Ilan Leibovitch & Co.Lawyer and real estate developer
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Short-Term or Long-Term Rental Abroad: Licensing, Tax and Restrictions by Country

Short-term vs long-term rental abroad: Airbnb rules in Europe 2026, licensing, tax and limits in Greece, Portugal, Cyprus, Romania, Bulgaria, Italy, USA.

By Adv. Ilan LeibovitchUpdated: 10 min read
RentalPl. VI·237

In brief

Short-term rental to tourists abroad is a regulated activity: in almost every European country it requires registration or a licence, a registration number in every listing and sometimes different taxation and VAT, and in city centres such as Athens, Lisbon and Porto new registrations are frozen or restricted. Long-term residential rental is simpler from a regulatory point of view, but is subject to tenant protections. As of November 2026, the choice between the two tracks should be made before the purchase, according to the country, the city and the building, and not only according to the expected yield.

Key takeaways

  1. 1Since 20 May 2026, EU Regulation 2024/1028 has applied, requiring platforms to share data with the authorities and relying on a registration number for each unit. A listing without a valid number is at risk.
  2. 2In Athens, new short-term rental registrations in municipal districts 1, 2 and 3 are frozen, and according to the government announcement of September 2026 the freeze has been extended until 31 December 2027.
  3. 3In Italy, from 2026, short-term rental of more than two apartments is deemed a business activity. In Greece, 13% VAT applies from the third property. In Romania, a private individual is limited to 7 rooms and 14 bed places.
  4. 4Short-term rental with ancillary services may be treated in Israel as business income, in which case the 15% track for foreign rental income does not apply.
  5. 5A "proven" Airbnb yield presented in a sale is only worth as much as the licence: check before signing whether the registration will pass to you or whether a new one can be issued.

What is the difference between short-term and long-term rental abroad?

The main difference is the legal regime: short-term rental to tourists is governed by tourism law and special registration duties, while long-term residential rental is governed by ordinary tenancy law. This leads to differences in licensing, tax, management and regulatory risk.

The definition of "short" also varies from country to country. In Greece, according to the guidance of the tax authority (AADE) of September 2025, a short-term rental is the letting of a furnished property for up to 59 days per contract, with no services beyond bed linen. In Italy, a "short rental" (locazione breve) is a contract of up to 30 days. In New York, the registration duty applies to stays of fewer than 30 consecutive days. There is therefore no single answer to the question "what is allowed on Airbnb abroad": you need to check the rules of the country, the municipality and sometimes also the building.

Long-term rental is usually simpler: no tourism licence is required, income is stable and management is limited. On the other hand, tenancy law in many countries protects the tenant, and eviction or rent increases are not always quick. This guide compares the two tracks in seven countries and points to the detailed guides.

What changed for short-term rentals in Europe in 2026?

Since 20 May 2026, Regulation (EU) 2024/1028 on data collection and sharing relating to short-term accommodation rental services has applied in all EU Member States. The Regulation applies to online platforms and to those who advertise on them, not to hotels. In countries that have set up a registration system, each unit has a registration number, platforms transmit activity data to the authorities, and a listing without a valid number may be deactivated or removed.

Implementation is not uniform. In Romania, for example, in May 2026 it was still not possible to generate the code in the Ministry of Tourism's SITUR system, and in Bulgaria the mechanism is implemented within the existing Tourism Act. What this means for the investor: the property must meet local requirements, and the number must appear in the listing as soon as the system allows it.

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Comparison table: licensing, tax and restrictions on short-term and long-term rental by country

The table summarises the main rules for a private owner who is not resident in the country. The tax shown is the tax in the country where the property is located only, before Israeli tax. Each figure is dated according to the source in which it was checked.

