Property in Japan vs Thailand vs Portugal: 2026 Comparison

Japan, Thailand, Portugal: the comparison at a glance

These three destinations dominate the searches of international investors: Japan for legal security and full ownership, Thailand for headline yield, Portugal for proximity and credit. They are not, however, playing the same game. The table below gathers the ten criteria that actually decide a cross-border investment, not the brochure arguments.

Criterion	Japan	Thailand	Portugal
Land ownership by a foreigner	Yes, unrestricted	No, prohibited	Yes, unrestricted
Quota or lease imposed	None	49 % of the building's floor area, otherwise a 30-year lease	None
Buyer-side acquisition costs	≤ 6 % of price	≈ 1 to 3 % (2 % transfer fee, usually split)	≈ 9.5 to 10.3 % (7.5 % non-resident IMT + 0.8 % stamp + legal)
Mortgage available to non-residents	No (resident employees only)	Virtually none	Yes, 60 to 70 % LTV
Gross long-term rental yield (market range)	4 to 5 % in major cities	5 to 8 %	4 to 5 %
Tax on a non-resident's rent	5 to 45 % progressive on net income, after depreciation	15 % of gross rent, withheld at source	25 % of net income (residential lease)
Annual holding tax	1.4 % + 0.3 % on the assessed value (≈ 0.3 to 0.6 % of the real price)	0.02 to 0.1 % (residential use)	IMI 0.3 to 0.45 % (+ AIMI 0.7 % above €600,000)
Tax on resale	39.63 % if held ≤ 5 years, 20.315 % beyond	Taxed as income, + 3.3 % if resold within 5 years	50 % of the gain at 12.5 to 48 % progressive rates
Visa obtained through the purchase	None	Possible via the LTR visa ($1M assets + $500k invested)	None since October 2023
Currency of the asset	Yen, historically weak against the euro	Baht	Euro (no FX risk for a euro-based investor)

Three lines drive everything else: who owns the land, whether tax hits gross or net rent, and who can borrow. Everything else can be recomputed from those three. Our guide to buying property in Japan covers the Japanese side step by step.

Ownership rights: freehold, a 49 % quota, or a 30-year lease

This is the most structural criterion, and the one yield comparisons quietly skip. An 8 % yield on a right that expires in 24 years is not comparable to 4 % on an asset held in perpetuity.

Japan: perpetual freehold, land included

Japanese law places no nationality or residency restriction on property purchase. A non-resident who has never set foot in Japan can buy land and a house, and hold shoyūken (shoyūken, full and perpetual ownership) registered in their own name in the tōki bo (tōki簿, land register). No quota, no lease, no nominee company, no expiry date. The transaction is secured by a shihō shoshi (shihō shoshi, judicial scrivener specialised in land formalities), who verifies title and registers the transfer on settlement day.

One nuance worth knowing: under the 2021 act on the survey of sensitive land, buying plots immediately adjacent to defence facilities, power plants or certain border islands triggers a notification and administrative review. This affects neither cities nor standard investment assets, but it is worth checking on an isolated rural plot.

Thailand: the land stays Thai

The Thai Land Code prohibits foreigners from owning land. Two routes remain:

• The condominium foreign quota: a foreigner may own a unit outright (chanote title registered at the Land Office) provided foreign-held space does not exceed 49 % of the building's total saleable floor area. Beyond that, units can no longer be sold freehold to foreigners, and a unit "inside the quota" often trades at a premium over the identical unit outside it.
• A 30-year lease, frequently marketed as 30 + 30 + 30 years. This needs saying plainly: the maximum registrable term is 30 years. Renewal promises are contractual and hold far less weight against a third-party buyer or the lessor's heirs. A lease is an asset that melts, year after year.

One more non-negotiable point: to register a unit under the foreign quota, funds must be remitted from abroad in foreign currency and documented by a foreign exchange transaction form issued by the Thai bank. Without it, no registration at the Land Office.

Portugal: full ownership, European standard

No nationality restriction, complete ownership, a reliable land registry and a familiar procedure for a European buyer. Of the three, it is the least disorienting framework, and also the most expensive to enter, as we will see.

What about the Japanese leasehold?

Japan also has a land lease right, shakuchiken (shakuchiken): you buy the building and a right to occupy the land, not the land itself. The difference with Thailand is decisive: in Japan it is a choice, flagged in the listing and discounted accordingly, whereas in Thailand it is often the only option. Our article on the shakuchiken land lease right explains how to spot it and what discount to demand.

