In brief
There is no country that is “the most worthwhile” for every investor, and we do not recommend a particular market without knowing the goal, the budget and the investment horizon. What can be compared is the legal framework: an Israeli may buy an apartment in all eight countries in this guide, but land, permits for foreigners, the reliability of the registry, the protection of the buyer’s money, tax and financing differ greatly between them. In most cases the significant risk is not the country, but a transaction in which the buyer did not receive a registered and protected right.
Key takeaways
- 1An Israeli may purchase an apartment in all eight countries. The differences begin with land: in Romania and Bulgaria land is usually acquired through a local company or a Superficie right, and in Ukraine agricultural land is prohibited to foreigners.
- 2In Cyprus a Council of Ministers permit is required, and in Greece a special permit in border areas and on certain islands, for buyers who are not EU citizens.
- 3In the US there is no government registry that guarantees ownership, and protection relies on a title search and title insurance (Title Insurance).
- 4The main risk varies by country: restitution claims and building irregularities in Romania, irregularities and incomplete registration in Greece, stuck title deeds in Cyprus, the occupancy permit in Bulgaria, and martial law in Ukraine.
- 5A European passport held by one of the family members can change the structure of the transaction, so it is checked before choosing a country.
- 6Tax on the property is also paid in Israel, so compare the total cost in both countries and not only the local tax.
“Which country should I invest in real estate?” is the first question most investors ask, and from a legal standpoint it is also the wrong question to start with. A country with low prices can be dangerous for a buyer who did not check the property, and an expensive country can be very simple in terms of registration and protection. We do not recommend a particular market and do not estimate returns, because the answer depends on your goal: ongoing income, capital preservation, a holiday home, status in the country or development.
What can be done is to compare the rules. This guide goes through the eight countries in which we handle transactions and compares them on six axes: who may buy, how the right is registered, what protects the buyer, what the most notable tax is, whether local financing is available and what main risk we see. The data is correct as of November 2026. You can also go to the country comparison tool.
How do you compare property abroad from a legal standpoint?
A real estate transaction is governed by the law of the country where the property is located, not by Israeli law. Therefore the protections Israelis are used to, such as the Sale (Apartments) (Assurance of Investments) Law or a caveat (warning note), do not exist abroad in the same form. In every country six questions need to be asked:
- Am I allowed to buy, and what exactly: an apartment, a house with land, land for development?
- Where is my right registered, and how reliable and complete is the registry?
- What protects my money between the first payment and registration?
- How much tax will I pay, on purchase, holding and sale, and in Israel?
- Can I obtain financing from a local bank, or is the transaction funded with own capital?
- What is the common risk in this market, and how is it checked before signing?
Quick comparison: 8 countries for the Israeli investor
| Country | Can an Israeli buy? | Where you sign and register | Notable tax (as of November 2026) | Local financing for foreigners | What to check before signing |
|---|---|---|---|---|---|
| Romania | Apartment - yes, in your name. Land - sometimes through a Romanian company | Public notary, land registry (Cartea Funciară) | 21% VAT on a new property from a developer; the buyer pays the notary and a 0.15% registration fee | Yes, up to about 70% | Restitution claims on the property, and building changes made without a permit |
| Greece | Yes. A special permit is required in border areas | Notary, land registry (Ktimatologio) | Effective transfer tax of 3.09% on resale; VAT on a new property is suspended | Limited, depends on the bank | Building irregularities, and incomplete registration in the land registry |
| Cyprus | Yes, with Council of Ministers approval | Deposit of the contract and registration in the land registry | Transfer fees of 3%-8% (reduced by 50%), or VAT on a new property, in which case there are no transfer fees | Yes, depending on the bank’s policy | Delay in issuing the title deed in the buyer’s name |
| Bulgaria | Apartment - yes, directly. Land - through a Bulgarian company | Notary, land registry (Property Register) | Local transfer tax of 0.1%-3%, notary and registration fees | Yes, depending on each bank’s policy | A building that has no occupancy permit (Act 16) |
| US | Yes, and usually through an LLC | Closing through a Title company and an escrow account (Escrow) | Depends on the US state; on sale, a FIRPTA withholding of 15% of the price | Yes, through private lenders, usually 60%-65% | The tax structure in the US and Israel, and the FIRPTA withholding on sale |
| Italy | Yes, subject to reciprocity between the countries | rogito before a notaio, and registration in the land registry | Registration tax of 9% from a private seller, usually on the cadastral value; 10% IVA from a developer | Limited | Conformity between the situation on the ground, the cadastral registration and the permits |
| Portugal | Yes. Non-residents pay purchase tax (IMT) of 7.5% | escritura or Casa Pronta, and registration in the land registry (registo predial) | IMT of 7.5% for non-residents and stamp duty of 0.8% | Limited, depends on the bank | Legislative changes in tax, rentals and residency |
| Ukraine | Apartment - yes. Agricultural land - no | Notary, State Register of Rights (land registry) | On sale by a non-resident: 18% income tax and a 5% military levy, subject to exemptions | Not practical under martial law | Martial law, restrictions on registration and restrictions on transferring funds |
Romania: what is special about the market from a legal standpoint?