CountryShort-term rental licensingMain restrictionsTax on short-term rentalTax on long-term rentalAs of
GreeceRegistration in the tax authority's registry and an AMA numberFreeze on new registrations in districts 1 to 3 of Athens until 31.12.2027. From the third property the activity is subject to 13% VATUp to two properties: property income on the rental scale, 15% to 45%Same scale: 15% to 45%AADE September 2025, To Vima September 2026, PwC 2026
PortugalAlojamento Local registration (RNAL number) by prior notice to the municipalityMunicipal containment areas. In Lisbon and Porto there are almost no new registrations in the centreBusiness income: 25% on 35% of turnover (50% in a containment area)25%, with reductions for long contracts, or 10% on rent of up to EUR 2,300 per monthOctober 2026
CyprusRegistration in the Deputy Ministry of Tourism's register of self-catering accommodation, for 3 yearsFire and third-party liability insurance, registration number in every listing, fine of up to EUR 5,000May be treated as business income. According to an October 2026 review, 9% VAT above a turnover of EUR 15,600Income tax bands, 0% up to EUR 22,000 and up to 35%, after a 20% deductionOctober 2026
RomaniaClassification certificate from the Ministry of Tourism, and a European registration number via SITURPrivate individual: up to 7 rooms and 14 bed places. In a condominium, the neighbours' consent is required10% after a fixed 30% deduction10% after a fixed 20% deductionJuly to September 2026
BulgariaRegistration in the mayor's electronic register under the Tourism Act, or categorisation for a guest houseRegistration number in every listing. Tourist tax set by the municipalityNon-resident: 10% final tax on gross. Rental on a business scale may be taxed differentlyNon-resident: 10% final tax on gross, with no deduction of expensesJune to October 2026
ItalyNational identification code (CIN) from the Ministry of TourismGas and carbon monoxide detectors and extinguishers. From 2026, more than two apartments on short-term rental are a business activitycedolare secca: 21% on one apartment, 26% on the secondcedolare secca of 21% (10% under an agreed-rent contract) or IRPEF bandsApril to October 2026
USANo federal licensing. Registration or permit depending on the city, county or stateLocal ordinances, building or homeowners' association rules, local occupancy taxesFederal tax as on rental income, plus local occupancy tax where applicable30% withholding on gross, or taxation on net by electionQualitative assessment, November 2026

Greece: can you open a new Airbnb in Athens?

In central Athens, hardly at all: new registrations in the short-term rental registry in municipal districts 1, 2 and 3 have been frozen since 2025, and according to the government announcement of September 2026 the freeze has been extended until 31 December 2027. The area includes Plaka, Kolonaki, Koukaki, Syntagma and Monastiraki. The same announcement also covers the first district of Thessaloniki.

According to AADE guidance of September 2025, a property in these districts that was registered by 31 December 2024 may be registered again, for example after a sale or inheritance. Later reports claim that on a sale the registration is deleted and that the buyer cannot obtain a new number. The question of whether the registration will pass to you must therefore be checked for the specific property before signing, as we explained in the guide to short-term rental in Greece. On the tax side, an individual with up to two properties on short-term rental reports property income, which from 2026 is taxed on a separate scale of 15%, 25%, 35% and 45%. From the third property, counted by AMA numbers, 13% VAT applies to all short-term rentals.

Portugal: what do you need to rent under Alojamento Local?

You need an Alojamento Local registration, made by prior notice to the municipality, which produces an RNAL number that must be displayed in every listing. Decree-Law 76/2024, which entered into force on 1 November 2024, lifted the general suspension of new registrations and the five-year limit, and restored the possibility of transferring a registration on a sale. At the same time, it transferred powers to the municipalities, which may define containment areas and restrict new registrations and transfers within them.

In practice, there are almost no new registrations in the centres of Lisbon and Porto, and in Lisbon the transfer of a registration in a containment area generally causes it to lapse. On the tax side, a non-resident pays 25% on residential rent, with reductions for long contracts or 10% on moderate rent, and is taxed as self-employed on AL. We have set out the details, including the link between long-term rental and the IMT refund, in the guide to renting out property in Portugal and Alojamento Local.

Cyprus: do you need a licence from the Deputy Ministry of Tourism to rent to tourists?

Yes. An apartment, house or villa rented as a whole unit to tourists must be registered in the Deputy Ministry of Tourism's register of self-catering accommodation, under Law 34(I)/2019 as amended by Law 9(I)/2020. The application includes confirmation that the building conforms to its building permit, a tax identification number, and insurance against fire and third-party liability. According to an October 2026 report, the fee is EUR 222 and the registration is valid for three years. The registration number must appear in every listing, and operating without registration may lead to a fine of up to EUR 5,000 or imprisonment of up to one year.

In long-term rental, an individual is taxed according to the income tax bands after a notional deduction of 20%, and from 2026 rent payments must be made by traceable means. In rental to tourists, the income may be treated as business income, with VAT implications. It is important to remember that there is no tax treaty between Israel and Cyprus, so double taxation is avoided through unilateral credit in Israel, as detailed in the guide to taxation of rental income in Cyprus.

