an extended family landholding group, with the head of the family administering it on behalf of members — so an individual rarely holds land alone and cannot deal with it alone. The Lands Code and Native Lands Act govern entitlement, and disputes are heard by the Lands Court and Lands Appeal Panel rather than the ordinary courts. Non-Tuvaluans cannot acquire customary land; the government leases land for public purposes and sublets. Scarcity is acute: the total land area is about 26 square kilometres, and sea-level rise and coastal erosion are physically reducing it, which gives Tuvaluan land law an existential dimension no other jurisdiction in the atlas shares.

Four tenure systems recognised by the constitution

Article 237 vests land in the citizens and recognises four tenure systems: customary, freehold, mailo and leasehold. Mailo is unique to Uganda, a quasi-freehold created by the 1900 Buganda Agreement, and the position of tenants on mailo land is the central land-law problem.

Mailo tenure is the distinctive Ugandan institution: land granted to Buganda notables in 1900 in perpetuity, on which peasant occupants have lived for generations. The Land Act 1998 protected those occupants as lawful or bona fide occupants with security of tenure, creating a divided ownership that neither registered proprietor nor occupant can unilaterally resolve — the source of most Ugandan land litigation.

An open property register and a farmland market opened in 2021

Rights in real property are recorded in the State Register of Real Property Rights, which is publicly searchable. The moratorium on sale of agricultural land ended in July 2021, and since 2024 legal entities may also buy, subject to area caps and a ban on foreign ownership.

The registers were closed for several weeks in 2022 and access is still restricted for occupied territories, so a current extract plus the wartime damage register both matter for any transaction.

Emirate-level land law with designated foreign freehold areas

Land is regulated by each emirate. Foreign nationals can own freehold only in designated areas, with Dubai and Abu Dhabi operating the largest and best-documented registers.

Because land is an emirate matter, there is no national property regime and no national register, and the designated-area rule means a foreign buyer's ability to take freehold depends entirely on the plot's location. Dubai's escrow legislation was the direct response to the off-plan failures of the 2008 crash and is the main protection for buyers of unbuilt units; verifying that payments go to the registered escrow account is the single most useful practical check. Long leasehold and usufruct of up to ninety-nine years are the usual structures outside designated areas. The DIFC and ADGM hold their own registers with their own rules, so a property inside a free zone is not governed by the emirate's register.

Registered title at HM Land Registry, with leasehold reform underway

Most land in England and Wales has registered title guaranteed by HM Land Registry. Residential purchases run through solicitors with searches and stamp duty; long residential leasehold is being reformed.

Scotland has a separate system (missives, the Land Register of Scotland and LBTT), so English guidance does not transfer north of the border.

State real property law, recording of deeds and title insurance

Real property is state law and the United States never adopted a national title register. Instead deeds are recorded county by county, the record establishes priority rather than guaranteeing ownership, and the resulting risk is managed commercially through title insurance — a product that exists because the register itself is not conclusive. Louisiana applies its own civil-law property regime.

Because priority depends on the recording statute, whether a purchaser takes free of an earlier unrecorded interest turns on whether the state is race, notice or race-notice — a distinction with no counterpart in a Torrens jurisdiction. Most states now use a deed of trust with a power of non-judicial foreclosure, which lets a lender sell without a court action and is far quicker than the judicial foreclosure required in states such as New York and Florida.

Registro de la Propiedad inscription with no restriction on foreign buyers

Real property transfers require a public deed before an escribano and inscription in the Registro de la Propiedad Inmueble, administered by the Dirección General de Registros. Uruguay places no nationality restriction on foreign ownership of land, including coastal and rural property, which distinguishes it from most neighbours.

The absence of foreign-ownership restrictions, combined with a stable registry and the escribano's professional responsibility for title study, is a significant part of Uruguay's appeal to non-resident buyers in Punta del Este and the interior. The escribano público plays a broader role than a notary in common-law systems, conducting the title investigation and being liable for its accuracy.

Land is state-owned, but 2019 reforms allowed privatisation of plots under buildings

Land remains state property as a rule, held under permanent or long-term use rights. From 2019 non-agricultural plots beneath privately owned buildings became privatisable.

