Freehold or Leasehold: A Tenure Map of the NAC Markets

"Freehold" means ownership without an end date; "leasehold" means ownership or use rights for a fixed term, after which you renew or hand back. But the words don't mean the same thing everywhere. A 999-year London leasehold is far safer than a 30-year land lease in Phuket, and a Kuala Lumpur freehold still needs state approval for a foreign buyer. Before comparing price and yield, Vietnamese investors need to know exactly which right they're buying.

Most writing on tenure covers one country. Vietnamese investors, though, often line up a London flat, a Bangkok condo and a Kuala Lumpur branded residence side by side, and it's easy to assume "freehold" works the same in all three. This guide goes market by market, then checks the tenure label on real project files – the same ones scored in the NAC Residence Index rankings – so you know which word to read twice.

England: Very Long Leases and an Unfinished Reform

In England almost every flat is leasehold: you own the flat under a long lease, while the land and the building's structure belong to the freeholder. What matters is the term remaining and the annual ground rent.

Two Berkeley projects in NAC's portfolio show what a good leasehold looks like. Per NAC's listing data, Fulham Reach carries a 999-year lease from 2011 at a peppercorn ground rent, and White City Living's The Solaris in west London is also a 999-year leasehold, with studios from £665,000, a 4.5% gross yield and a NAC score of 85/100. With nearly a millennium on the clock, expiry risk is academic.

The new law is passed but not yet working. The Leasehold and Freehold Reform Act 2024 bans new leasehold houses and lifts the standard lease extension to 990 years at a peppercorn rent. But as Taylor Walton noted on Mondaq in September 2026, many provisions still await secondary legislation, valuation consultations are under way, and implementation isn't expected before mid-2027. The government also plans further changes through a new bill, including a £250-a-year cap on ground rent.

In England, "leasehold" is not a red flag in itself; the question is how many years remain.

The lesson: in England, "leasehold" is not a red flag in itself. The questions are how many years remain and what the ground rent is.

Thailand: Condos Are Freehold, Land Is Not

Thailand draws a sharp line. According to The Thaiger's legal guide, updated August 2026, foreigners can own a condominium unit freehold under section 19 of the Condominium Act, provided total foreign ownership stays within 49% of the building's saleable floor area. Land is a different matter: foreigners can't own it, so a villa comes with a registered lease of at most 30 years. The same source reports that a March 2025 Supreme Court ruling voided pre-agreed automatic renewal clauses, so each renewal needs fresh registration with the landowner's agreement.

NAC's Phuket portfolio shows the split exactly. Per NAC's listing data, Hythe by Botanica's "vertical villas" in Layan are foreign-quota freehold condominiums, completed in December 2025, from $326,000 with a 6.0% gross yield. The listing itself spells out the advantage over the area's landed villas, which foreigners can only lease. Nearby, Botanica Foresta II – 35 private-pool villas – carries a leasehold label, from $888,000.

Vietnam: 50 Years for Foreigners, and Caps per Building

For Vietnamese readers, a clarification up front: the rules below apply to foreigners buying in Vietnam, not to Vietnamese citizens. They still matter, because they decide who can buy your unit later and how liquid a project is.

Under Article 20 of the 2023 Housing Law, as summarised by Thu Vien Phap Luat, a foreign individual may own a home for up to 50 years from the date of the certificate, renewable once for up to 50 years, with the renewal filed at least three months before expiry. VnEconomy (2024) adds that, under Decree 95/2024, foreigners may own no more than 30% of the units in an apartment building, and no more than 250 landed houses in a designated population area.

Same city, same yield – different tenure and a different entry price.

NAC's data reflects this. Novaland's The Prince Residence in Phu Nhuan is labelled "leasehold 50 years (foreign)", was delivered in 2015, and is priced from $144,000 with a 5.5% gross yield and a NAC score of 80/100. It's a reminder that a leasehold label can sit alongside a high score when location, legal standing and rental income are all clear.

Dubai and Malaysia: Freehold, With Conditions

Dubai: freehold inside designated areas. Dubai Law No. 7 of 2006 on real property registration%20of%202006.html) lets non-UAE nationals hold freehold with no time limit, or usufruct and lease rights of up to 99 years, but only in areas designated by the Ruler. All of NAC's Dubai projects sit in those areas and are labelled freehold.

