If a lower entry point and condo ownership in a dollarised Asian market are priorities, Cambodia fits better.
When a mature European market and broadly open foreign property ownership matter more, Portugal is the stronger choice.
It depends on your objective and time horizon; this compares markets, not two specific properties.
Portugal offers euro ownership, EU liquidity and tourism, but housing no longer qualifies for the Golden Visa and the 2026 non-resident IMT raises entry cost; Cambodia is cheaper and USD-based, without EU status and with thinner resale evidence.
A Portuguese apartment is no longer a Golden Visa ticket. Since the 2023 changes, direct real-estate acquisition has been removed from the qualifying ARI investments, while the remaining routes concern other forms of capital and activity. Lisbon, Porto or the Algarve therefore need to be selected as property markets rather than packaged as residence products.
Portugal remains strong for long ownership: full title, euro exposure, an EU legal setting, tourism and lifestyle demand, established registries and a broad secondary market. Entry is expensive. From 2026, certain acquisitions of urban residential property by an individual who is not Portuguese tax resident attract a flat 7.5% IMT, usually alongside 0.8% stamp duty. Annual IMI, condominium costs and municipal Alojamento Local rules further shape net yield.
Phnom Penh has no European residence benefit and weaker comparable evidence, but it allows a materially smaller commitment, commonly in USD, through an eligible strata unit. Every rate, index, threshold and price below is indicative and must be verified for tax residence, municipality, rental permission, exact asset and transaction date.
Rules and deal terms can change; check the exact unit, current documents and contract before committing.
| Criterion | Cambodia | Portugal |
|---|---|---|
| Foreign ownership | Above-ground strata | Full registered title |
| Portugal requires NIF, banking and registry due diligence. | ||
| Building foreign cap | Up to 70% area | No general cap |
| Cambodia measures the cap by private-unit floor area. | ||
| Operating currency | Usually USD | Euro |
| The investor’s base currency and conversion costs remain part of return. | ||
| Property Golden Visa | No EU route | Excluded since 2023 |
| ARI remains under other categories; an ordinary home does not qualify. | ||
| Non-resident IMT | About 4% tax base | 7.5% in scope |
| The 2026 Portuguese rate depends on tax residence and statutory exceptions. | ||
| Stamp duty | Within deal structure | Usually 0.8% |
| Portuguese base and applicability must be confirmed at contract. | ||
| Annual property tax | Property tax | IMI about 0.3–0.45% |
| The municipal rate applies to VPT, not necessarily the market price. | ||
| Rental-income tax | Structure-dependent | Often 25% |
| Deductions and long-lease reductions depend on conditions and owner status. | ||
| Short-term letting | Building-specific | Municipal AL rules |
| Registration does not override containment zones or condominium restrictions. | ||
| Recent price signal | Fewer official series | +17.8% y/y, Q1 2026 |
| INE also reported transactions down 8.7%; neither figure values a unit. | ||
| Resale market | Thin | Broader EU market |
| Lisbon, Porto and Algarve have different tenants and exits. | ||
Full ownership, infrastructure and the EU market are stronger. Residence must be obtained through a separate route because housing is outside the Golden Visa.
Portuguese prices, IMT and limited affordable supply restrict the shortlist. Phnom Penh lowers the USD ticket but requires a more conservative resale case.
INE, registries, lenders and a broad audience provide more evidence. Strong national growth does not replace address and condominium review.
A municipality or condominium can restrict the use. Phnom Penh short stays are also not the core tenant base; a long-let fallback is essential.
A lower dollar entry preserves reserves. The unit must work on ordinary long-term rent without promised appreciation or buyback.
Portugal removed direct real-estate investment from the ARI/Golden Visa qualifying list in 2023. AIMA’s current page lists the remaining routes—qualifying funds, job creation, research, culture and other permitted investments—but an ordinary apartment had not returned as at 3 August 2026. Title alone creates no application right.
The change matters for valuation. A seller should not charge a visa premium or blur ownership with a separate immigration route. D7, D8, employment, entrepreneurial and family options may support residence, but each has independent conditions.
A Cambodian condominium also provides no EU residence, yet its investment case was never built around a European visa floor. Portugal is stronger for EU life and long-term capital preservation; Cambodia is stronger for a smaller test commitment. In either market the apartment must work on rent and exit without an immigration bonus.
From 2026, Portugal’s IMT Code applies a flat 7.5% rate to certain acquisitions of urban residential property by an individual who is not Portuguese tax resident. The provision and exceptions were checked in the current text on 3 August 2026; buyer status, use and signing date must be confirmed before the CPCV. Stamp duty of 0.8% generally sits alongside it.
A high sunk entry cost makes a quick flip less robust. Legal, registry, notarial, banking, valuation and renovation costs add to the tax. Becoming resident later does not necessarily refund tax paid on an earlier non-resident acquisition.
Cambodia’s transfer-tax reference is approximately 4% of the prescribed base, sometimes with temporary relief for qualifying condominiums. The system is less expensive in absolute terms, but base, payer and registration still require advice. Portugal offers institutional maturity; Cambodia reduces the cash cost of a wrong selection.
INE reported Portuguese house prices up 17.8% year on year in the first quarter of 2026 while the number of transactions fell 8.7%. The Q1 2026 indicators are national references. They can coexist because scarce supply and a shift in the mix of sold homes can support prices while fewer deals complete.