Acquisition costs and financing: where the real entry ticket is decided

Investors tend to think in listed prices. Yet the cost gap between these three countries reaches seven points of price: more than eighteen months of rent. On €300,000, that is €21,000 of extra capital locked up before the first rent cheque.

Item (buyer side)	Japan	Thailand	Portugal (non-resident)
Agency commission	3 % + ¥60,000 + 10 % consumption tax (statutory cap)	0 % (paid by seller)	0 % (paid by seller)
Transfer / acquisition tax	fudōsan shutoku-zei: 3 % of the assessed value, far below the price paid	2 % of appraised value, usually split 50/50	IMT: flat 7.5 % since 2026 on a non-resident's second home
Registration / stamp	tōroku menkyo-zei 0.3 to 2 % of assessed value + inshi-zei (stamp duty)	0.5 % stamp duty (or 3.3 % specific business tax, seller-side, if resold within 5 years)	0.8 % stamp duty
Lawyer / notary	shihō shoshi: ¥100,000 to ¥150,000 (€670 to €1,000)	Lawyer: 0.5 to 1 %	Lawyer + notary + registry: 1 to 2 % + €500 to €1,000
Realistic total	≤ 6 % of price	≈ 1 to 3 %	≈ 9.5 to 10.3 %

The Japanese side is broken down item by item in our article on purchase costs when buying property in Japan. The key mechanism: several Japanese taxes are computed on the assessed value (kotei shisan-zei hyōka-gaku, kotei shisan-zei hyōka-gaku), which sits well below market price; that is what keeps the total under 6 %, and often far lower on expensive assets.

Financing: Portugal's one decisive advantage

Here we owe the reader honesty, even where it works against Japan.

• Portugal: banks do lend to non-residents, at 60 to 70 % LTV (versus roughly 80 % for residents). That is genuine leverage: a €300,000 asset for roughly €105,000 to €120,000 of equity plus costs. Cash-on-cash return can then comfortably exceed the asset's own yield.
• Japan: Japanese mortgages are reserved for people who are both resident AND employed in Japan, with a local income history. A non-resident buys cash, full stop. The "Japanese loan from abroad" schemes circulating on forums do not survive scrutiny: our article on mortgages in Japan for foreign buyers sets out the rare eligible cases and the alternatives.
• Thailand: Thai banks barely lend to non-resident foreigners. What remains are developer instalment plans on new-build, on terms that are not those of a bank loan.

Expert tip. Portuguese leverage is real, but it is paid for twice: through the 10 % entry costs, and through the fact that the asset must serve the debt before it serves you. A cash purchase in Japan produces net cash flow from year one, with no covenants, no loan insurance and no rate exposure. These are two investment philosophies, not a one-winner contest.

Rental yields and short-term letting: three very different regimes

Headline gross yields are not comparable across these countries, for one simple reason: they do not face the same tax base or the same operating costs. Below are observed market ranges: read them as prudent orders of magnitude, not as promises.

Indicator	Japan (Osaka, Fukuoka, Sapporo)	Thailand (Bangkok, Phuket)	Portugal (Lisbon, Porto)
Gross yield, long-term letting	4 to 5 %	5 to 8 %	4 to 5 %
Costs and management (share of gross rent)	25 to 30 %	30 to 45 % in a managed rental pool	25 to 30 %
Tax base on rent	Net income, after depreciation	Gross rent	Net income
Letting under 30 days	Regulated, with clear licences	Prohibited in a condominium without a hotel licence	Allowed with registration, subject to municipal rules

Japan: three licences, one readable framework

Japan has the most explicit regime of the three. Minpaku (minpaku, short-term letting in a dwelling) falls under the jūtaku shukuhaku jigyō-hō (jūtaku shukuhaku jigyō法, Housing Accommodation Business Act) and caps operation at 180 nights per year; simplified lodging, kan'i shukusho (kan'i shukusho) under the ryokan gyō-hō (ryokan gyō-hō, Hotel Business Act), allows 365 nights; special zones such as Osaka run their own scheme. Everything is written down and can be checked at city hall before you buy. Our articles on the minpaku licence and the 180-night rule and the 365-night hotel licence detail each set of conditions.

Demand is documented: Japan welcomed a record 42.7 million visitors in 2025, against an accommodation stock constrained by licensing. That organised scarcity is why well-located, properly licensed assets reach double-digit yields: see our city-by-city figures in Airbnb profitability in Japan by city.