In Romania ownership passes by a notarial contract and is registered in the land registry, and anyone can obtain a registry extract and check the property before paying. An Israeli without a European passport registers the building in his own name and obtains the land by a Superficie right or through a Romanian company. Protection in an off-plan purchase is built in layers, because there is no escrow holding the buyers’ money. The risks we check in every transaction: restitution claims from the communist period, and construction or additions without a permit. See the legal guide to Romania and who may buy what according to passport.
Greece: where is the risk hidden?
There is no general restriction on foreigners, but a buyer who is not an EU citizen needs a prior permit in border areas, including popular islands such as Rhodes and Santorini, and a transaction without a permit is void. The national cadastre is not yet complete in all areas, and building irregularities are common, so the property’s electronic identity certificate and coastal and forest restrictions are checked. In Greece a purchase can also support a Golden Visa, subject to the threshold and the ban on short-term rental. See the legal guide to Greece.
Cyprus: why is the title deed the key?
An Israeli without a European passport needs a Council of Ministers permit for the property to be registered in his name. The well-known problem in Cyprus is stuck title deeds: buyers who paid the full price have remained for years without a title deed, mainly because of the developer’s mortgage or building irregularities. The main protection is depositing the sale contract with the land registry within six months of signing. As of September 2026 the government and the House of Representatives are advancing legislation that would restrict purchases by foreigners, so the legal position is checked on the day of signing. It is also important to distinguish between the Republic and the north of the island, where the legal risk is fundamentally different. See the guide to depositing the contract and the comparison between Northern Cyprus and the Republic.
Bulgaria: what is checked in a new building?
An Israeli may register an apartment in his name, but not land, so a house with a plot is usually acquired through a Bulgarian company (EOOD). In new projects the documents that determine the risk are Act 14, which approves the structural frame and allows ownership of a unit to be transferred, and Act 16 with the use permit, without which the apartment is not a property that may be lived in, financed or sold. The payment schedule should be tied to these stages. See the legal guide to Bulgaria.
The US: what is different from what we know?
Real property law in the US is a matter for each state, and there is no government guarantee of registration. Instead, the market relies on a title search, title insurance and a neutral Escrow. Most Israeli investors purchase through an LLC, and then the tax structure in both countries is a key decision, because a structure that is convenient in the US may be expensive in Israel. On sale, the buyer withholds 15% of the price under FIRPTA. See the guide to an LLC for Israelis and the guide to title insurance and Escrow.
Italy and Portugal: what is common and what is different?
In both, the final transaction is signed before a notary or registrar and registered in the land registry, and the Israeli buyer can work from Israel with a power of attorney. In Italy a foreigner buys subject to reciprocity, and according to the Italian Ministry of Foreign Affairs the condition is met with respect to Israel. The main risk in Italy is a mismatch between the property on the ground and the registration in the catasto and the permits, so a qualified technician checks it before the compromesso. In Portugal, since May 2026 a non-resident pays a flat IMT of 7.5% on a residential apartment, and legislation on tax, rentals and residency has changed several times in recent years. See due diligence in Italy and taxation in Portugal.
Ukraine: what changes under martial law?