The 2019 statute was a genuine change: owners of buildings on non-agricultural land can buy the plot beneath, creating private land ownership for the first time, though agricultural land is expressly excluded and remains leasehold. Buildings have always been privately ownable, including by foreigners. Compulsory demolition and resettlement for urban redevelopment generated substantial litigation and a 2019-2020 tightening of compensation rules and court authorisation requirements after public criticism.

All land returned to custom owners in 1980; only leases for others

Articles 73 to 75 of the Constitution vested all land in the indigenous custom owners at independence. Nobody else can own land — non-indigenous persons and foreigners hold leases only.

This is the most complete indigenous land restoration in the region: colonial freehold titles were extinguished, not merely restricted. The consequence is that every non-custom-owner interest is a registered lease, and the validity of that lease depends on having dealt with the right custom owners. Identifying them is the central difficulty, because custom ownership is determined by custom, not by a register. The Custom Land Management Act 2013 shifted determination of custom ownership to custom-based nakamal and Island Court processes and removed the Minister's power to grant leases over disputed custom land — a reform aimed squarely at earlier abuses where leases were issued over land whose ownership was unresolved. Due diligence must therefore examine the custom-ownership determination, not just the lease register entry.

Registro Público title with a substantial expropriation history

Real property transfers are executed by public document and registered in the Registro Público under SAREN, which perfects the right against third parties. Between 2005 and 2015 the state expropriated or occupied a large number of agricultural, industrial and commercial properties, and several resulting claims produced major ICSID arbitration awards against Venezuela.

The Ley de Tierras permits state intervention in land deemed idle or below productive capacity, and rural title is therefore materially less secure than the registry alone suggests. The expropriation wave generated a distinctive body of investment-treaty jurisprudence, with awards in cases brought by international mining, oil, glass and food companies, much of which remains unsatisfied.

All land is owned by the people, held through time-limited use rights

There is no private ownership of land: the state holds it on behalf of the people and grants land use rights, typically for fifty years for projects. Foreigners cannot hold residential land use rights but may own apartments within quota.

Land use right certificates are the tradable interest, and they are mortgageable, transferable and inheritable subject to conditions. Foreign-invested enterprises normally lease from the state or sublease serviced land inside industrial zones. Foreign individuals and entities may own apartments capped at 30 percent of units in a building and 250 houses in a ward, on ownership terms of fifty years, renewable. Compulsory acquisition for socio-economic development has been the most contested area; the 2024 Land Law narrowed the permitted grounds and moved compensation toward market-based valuation, replacing the government land price framework with annual provincial price tables.

Registered title overlaid by tribal custom and conflict displacement

The Civil Code and Land Law provide for registered ownership, but tribal custom governs much rural land and the conflict has produced large-scale displacement and disputed occupation.

Registration coverage was incomplete before 2014 and the conflict has made it worse, with records damaged or inaccessible and parallel administrations issuing documents in different areas. Tribal custom is not a residual influence in rural land but frequently the primary normative system, and customary arbitration resolves boundary and inheritance disputes that never reach a court. Mass displacement has created widespread secondary occupation of abandoned property, and waqf land holdings add a further layer. Any title question requires knowing which authority controls the area and which records survive.

All land vested in the President, held on 99-year leasehold, with customary tenure alongside

The Lands Act 1995 vests all land in the President in perpetuity, held in trust for the people. There is no freehold: the maximum private interest is a 99-year state lease, registered in the Lands and Deeds Registry. Customary land, the majority by area, is administered by chiefs and must be converted to leasehold before it can be registered or mortgaged.

The absence of freehold is the defining feature: every registered Zambian title is a leasehold from the state, and the conversion of customary land into that system — requiring chiefly consent — is the single most contested process in Zambian property practice.

Deeds registration alongside state-acquired agricultural land and 99-year leases

Urban and commercial property is held under Roman-Dutch ownership registered in the Deeds Registry. Agricultural land compulsorily acquired in the fast-track programme after 2000 vests in the state, with occupiers holding 99-year leases, offer letters or permits rather than transferable title. Communal land is administered under the Communal Land Act.

The critical practical distinction is between registrable title and the instruments issued over resettled agricultural land. A 99-year lease is not freehold and its bankability has been the central constraint on agricultural finance since 2000; section 72 of the Constitution also limits compensation for acquired agricultural land to improvements in most cases.