Ilan Leibovitch & Co.Lawyer and real estate developer
GeneralRegulation

Can Israelis Buy Property Abroad? Restrictions on Foreign Buyers by Country

Can foreigners buy property in Romania, Greece or Cyprus? One table of foreign-buyer restrictions in 8 countries: apartments, land, farmland and permits.

By Adv. Ilan LeibovitchUpdated: 8 min read
RegulationPl. VI·226

In brief

An Israeli can register an apartment or house in their own name in all eight countries covered in this guide: Romania, Greece, Cyprus, Bulgaria, Portugal, Italy, the USA and Ukraine. Restrictions on foreign buyers mainly concern land and permits: in Romania and Bulgaria land is usually bought through a local company, Cyprus requires a Council of Ministers permit, Greece requires a permit in border areas, and in Ukraine agricultural land is closed to foreigners. A passport of an EU member state removes most of the restrictions in the EU countries.

Key takeaways

  1. 1In all eight countries an Israeli may register an apartment in their own name. The differences lie in land, agricultural land and permits.
  2. 2In Romania and Bulgaria an Israeli without an EU passport cannot register land in their own name, so a house with a plot is usually bought through a local company.
  3. 3Cyprus requires a Council of Ministers permit before the title is registered, and Greece requires a permit only in border areas such as the Dodecanese and Santorini. Registration without a permit is void.
  4. 4Agricultural land is almost closed to foreigners in Romania, Bulgaria and Ukraine, even through a newly formed company.
  5. 5A passport of an EU member state removes the restrictions in Romania, Greece, Cyprus and Bulgaria, provided you actually buy with it.

"Am I even allowed to buy there?" is the first question an Israeli investor asks. The answer depends on three things: which passport will appear in the contract, what exactly you are buying (an apartment, land or agricultural land), and where the property is located. This guide brings together the restrictions on foreign buyers in eight countries in one table and refers to the detailed guide for each country. A broader comparison, which also covers tax, financing and the reliability of the registry, appears in the legal comparison of 8 countries for the Israeli investor.

Can Israelis buy property abroad?

Yes. An Israeli may register an apartment or house in their own name in all eight countries covered in this guide. Restrictions on foreign buyers are almost never a ban on buying an apartment. They concern three areas: ownership of the land itself, agricultural land, and a requirement for a prior permit before the title is registered.

It is important to understand who counts as a "foreigner". In Romania, Greece, Cyprus and Bulgaria the restrictions apply to anyone who is not a citizen of an EU or European Economic Area member state (in Greece, EFTA as well). An Israeli who also holds a Romanian, Portuguese, Polish or German passport and buys with it is treated as an EU citizen. In these countries this is sometimes the most important decision in the deal, even before choosing the property.

Restrictions on foreign buyers by country: comparison table

The table refers to an Israeli buyer who does not hold citizenship of an EU member state, and is correct as of November 2026. It summarises the rule, not every exception, so before a transaction the specific case must be checked.

CountryApartment or house in your nameLand in your nameAgricultural landPermit or special conditionLegal basis
RomaniaYesNo. Through a Romanian company (SRL) or a Superficie rightNo, and a new company does not meet the conditions of Law 17/2014 eitherNo permit. The restriction applies to land onlyLaw 312/2005, Article 6
GreeceYesYesYes. A very large plot requires approval for any buyerPermit from a committee of the decentralised administration, in border areas onlyLaw 1892/1990
CyprusYes, with a permitYes, with a permit. Above two "skales" further conditions may be addedSubject to a permit. Further restrictions have been proposedCouncil of Ministers permit before registration of titleCap. 109, Section 3
BulgariaYes, apartment and buildingNo. Through a Bulgarian company (EOOD or OOD)No, and not through a new company eitherNo permit. The restriction is in the ConstitutionConstitution, Article 22. Property Act, Article 29
PortugalYesYesYesNo general restriction. Limited restrictions in sensitive areasNo special regime for foreigners
ItalyYesYesYesReciprocity condition, which is met for IsraelArticle 16 of the Preliminary Provisions to the Civil Code
USAYesYesYes, with a report within 90 daysNo federal ban. Certain states restrict buyers from certain countries, not IsraelAFIDA (1978) and state law
UkraineYesWithin a settlement, yes. Outside a settlement, only beneath your own buildingNo. Inheritance requires disposal within one yearRegistration under martial law is restricted in certain areasLand Code, Article 81
How to read the table

"Through a company" means that a local company you own registers the land in its name. This is entirely lawful, but you hold shares rather than the property itself, which has consequences for tax in Israel and in the country of the property, for ongoing management and for financing.

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Where can an Israeli not register land in their own name?

In Romania and Bulgaria. In both countries a non-EU foreigner can own a building or an apartment, but not the land itself, unless an international treaty allows it. No such treaty with Israel has been identified in either country.