Romania: what restricts short-term rental in Bucharest?

Three things: a classification certificate from the Ministry of Tourism, the neighbours' consent in a condominium, and a ceiling of 7 rooms and 14 bed places for a private individual. The ceiling was set by Order 948/2026, published in July 2026, and is counted across all apartments together. Beyond it, a registered business is required. In Bucharest a municipal tourist tax also applies, and from 2026 the electronic invoicing obligation also applies to a private landlord.

The tax itself is relatively low in both tracks: according to PwC (September 2026), in rental to tourists of up to 7 rooms the tax is 10% after a fixed 30% deduction, and in long-term rental 10% after a fixed 20% deduction. The real difference is the operational burden. See the guide to short-term rental in Romania.

Bulgaria: how do you register an apartment for rental to tourists?

Guest rooms and guest apartments that are not categorised are registered in an electronic register kept by the mayor under the Tourism Act, and the registration number must appear in every listing on a platform. A guest house requires categorisation. A non-resident who holds a property in his own name pays in Bulgaria a final tax of 10% on the gross rent, with no deduction of expenses, so on the Bulgarian side the difference between short-term and long-term rental is not in the rate but in the registration duties, the tourist tax and the question of whether the activity has become a business. The comparison between personal holding and a company appears in the guide to renting out property in Bulgaria.

Italy: what is the CIN code and when does short-term rental become a business?

The CIN is a national identification code that every apartment on short-term or tourist rental must obtain from the Ministry of Tourism, display outside the building and state in every listing. Under Article 13-ter of Decree-Law 145/2023, renting without a CIN carries a fine of EUR 800 to 8,000, and every unit requires gas and carbon monoxide detectors and fire extinguishers.

On tax, cedolare secca on short-term rental is 21% on one apartment of your choice and 26% on the rest, and platforms withhold 21% at source as an advance. According to the Italian Revenue Agency's guide of April 2026, from 2026 the short-term rental regime applies to two apartments at most, and beyond that the activity is deemed a business. In long-term rental you can choose cedolare secca at 21%, or 10% under an agreed-rent contract in certain municipalities. The full comparison is in the guide to renting out property in Italy.

USA: who decides whether short-term rental is allowed?

In the USA there is no federal licensing for short-term rental, and the rules are set mainly at city, county or state level, and sometimes also by the building's or homeowners' association (HOA) rules. Some cities require registration or a permit, some restrict short-term rental to a home in which the host lives, and some prohibit it in certain areas. New York is a prominent example: under Local Law 18, a host offering stays of fewer than 30 days must register with the city's Office of Special Enforcement, and since 5 September 2023 platforms may not process bookings for a property that has not been verified.

On the tax side, the federal default for a non-resident is 30% withholding on gross rent, with an option to elect taxation on net income, and in short-term rental local occupancy taxes are usually added. You should therefore check the city's ordinances and the building's rules before signing.

How is short-term rental taxed in Israel compared with long-term rental?

In Israel, income from renting out a property abroad that is not business income may be taxed at 15% under section 122A of the Income Tax Ordinance, or at the marginal rate with a credit for the foreign tax. Short-term rental with ancillary services may be treated as a business, in which case the 15% track does not apply.

In the 15% track only depreciation is deductible and there is no credit for the tax paid in the country where the property is located. In the regular track you are taxed on net income and receive a credit for the foreign tax, up to the amount of the Israeli tax. When the short-term rental includes cleaning, changing linen, welcoming guests and ongoing management, it may be treated in Israel as business income, with self-employed filings and sometimes also National Insurance contributions. In both cases an annual return is filed.

How do you choose between short-term and long-term rental?

  1. Check the rules at street level, not just at country level. Is the area frozen, in a containment area or expected to be restricted, and what do the building's rules allow.
  2. Check the status of the existing licence. Is there an active registration number, and does it pass to the buyer or can a new one be issued.
  3. Count properties and rooms. The thresholds of two properties in Greece and Italy and 7 rooms in Romania change your status from private to business.
  4. Calculate the tax in both countries. Including VAT, tourist tax, and whether Israel will treat it as a business.
  5. Price the operations. Management, cleaning, insurance, guest reporting and electronic invoices.
  6. Prepare a fallback scenario. What is the yield if the rules change and you have to switch to long-term rental.