Thailand: the short-term letting trap in condominiums

This is the most expensive blind spot in the Thai market. The Hotel Act prohibits letting for fewer than 30 days without a hotel licence, and an ordinary residential condominium does not get one. Many units are nonetheless let nightly, with a risk of fines and closure that falls on the buyer, not the seller. A clean route does exist: licensed managed hotel residences operated as a rental pool, where the advertised return is net of vacancy but reduced by 30 to 45 % of management fees.

Portugal: easy registration, constrained geography

Alojamento Local (local accommodation) requires a registration number displayed on every listing, dedicated insurance and compliance with the building's rules. Licences are no longer time-limited, but each municipality now sets its own regulation and may freeze new authorisations in saturated zones: precisely the centres of Lisbon and Porto, which is where the yield lives. You therefore buy a location and a local regulatory risk.

For a numbers-first comparison of the short-term segment against another Asian destination, see our analysis of Airbnb in Bali versus Japan.

Non-resident taxation: where your rent actually goes

This is where yield rankings flip. Two countries tax net income, one taxes gross, and that single difference can erase three points of yield.

Stage	Japan	Thailand	Portugal
Rent received	5 to 45 % progressive on net income (costs, interest, property tax and building depreciation all deductible)	15 % of gross, withheld by the tenant or manager and paid to the Revenue Department	25 % of net income (residential lease)
Withholding at source	20.42 % only where the tenant is a corporate entity; reconciled in the annual return	Systematic	None; annual return instead
Annual filing	kakutei shinkoku (kakutei shinkoku), 16 February to 15 March	Income tax return if staying 180 days or more; otherwise the withholding is final in practice	Non-resident IRS return
Annual holding cost	1.4 % property tax + 0.3 % city planning tax on the assessed value	0.02 to 0.1 % (residential use), with allowances	IMI 0.3 to 0.45 % + AIMI 0.7 % above €600,000
Resale	39.63 % if held ≤ 5 years, 20.315 % beyond	Taxed as income, withheld at the Land Office based on holding period; + 3.3 % if resold within 5 years	50 % of the gain at 12.5 to 48 % progressive rates

Why Japanese tax is the mildest in practice

On paper, a 45 % top rate is frightening; in reality, an investor holding one or two assets often pays under 10 % of gross rent. The reason is one word: depreciation. Japanese buildings depreciate over a short tax life, and that non-cash charge is set against rent, sharply reducing (sometimes to zero in the early years) the taxable income. Our article on rental income tax in Japan for non-residents works through the calculation, and the one on Japanese property tax explains why a 1.4 % rate does not mean 1.4 % of your purchase price.

Why Thailand's 15 % withholding costs more than it looks

On a 7 % gross yield, a 15 % withholding on gross mechanically removes 1.05 points of yield before a single cost is counted. No expense, no depreciation, no loan interest is deductible against it. That is the price of simplicity: the withholding is easy to administer, but it taxes turnover, not profit.

Portugal: moderate tax, but a rising annual bill

25 % of net income is reasonable. What weighs is the stacking: IMI every year, AIMI above €600,000 of assessed value, and above all a capital gains tax on 50 % of the gain at progressive rates, with an obligation to declare worldwide income to determine the applicable bracket. A well-paid investor at home can therefore see a Portuguese gain taxed near the top of the scale. Compare with capital gains tax on property in Japan, which is flat and known in advance.

Visas and residency: what property buys, and what it does not

This is the most frequently asked question, and the one where outdated information circulates most. Here is the state of the law in 2026.

Country	Does buying property grant residency?	Existing route
Japan	No, never	No bridge whatsoever. The only possible link runs through a real, operating company (the keiei kanri visa, keiei kanri, business manager), whose requirements were substantially raised in 2025
Portugal	No, since October 2023	Real estate was removed from the eligible golden visa investments; what remains is mainly the regulated venture capital fund route from €500,000, excluding direct or indirect real estate
Thailand	Indirectly, yes	The Long-Term Resident visa, wealthy global citizen category, requires around $1M in net assets and $500,000 invested in Thailand, with property an eligible asset; it grants a 10-year stay

Japan: the golden rule, with no exception

Owning property in Japan confers no visa, no residency and no path to permanent residence. You may buy ten assets as a non-resident: your immigration status will not move an inch. That is in fact good practical news, since no residence status is required in order to buy: our article on buying a house in Japan as a foreigner without a visa sets out the full remote procedure.

If living in Japan is the real objective, the only investment-linked route is the keiei kanri visa, which presupposes a company with premises, a business plan and substantive activity. The 2025 reform raised the reference capital from ¥5 million to roughly ¥30 million (from about €33,000 to €200,000) and tightened conditions across the board: see the business manager visa for property investment in Japan.