In Romania, Article 6 of Law 312/2005 provides that citizens of non-EU states acquire land only under international treaties and on the basis of reciprocity. A house with a plot is therefore usually registered with the house in the buyer's name and the land held under a Superficie right, or everything is registered in the name of a Romanian company (SRL), which is a Romanian legal person even when its shareholders are Israeli. We set out the routes in the guide to buying land in Romania as a foreigner, and the differences between nationalities in the table of who can buy in Romania by passport.

In Bulgaria, Article 22 of the Constitution and Article 29 of the Property Act allow foreigners to acquire buildings and limited property rights, but land only under an international treaty or through statutory inheritance. An apartment in a multi-unit building is registered directly in the buyer's name. A house with a garden, a villa or a building plot is usually bought through a Bulgarian company, most often an EOOD. We explained the structure and its costs in the guide to buying land in Bulgaria through a company.

Which countries require a permit to buy property as a foreigner?

Cyprus always, and Greece only in border areas. In both countries a transaction registered without the permit is void, so the permit is a condition of the deal, not a formality.

In Cyprus, Section 3(1) of the Acquisition of Immovable Property (Aliens) Law, Cap. 109, prohibits an alien from acquiring immovable property without the prior permission of the Council of Ministers, which in practice is granted through the District Officer. The permit is required before registration of title, not before signing, so the contract is deposited with the Land Registry immediately and the application is filed in parallel. Where the area exceeds what is needed for a residence or business premises, and in any case exceeds two "skales", the law allows the permit to be made subject to further conditions. As of September 2026 the government and the House of Representatives were discussing proposals to tighten the regime, so the state of the law is checked on the day of signing. See the guide to the Council of Ministers permit in Cyprus.

Greece has no general restriction on foreigners. However, under Law 1892/1990 a buyer who is not an EU or EFTA citizen needs a prior permit to acquire a right in a property located in a border area. The permit is issued by a committee of the regional decentralised administration, and a positive vote of the Ministry of Defence representative is required. The border areas include, among others, all the Dodecanese islands (Rhodes, Kos and others), Santorini, Lesvos, Chios, Samos and the Evros area. The prohibition also applies to transfers of shares in a company that holds such a property. See the guide to the permit for buying in Greek border areas.

Do not pay a large deposit before the permit

When the transaction depends on a permit, the contract should provide that obtaining the permit is a condition and that the deposit is refunded in full if the application is rejected. In Cyprus the equivalent protection is depositing the contract with the Land Registry immediately after signing.

Where are there no restrictions on foreign buyers?

In Portugal, Italy and the USA an Israeli buys an apartment, house or land much like a local citizen, with specific reservations.

  • Portugal: there is no general ban on foreign ownership of residential property, and residency is not required in order to buy. Professional sources mention limited restrictions in certain sensitive areas, such as military and protected zones, which only rarely affect an ordinary apartment purchase. Owning property does not confer a right to live in Portugal, and since October 2023 buying real estate is no longer a Golden Visa route either.
  • Italy: a foreigner enjoys civil rights, including the acquisition of immovable property, on condition of reciprocity. According to the reciprocity page the Italian Ministry of Foreign Affairs publishes on Israel, there are no legal restrictions in Israel on Italians acquiring land and buildings, except state land, so the condition is met for Israelis. The notaio checks this before signing.
  • USA: there is no federal ban on the purchase of real estate by foreigners. Anyone acquiring an interest in agricultural land must report it to the US Department of Agriculture within 90 days under AFIDA. Several states, including Florida and Texas, have enacted restrictions on buyers connected to certain countries such as China, Russia and Iran, and Israel is not on these lists. In 2026 amendments expanding oversight were proposed at the federal level, and as of September 2026 no new ban had been enacted.

Can foreigners buy agricultural land abroad?

Usually not, or only under conditions a foreign investor does not meet. Agricultural land is the asset most restricted for foreigners in Eastern Europe, and this is where "cheap land on the edge of town" deals get stuck.

  • Romania: agricultural land outside the built-up area (extravilan) is subject to Law 17/2014, with pre-emption rights and seniority and residence conditions for the buyer, which a newly formed Romanian company does not meet.
  • Bulgaria: the Agricultural Land Act generally requires more than five years of residence or establishment in Bulgaria. A foreigner who inherited agricultural land without a basis for acquisition must transfer it within three years.
  • Ukraine: under Article 81 of the Land Code, foreigners may not own agricultural land, and a foreigner who inherited such land must dispose of it within one year. As of January 2026 parliament was discussing proposals to open controlled access, but the ban remains in force.
  • Greece: outside border areas there is no nationality-based restriction, but acquiring an agricultural plot of more than 250,000 m² requires prior approval, for any buyer.
The country house trap

Many houses outside the cities stand on a plot registered as agricultural. In that case a foreigner can buy the building but not the plot. So before agreeing a price, check the land designation in the registry rather than relying on the agent's description.

Does an EU passport remove the restrictions?