What to do before signing, and how we accompany you

The decision between short-term and long-term rental should be made before the purchase, because it affects the choice of property, the holding structure and the tax in both countries. Before signing, we check the property's registration status, the municipal regulations and the building's rules, and look at the transaction from the perspective of an Israeli investor. Local steps are carried out by lawyers and tax advisers licensed in the country where the property is located, and we coordinate between them and your accountant in Israel.

General information only

The information here is general information, as of November 2026, and is not legal or tax advice for a specific case. Short-term rental rules change quickly, at country, municipality and building level, so before any decision you should check the current position and obtain individual advice.

Frequently asked questions

Can I rent out an apartment abroad on Airbnb without a licence?

In most EU countries, no. Greece requires an AMA number, Portugal an Alojamento Local registration, Cyprus registration with the Deputy Ministry of Tourism, Romania a classification certificate, Bulgaria registration with the mayor and Italy a CIN code. Since 20 May 2026 platforms share data with the authorities, and a listing without a valid number is at risk.

Which is better, short-term or long-term rental abroad?

There is no general answer. Short-term rental may earn more, but involves licensing, operations, local restrictions that change and sometimes higher tax. Long-term rental is more stable and simpler, but is subject to tenant protections. The decision depends on the area, the building, the number of properties and the tax in both countries.

Does the Airbnb licence pass to the buyer when buying an apartment abroad?

It depends on the country and the area. In Portugal the registration is transferable, but in a containment area in Lisbon a transfer generally causes it to lapse. In Greece, in central Athens, there are conflicting reports about re-registration after a sale. The registration status is therefore checked before signing, without relying on the listing.

How much tax do you pay on renting out an apartment abroad?

The tax in the country where the property is located varies greatly: for example 10% on gross for a non-resident in Bulgaria, 10% after a deduction in Romania, 21% or 26% on short-term rental in Italy and 25% on residential rent in Portugal (as of October 2026). In Israel you choose between 15% without credit and the marginal rate with credit, if the income is not business income.

Is short-term rental abroad treated as a business in Israel?

It may be treated as a business when it includes ancillary services and ongoing management, such as cleaning, linen and welcoming guests. In that case the 15% track does not apply, National Insurance contributions may be due, and reporting is made as self-employed. The classification should be checked with your accountant before you start renting.

Can you open a new short-term rental in central Athens in 2026?

As a rule, no. New registrations in municipal districts 1, 2 and 3 of Athens are frozen, and according to the government announcement of September 2026 the freeze has been extended until 31 December 2027. Properties that were registered by the end of 2024 have a different status, and each property must be checked individually.

What is the new EU regulation on short-term rentals?

Regulation (EU) 2024/1028 has applied since 20 May 2026 to rental platforms and those who advertise on them. It requires the transmission of activity data to the authorities and relies on a registration number for each unit in countries that have set up a registration system. Implementation varies from country to country.

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. European Commission (Transition Pathways) - Regulation (EU) 2024/1028 on data collection and sharing for short-term accommodation rentals
  2. CNN Greece - AADE's updated guide to short-term rentals (25.9.2025)
  3. To Vima - Extension of short-term lease restrictions in Athens and Thessaloniki until 2027 (7.9.2026)
  4. PwC Worldwide Tax Summaries - Greece, individual taxation: rental income scale from 2026
  5. PLMJ - Changes to the Alojamento Local rules under Decree-Law 76/2024
  6. Elias Neocleous & Co - Law 9(I)/2020 on registration of self-catering accommodation in Cyprus (21.2.2020)
  7. Cyprus Mail - Cyprus landlords rethink short-term rental (27.10.2026)
  8. PwC Worldwide Tax Summaries - Romania, individual taxation: rental income (September 2026)
  9. StartupCafe - Order 948/2026: ceiling on rooms and bed places for private individuals (8.7.2026)
  10. StartupCafe - New rules for renting on Airbnb and Booking from 20 May 2026 (8.5.2026)
  11. Dimitrov, Petrov & Co - Short-term rentals: the EU framework and its implications for Bulgaria (2.6.2026)
  12. RSM Bulgaria - Direct holding of real estate in Bulgaria and rental taxation
  13. Normattiva - Decree-Law 145/2023, Article 13-ter (CIN, safety requirements and fines)
  14. eDotto - Italian Revenue Agency guide to the 2026 short-term rental rules (16.4.2026)
  15. NYC Mayor's Office of Special Enforcement - Short-term rental registration law (Local Law 18)

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