Bali Off Script

Thailand or Bali for property?

Thailand gives you a condominium freehold and prosecutes the company workaround. Indonesia gives you no land at all and has criminalised the equivalent.

By Kai, Bali property adviser Updated 4 min read

These two markets get compared constantly and the comparison usually stops at price. The meaningful differences are structural.

What you can actually own

Thailand. A foreigner may own a condominium unit freehold, in their own name, registered, subject to the building's foreign quota — no more than forty-nine percent of the total floor area of a condominium may be foreign-owned. That is real, registered ownership and it is the single biggest structural advantage Thailand has.

Land is different. Foreigners generally cannot own land in Thailand. The workarounds are a thirty year registered lease, or a Thai company holding the land — and the company route has drawn increasing enforcement attention, with nominee shareholder arrangements prosecuted.

Indonesia. No freehold for foreigners, of any kind, including apartments — though strata title over an apartment is available above a minimum value threshold, and in practice most foreign apartment holding runs through leasehold or a company. Land is leasehold, Hak Pakai with residency, or HGB through a PT PMA.

Nominee arrangements are void in Indonesian law, and Perda Bali 4/2026 prohibits facilitating them.

So both countries restrict land, both have criminalised or voided the same workaround, and Thailand offers a genuine freehold route that Indonesia does not — but only for condominiums.

What that means practically

If you want registered freehold in your own name, Thailand is the only one of the two that offers it, and only in a condominium within the foreign quota.

If you want a villa with land, neither country gives you ownership, and you are comparing a Thai thirty year registered lease against an Indonesian leasehold.

Here there is a real difference: a Thai lease is registered at the Land Department and appears on the title deed. An Indonesian Hak Sewa is not registered and appears nowhere. That makes the Thai instrument structurally stronger — a subsequent purchaser of the land takes subject to a registered lease, whereas in Indonesia your protection depends entirely on drafting.

Against that, Thailand's thirty year cap is firmer than Indonesian practice, where leases reaching fifty or eighty years through agreed extensions are common.

Yields and market

Bali runs on short-term holiday letting, with strong seasonality, high gross yields and high operating costs. A well-run villa nets seven to fourteen percent depending on quality and management.

Thailand has more variety. Phuket and Samui behave like Bali. Bangkok and Chiang Mai are long-term rental markets with lower gross yields, lower volatility and far lower management burden. Condominium yields in Bangkok are typically mid single digits net.

Bali's advantage is yield. Thailand's advantage is the option to hold a lower-maintenance, registered asset.

Tax

Thailand taxes rental income progressively for residents and at a flat rate for non-residents, with transfer taxes and a specific business tax on disposals inside five years. It has a wide treaty network.

Indonesia applies a final tax on rental income — ten percent for a resident individual, twenty percent for a non-resident — plus a regional tax on accommodation that platforms do not collect for you, and a final 2.5 percent on the transfer value at disposal rather than a tax on gain.

Neither is obviously better and both interact with wherever you are tax resident. Take advice in both jurisdictions.

Visas

Thailand's Long Term Resident and Elite visas are well-established, clearly priced and widely used. Indonesia's second home and golden visa routes are newer and the administrative practice around them is still settling.

Thailand currently has the more predictable residency picture for someone who wants to be there long term without running a business.

Lifestyle and practical

Bali is one island with a concentrated foreign market, a strong creative and entrepreneurial scene, and severe traffic and infrastructure strain in the south.

Thailand is a much larger country with several distinct markets, better medical infrastructure, better domestic transport and a longer-established expatriate system.

Which I would choose

For a registered, low-maintenance asset in your own name: a Thai condominium within the foreign quota. Nothing in Indonesia matches that structurally.

For yield from a villa you will also use: Bali, provided the lease is well-drafted, the term is long and the extension is guaranteed.

For long-term residency without a business: Thailand, currently, on visa predictability.

For an earlier-stage market with more land upside: Bali, with the caveat that on a leasehold you do not capture land appreciation.

Common questions

Can foreigners own property in Thailand?

Foreigners may own a condominium unit freehold in their own name, subject to the building's forty-nine percent foreign quota. Land generally cannot be owned, with a registered thirty year lease as the main alternative.

Is a Thai lease better than an Indonesian one?

Structurally yes, because a Thai lease is registered at the Land Department and appears on the title deed, whereas Indonesian Hak Sewa is not registered anywhere. Indonesian practice does allow longer effective terms.

Are yields higher in Bali or Thailand?

Bali, on short-term villa letting, with correspondingly higher operating costs and seasonality. Thai condominium markets offer lower but steadier returns with far less management burden.

Which has better visas, Thailand or Indonesia?

Thailand's Long Term Resident and Elite visas are more established and more predictable. Indonesia's second home and golden visa routes are newer and administrative practice is still settling.

Kai, Bali property adviser

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