Israelis may buy an apartment, a house or a commercial building, but not agricultural land. Ownership passes only upon registration in the State Register of Rights, and registration under martial law may be restricted in certain areas. The big risk is the money: according to decisions of the National Bank of Ukraine, transfers abroad are restricted, and we did not find a general permit allowing an individual non-resident to transfer abroad the proceeds of a real estate sale. See the guide to buying in Ukraine and the guide to selling and transferring the funds.
Property abroad: which risks recur in every country?
From the experience of the transactions we see, most failures do not stem from the choice of country, but from the same patterns, in every market:
- Payment to a developer before there is a building permit, or before the buyer has received any registered right.
- A lawyer who represents the seller or the developer, and not the buyer.
- A promise of return or “guaranteed rent” from the seller that is not backed by security.
- A property with building irregularities, which is hard to finance, insure and later sell.
- A holding structure chosen without checking the tax in Israel.
- Time pressure that prevents a check before the first payment.
We expanded on this in the red flags guide and in the guide on a lawyer for a cross-border transaction.
How do you start choosing a country without a market recommendation?
- Define the goal: income, capital preservation, personal use, status or development. Each goal narrows the options differently.
- Check passports in the family: European citizenship resolves the land question in Romania and Bulgaria and the Council of Ministers permit in Cyprus.
- Set a total budget: price, VAT or transfer tax, notary, registration and legal fees. Use the acquisition cost calculator.
- Decide on financing: will you need a local mortgage, and in which country is it available to you. See the guide to a mortgage for property abroad.
- Calculate the tax in both countries on rent and on sale, with an accountant.
- Ask about the exit: how easy it is to sell, to bequeath and to transfer the money back to Israel.
Further reading: Buying Property Abroad as an Israeli: The Complete 2026 Guide - From Choosing a Country to Reporting in Israel; Can Israelis Buy Property Abroad? Restrictions on Foreign Buyers by Country.
How we support an investor who has not yet chosen a country
We do not recommend a market without knowing the investor’s goal, budget and investment horizon. In the first conversation we map the legal restrictions relevant to him, according to the passports in the family, the holding structure and the financing. Once a country and a property are chosen, we check the rights and encumbrances, draft the contract and the payment mechanism, and coordinate with the local lawyers and notaries and with the tax adviser in Israel.
The content of this article is general information only, correct as of November 2026, and does not constitute legal advice, tax advice or a recommendation to invest in a particular country or property. Rules and taxes change, and every transaction has its own circumstances. Before any decision, individual advice must be obtained.
Frequently asked questions
Which country should I invest in real estate?
There is no single answer, and we do not recommend a particular market without knowing the goal, the budget and the investment horizon. What can be compared are the rules: who may buy, how the right is registered, what protects the money, the tax in both countries and the financing.
In which countries can an Israeli register land in his name?
In Greece, Cyprus (with Council of Ministers approval), the US, Italy and Portugal there is no general restriction similar to the one in Romania and Bulgaria. In Romania and Bulgaria an Israeli without a European passport usually holds land through a local company, and in Romania also by a Superficie right. In Ukraine agricultural land is prohibited to foreigners.
What is the big risk in property abroad?
In most cases it is not the country itself, but a transaction in which the buyer paid before receiving a registered and protected right, or a property with a registration or permit problem. Each country also has a typical risk, such as stuck title deeds in Cyprus or the occupancy permit in Bulgaria.
Do I need a local lawyer if I have a lawyer in Israel?
Yes. The transaction is governed by local law, and signing and registration take place before a notary and local authorities. The Israeli lawyer coordinates the picture from the buyer’s perspective, including tax and reporting in Israel.
Does the notary in the country of the property protect me?
The notary is neutral and checks the validity of the deed, but does not represent the buyer and does not check for him the merits of the transaction, the payment terms or the risks vis-à-vis the developer.
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- Italian Ministry of Foreign Affairs - Reciprocity sheet: Israel
- CyLaw - The Acquisition of Immovable Property (Aliens) Law, Cap. 109
- Cyprus Mail - Government moves to restrict foreign property purchases (September 2026)
- European Land Registry Association - Greece: Legal restrictions
- ELRA - Bulgaria: Limitations to Foreigners
- Baker McKenzie Global Corporate Real Estate Guide - Ukraine: Acquisition of Real Property
- Decreto-Lei n.º 97/2026 (Portugal) - IMT for non-residents
- IRS - FIRPTA Withholding