Portugal: the window has closed

Many articles still online present a €280,000 or €500,000 purchase as a gateway to European residency. That has been false since October 2023: real estate (directly or through property-backed funds) was removed from the eligible investments. Buying an apartment in Porto may be an excellent investment; it is no longer an immigration plan.

Thailand: the only real bridge, reserved for large portfolios

The wealthy global citizen category of the Long-Term Resident visa does accept property within the $500,000 to be invested, but it also requires roughly $1M in net assets and health coverage. It is not an entry-level visa: on a €300,000 budget, the question does not arise.

Worked example: 300,000 euros in Osaka, Phuket or Porto

Let us compare at an identical budget, with explicit and deliberately conservative assumptions. Objective: regular rental income, cash purchase, ten-year horizon, a European investor who is non-resident in all three countries.

Assumptions

• Purchase budget: €300,000 (roughly ¥45,000,000 at ¥150/€).
• Japan: a 55 m² chūko (中古, second-hand) apartment near a station in Osaka, long-term let, 4.5 % gross yield.
• Thailand: a foreign-quota apartment in Phuket, operated in a managed rental pool, 7 % gross yield.
• Portugal: an apartment in Porto on a standard residential lease, 4.5 % gross yield.
• No mortgage, so that we compare assets rather than structures.

Line	Japan (Osaka)	Thailand (Phuket)	Portugal (Porto)
Purchase price	¥45,000,000 (€300,000)	€300,000	€300,000
Acquisition costs	≤ €18,000 (6 %)	≈ €7,500 (2.5 %)	≈ €29,400 (9.8 %)
Total capital committed	€318,000	€307,500	€329,400
Gross annual rent	€13,500	€21,000	€13,500
Costs, management, vacancy, annual tax	− €4,500	− €7,200	− €4,100
Tax on rent	− €0 to €800 (building depreciation)	− €3,150 (15 % of gross)	− €2,350 (25 % of net)
Net annual income in hand	≈ €8,500	≈ €10,650	≈ €7,050
Net yield on capital committed	2.7 %	3.5 %	2.1 %
Nature of the asset after 10 years	Land + building in perpetual freehold	Quota unit, or a lease down to 20 years	Apartment in full ownership
Tax on resale (assumption)	20.315 % of the gain	Progressive, withheld at the Land Office	50 % of the gain at 12.5 to 48 %

Reading the table

On income alone, Thailand comes first. But the ranking recomposes as soon as you look at what you own: in Japan the capital committed is lower than Portugal's, the net income is close to Phuket's without exposure to rental-pool economics, and the asset held includes the land, in perpetuity. In Phuket, the same sum buys either a foreign-quota unit (whose resale depends on the building's remaining quota), or a lease with twenty years left on it a decade from now.

The variant that changes everything in Japan

The same Osaka asset, bought in a zone where short-term accommodation is permitted and operated under licence, is no longer comparable: observed gross yields on that segment sit well above long-term letting, and tax still applies to net income after depreciation. That is precisely immoJapon's playing field: our selected properties are filtered on location and licensing feasibility, and our yield simulator lets you test your own assumptions before committing. For a city-level view, see investing in Osaka property.

Expert tip. Never compare two countries on gross yield. Always recompute three numbers: net yield after local tax, yield on the capital actually committed (costs included), and the residual value of the right you hold at your resale horizon. Those three settle the question.

Common mistakes to avoid

Comparing gross yields across countries

A Thai 7 % taxed on gross and a Japanese 4.5 % taxed on net after depreciation are not the same number. Always bring everything back to net after tax and after entry costs.

Buying a Thai unit outside the quota through a nominee company

The structure still circulates, it is expressly illegal, and it exposes the buyer to the nullity of the acquisition. If the unit you want is not available within the foreign quota, change buildings rather than structures.

Mistaking a 30 + 30 + 30 lease for freehold

Only the first 30-year term is registrable. The rest is a contractual promise whose value depends on the lessor's solvency and good faith, and on their heirs.

Forgetting Portugal's 10 % in the yield calculation

The move to a flat 7.5 % IMT for non-residents in 2026 mechanically degraded entry-level net returns in Portugal. A yield computed on the listed price rather than on capital committed overstates the outcome by roughly 10 %.

Counting on a Japanese mortgage without being a resident employee

This is the most common disappointment. A Japanese mortgage requires residency and local salaried employment. Plan for a cash purchase, or finance from your home country: our article on financing a Japanese purchase from abroad reviews the real options.