In the EU countries, in most cases, yes. In Romania, Greece, Cyprus and Bulgaria the restrictions apply to citizens of non-EU states, so an Israeli who buys as an EU citizen is treated like any European citizen. There are three caveats:

  1. You must actually buy with the EU passport: present it to the notary and make sure all transaction documents are consistent.
  2. An EU passport does not resolve the agricultural land rules, which impose seniority and residence conditions on EU citizens as well.
  3. The choice of citizenship also affects tax, inheritance and reporting in Israel, so the full picture is checked before choosing.

In Ukraine and the USA an EU passport does not change the picture. In Ukraine the ban on agricultural land applies to all foreigners, and in the USA there is no restriction on Israelis in any case.

Can a "creative solution" get around the restriction?

It is not advisable to rely on one. Registration in the name of a relative who is an EU citizen, an unregistered trust arrangement or a long lease may look simple, but they shift the risk from local law to personal relationships, inheritance and creditors. In Greece the prohibition in border areas also covers contractual (obligatory) rights and share transfers. In Cyprus a lease of more than 33 years and the acquisition of control of a company holding immovable property count as an "acquisition" requiring a permit. A lawful and transparent structure, such as a local company or a registered Superficie right, is preferable to a structure whose only purpose is to circumvent the law.

What to do before signing, and how we accompany you

Before falling in love with a property, settle three things: which citizenship you are buying with, whether the deal includes land or agricultural land, and whether the location requires a permit. Only then choose a holding structure and draft a contract that makes payment conditional on the permit where one is required. We examine these questions at the start of every transaction, work with the lawyers and notaries in the country of the property, and review the Israeli consequences together with your advisers.

General information

This guide is general information, as of November 2026, and is not legal or tax advice for a specific case. The rules on acquisition of real estate by foreigners change, and in Cyprus, the USA and Ukraine there are pending bills. Before any transaction, it is advisable to obtain individual advice.

Frequently asked questions

Can an Israeli buy an apartment in Romania?

Yes. Any foreigner may register an apartment, house or villa in Romania in their own name. The restriction concerns land: an Israeli without an EU passport cannot register land in their own name, so the land is arranged through a Superficie right or a Romanian company (SRL).

Can foreigners buy property in Greece?

Yes, and Greece has no general restriction on foreigners. A buyer who is not an EU or EFTA citizen needs a prior permit only if the property is in a border area, such as the Dodecanese islands, Santorini or Lesvos. A transaction in such an area without a permit is void.

Do you need approval to buy an apartment in Cyprus?

An Israeli without an EU passport needs a permit from the Council of Ministers, granted through the District Officer, for the property to be registered in their name. The permit is required before registration of title, and in the meantime the contract is deposited with the Land Registry. An EU citizen does not need a permit.

Can an Israeli buy land in Bulgaria?

Not in their own name. A non-EU foreigner can acquire buildings and apartments in Bulgaria, but land only under a treaty or by inheritance. A house with a plot is usually bought through a Bulgarian company (EOOD), and even that company cannot acquire agricultural land without more than five years of seniority.

Can foreigners buy real estate in the USA?

Yes. There is no federal ban in the USA on the purchase of real estate by foreigners. Acquiring an interest in agricultural land requires a report within 90 days under AFIDA, and several states restrict buyers connected to certain countries such as China, Russia and Iran, but not Israelis.

Can you buy agricultural land abroad as a foreigner?

In Romania, Bulgaria and Ukraine, hardly at all. Romania and Bulgaria impose seniority and residence conditions that a new company does not meet, and in Ukraine foreigners may not own agricultural land at all. Before buying a country house, check the designation of the plot.

Does buying property abroad give a right of residence?

Not automatically. Romania has no residence route in exchange for buying property, in Portugal buying real estate has not been a Golden Visa route since October 2023, and in Cyprus the purchase permit does not confer a right of stay. In Greece a purchase can support a Golden Visa under the prescribed conditions.

Read next · 10 min readWhich Country Should You Buy Property In? A Legal Comparison of 8 Countries for the Israeli InvestorBuying property abroad: legal comparison of Romania, Greece, Cyprus, Bulgaria, the US, Italy, Portugal and Ukraine - who may buy, registration, tax, risks.Read the guide

Sources

  1. Law no. 312/2005 on the acquisition of land by foreign citizens (text, notari.pro)
  2. CyLaw - Acquisition of Immovable Property (Aliens) Law, Cap. 109, consolidated text
  3. European Land Registry Association - Greece: legal restrictions
  4. European Land Registry Association - Bulgaria: limitations to foreigners
  5. Italian Ministry of Foreign Affairs - Reciprocity page: Israel
  6. Iowa State University, CALT - The federal push to regulate foreign farmland ownership (September 2026)
  7. Kinstellar (Legal 500) - Land ownership and leasing rights for foreign investors in Ukraine (January 2026)
  8. Harris Sliwoski - Buying property in Portugal in 2026 for foreign buyers

Let’s start with a conversation.

A sound international transaction begins long before signing. A short introductory call will clarify whether, and how, we are the right firm to support you.

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