Malaysia: freehold or leasehold, the state must approve. According to Chambers Global Practice Guides (figures as of 15 April 2025), foreign buyers must meet a minimum price set by each state. In Malaysia, leasehold land belongs to the state and is granted for a fixed term, most commonly 99 years; extension isn't automatic and carries a premium payable to the state, per Global Law Experts' 2026 overview.

Two Kuala Lumpur projects in NAC's portfolio make the difference concrete. Per NAC's listing data, Oxley Towers KLCC, the SO/ Sofitel complex on Jalan Ampang, is freehold, from $328,000 with a 5.0% gross yield and a NAC score of 78/100. Pavilion Square in Bukit Bintang is leasehold, from $245,000, also at 5.0%, with completion expected around 2028–2029 and a score of 73/100. Same city, same yield – different tenure and a different entry price.

Australia, Greece, Cyprus and Türkiye: Freehold Is Common

In the remaining NAC markets, most projects carry a freehold label – though a few İstanbul listings are marked leasehold, so always read the label on each file. The thing to check isn't the term but the conditions of purchase: in Australia, foreigners can only buy new homes until 30 June 2029 (as extended) and need foreign investment approval; in Greece, Cyprus and Türkiye, ownership is often tied to a residence or citizenship programme with its own investment threshold.

The chart below lines projects up by tenure label. What stands out is that tenure alone doesn't set the yield: a leasehold unit can let as well as, or better than, a freehold one.

A practical strategy for Vietnamese investors

Ask "how many years are left", not just "freehold or leasehold". A 999-year lease and a 30-year lease are completely different assets. Put the remaining term in your comparison table.

Check the foreign quota before you pay a deposit. It's 49% of floor area in Thailand and 30% of units in Vietnam. If the quota is full, you may be left with a leasehold option or a wait.

Build the minimum price into the plan from day one. In Malaysia the floor varies by state and can be revised; confirm it with a local lawyer for the exact project, especially if you're pairing it with Malaysia's MM2H residence programme.

Think about the next buyer. Your tenure is what the next owner inherits. A freehold unit in an area open to foreigners usually has a wider pool of resale buyers.

Explore on NAC

×SobhaSobha Estates🇦🇪 Dubai · from $6.2MYield 5.0%White City Living🇬🇧 London · from £665KYield 4.5%×BotanicaHythe by Botanica🇹🇭 Phuket · from $326KYield 6.0%×NovalandThe Prince Residence🇻🇳 Ho Chi Minh City · from $144KYield 5.5%×OxleyOxley Towers KLCC🇲🇾 Kuala Lumpur · from $328KYield 5.0%Pavilion Square🇲🇾 Kuala Lumpur · from $244KYield 5.0%

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See also: NAC's Malaysia projects · The Berkeley portfolio in the United Kingdom · The residence programme comparison table · The full NAC Property Hub

Frequently asked questions

Does leasehold hurt resale value?

It depends on the term left. A 999-year London lease makes almost no difference; a short one, like a 30-year Thai land lease, matters more because the next buyer only gets the remaining years.

Can foreigners buy a freehold villa in Phuket?

No – foreigners can't own land in Thailand. The freehold route for foreigners is a condominium unit within the 49% quota.

What happens when a foreigner's 50-year term in Vietnam ends?

Under the 2023 Housing Law, the owner can renew once for up to 50 years if they apply at least three months before expiry.

NAC strategic insight

Freehold isn't automatically good and leasehold isn't automatically bad. What matters is buying what you think you're buying: how long the term runs, who can renew it, whether the foreign quota is open, and who the next buyer will be. NAC labels tenure on every listing so you can compare on level ground.

If you're torn between two projects with different ownership structures, book a consultation with NAC and we'll go through the legal paperwork with you before you decide.

Sources

• Mondaq / Taylor Walton — Update on the implementation of the Leasehold and Freehold Reform Act 2024 (2026)
• The Thaiger — Buying property in Thailand as a foreigner: names, money and the 49% rule (2026)
• VnEconomy — Foreign ownership limits set for Vietnamese property (2024)
• Chambers Global Practice Guides — Real Estate 2025: Malaysia (2025)
• Global Law Experts — Freehold vs leasehold in Malaysia (2026)