Buying in Japan hoping for a visa

No asset, at any price, creates a right of residence in Japan. Always keep the wealth project and the immigration project separate.

Ignoring currency

A euro-based investor carries FX risk in Japan and Thailand, none in Portugal. That risk cuts both ways: a historically weak yen has handed European buyers an entry discount, while a recovering yen raises the euro value of the asset and makes future purchases dearer. See the weak yen and Japanese property.

In Japan, forgetting that value sits in the land

Japanese buildings depreciate; land does not. A high yield on a 40-year-old timber house in a depopulating area is not a bargain: it is an asset winding down. Our article on why Japanese houses lose value while land holds it explains the mechanics, and why location outranks price even on a vacant house.

Operating short-term without checking the licence

Three countries, three regimes, and in all three the penalty falls on the owner. Verify licensing feasibility before making an offer, never after.

Conclusion: which country suits which investor

There is no absolute winner, but three very clear profiles.

• Portugal suits the investor who wants leverage and zero currency risk: it is the only one of the three where a non-resident genuinely borrows. The price is nearly 10 % in entry costs, a capital gain taxed at progressive rates, and a definitive goodbye to the golden visa argument.
• Thailand suits the investor chasing high immediate income and willing never to own the land, to absorb 15 % on gross rent, and to depend on the foreign quota at resale. The Long-Term Resident visa only matters for large portfolios.
• Japan suits the investor who values legal solidity and net-after-tax income: perpetual freehold including land, entry costs capped at 6 %, tax assessed on net income after depreciation, 20.315 % on resale beyond five years, and a record tourism market backed by licence-constrained accommodation. The trade-off is explicit: cash purchase, no visa attached, and an absolute requirement to get the location right.

Our conviction, after working files in all three markets: over the long run, what you own matters more than what you collect in year one. That is exactly where Japan stands apart, and it is also the market where the gap between a good and a bad purchase is widest, because everything hinges on the station, the neighbourhood and the licence. To test your project against real assets, browse our completed projects or tell us about your budget through our personalised support, from property search to handover of the keys.

Frequently asked questions

Is it better to invest in property in Japan, Thailand or Portugal?

It depends on your priority. Japan offers freehold land ownership, purchase costs capped at 6 % and taxation on net income: the best security-to-net-return ratio. Thailand delivers the highest gross yield but bans foreign land ownership. Portugal is the only one of the three giving a non-resident real access to mortgage financing.

Can a foreigner buy land in Japan, Thailand and Portugal?

In Japan and Portugal, yes, with no nationality or residency restriction. In Thailand, no: a foreigner cannot own land. They can only buy a condominium unit within the 49 % foreign quota of the building's floor area, or take a registered 30-year lease.

Which country has the lowest purchase costs?

Thailand, where the 2 % transfer fee is usually split between buyer and seller. Japan stays under 6 % all in. Portugal is the most expensive for a non-resident at roughly 9.5 to 10.3 %, including the flat 7.5 % IMT, stamp duty and legal fees.

Can I get a mortgage to buy in Japan while living abroad?

No. Japanese mortgages are reserved for people who are both resident and employed in Japan. A non-resident buys in cash, or finances the purchase from their home country, for instance by leveraging an existing property there.

Does buying property grant a visa in Japan or Portugal?

No in both cases. Japan has never had a property-linked visa. Portugal removed real estate from its golden visa eligible investments in October 2023. Only Thailand still accepts property within the $500,000 to be invested for its Long-Term Resident visa, and it also requires around $1 million in net assets.

How is a non-resident's rental income taxed in these three countries?

Japan applies 5 to 45 % progressive rates on net income after deducting costs and building depreciation, which often results in a very low effective rate. Thailand withholds 15 % on gross rent with no deductions. Portugal taxes 25 % of net income on a residential lease.

Which country is most favourable to short-term Airbnb-style letting?

Japan, because the framework is explicit: 180 nights a year under a minpaku licence, 365 nights with a simplified lodging licence, and demand supported by 42.7 million visitors in 2025. In Thailand, letting for under 30 days in a condominium is prohibited without a hotel licence. In Portugal registration is easy, but municipalities can freeze the most profitable zones.

What happens to my Thai property when the 30-year lease expires?

Only the first 30-year term can be registered at the Land Office. Renewals promised in the contract are private undertakings, hard to enforce against a third-party buyer or the lessor's heirs. That is the fundamental difference with Japanese or Portuguese freehold, which has no end date.