Lisbon, Porto and the Algarve have different engines. Lisbon combines local households, international businesses and expatriates but faces severe affordability pressure. Porto is smaller and neighbourhood-, university- and tourism-dependent. The Algarve is more lifestyle- and seasonal, with higher remote-management costs.
Phnom Penh lacks a comparable official series, which is a real weakness. It should be offset with building-level evidence: achieved rents, completed resales and marketing periods. Neither a Portuguese national index nor a Cambodian developer list price should be applied to a unit without adjustment.
Alojamento Local depends on the municipality, containment zone, legal use, safety compliance and condominium rules. Following multiple reforms, municipalities have greater power to limit new registrations and supervise existing stock. Lisbon and every other municipality must be checked by exact address and effective date.
A registration number is not a perpetual operating right and may not transfer without conditions. The buyer needs the licence file, condominium minutes, complaints, operating history, insurance and fire-safety compliance. Revenue must be reduced for platforms, cleaning, utilities, management, tourist tax and seasonal vacancy.
Short stays are secondary to corporate renting in much of Phnom Penh and may be restricted by condominium rules. A strong asset in either country needs a long-term fallback. If ordinary rent cannot carry the costs, the purchase is too dependent on municipal permission and peak season.
Portuguese municipalities generally set IMI around 0.3% to 0.45% for urban property, applied to the taxable value VPT rather than necessarily the transaction price. The range was checked on 3 August 2026 and must be confirmed for the municipality and tax record. Condominium fees, insurance, minimum utilities and maintenance continue when the unit is empty.
A standard autonomous rental-income tax rate of roughly 25% applies to many owners, while deductible costs and reduced treatment for qualifying long leases depend on detailed conditions. A long contract does not automatically earn a reduction; term, compliance and taxpayer status matter.
Cambodian annual property tax and common charges can be lower in absolute terms, but vacancy is more damaging in a smaller tenant pool. Compare full-year net income after repair reserves and management. Owner-specific rates must be calculated for the income date.
A well-positioned Portuguese home can appeal to a local household, EU buyer, expatriate, lifestyle owner or long-term investor. Registry evidence, mortgage valuations and notarial procedure create more comparables. High prices and taxes nevertheless reduce the buyer pool and extend the period needed to recover entry costs.
Phnom Penh is accessible at a lower USD ticket. A buyer can retain more reserve while acquiring a completed or off-plan strata unit. On exit, the seller competes with developer stock and instalments, making issued title, practical size, honest common costs and a rental history critical.
Portugal is stronger for euro liquidity and lifestyle utility; Cambodia is stronger for capital efficiency. Both should be modelled with no appreciation and a long sale period. Completed comparable sales should be supplied on client request rather than replaced by a country average or project marketing estimate.
Portugal offers a mature euro resale market and far better evidence, but the buyer pays for that depth through acquisition tax, carrying costs and a higher basis. Cambodia preserves more capital at entry while leaving a narrower exit route. I would model the property without a housing-linked Golden Visa assumption and verify local letting rules, annual charges and achieved comparables.
Elvira Shamuratova
Founder of Elvira Cambodia · Associate Director at Pointer Property · strategic partner of NovAsia
No. Direct real-estate acquisition was removed from qualifying ARI investments in 2023 and had not returned as at 3 August 2026.
AIMA lists other categories including qualifying funds, job creation, research and culture. Each has its own conditions; an apartment does not qualify by itself.
From 2026 the rate applies to certain urban residential acquisitions by an individual who is not Portuguese tax resident. Status, use and exceptions must be confirmed before CPCV.
Municipal rates for urban property are generally around 0.3–0.45% of VPT, not market value. The exact municipality and tax record determine the amount.
Not automatically. Municipal zone, transfer of registration, condominium rules, safety and current restrictions all need review.
A change in the mix of sold homes and scarce supply can lift the index despite fewer completions. INE Q1 2026 does not value an individual apartment.
No. The lower USD ticket helps, while resale and data are weaker. The advantage only survives with clear title, real tenant demand and a credible exit.
Primary documents and datasets, with issuing body and date.
The country-specific rules belong in one guide, not repeated in full on every comparison.
Foreign ownership and strata title · Taxes, fees and cost of ownership
For creditworthiness assessments from 1 August 2026, Banco de Portugal’s Recommendation sets a 45% debt-service-to-income ceiling and an 80% loan-to-value ceiling for purposes other than an owner’s permanent home. These are macroprudential limits, not a promise that a bank will lend a non-resident 80% of the price: a lender may require more equity or decline the application. An investment buyer should obtain written pre-approval and model at least 20% equity against the price before IMT, stamp duty and closing costs.
A Cambodian developer instalment plan is not a mortgage. Its protections come from the SPA rather than a bank’s affordability assessment. Compare more than the monthly payment: check when registered title can pass, what secures money already paid, default penalties, termination rights and what happens to payments if construction is delayed.
A Portuguese CPCV is optional, but once signed its terms govern the parties before completion. The official government guide requires it to identify the property and encumbrances, price and payment method, deposit amount, final-contract deadline and consequences of non-performance. The checklist does not prescribe a universal deposit percentage, so market custom should not be mistaken for a statutory rule.
Before signing, the buyer’s lawyer should make deposit exposure conditional on satisfactory title, permit and debt checks and, where relevant, finance approval. In Cambodia the reservation form and SPA perform the equivalent risk-allocation work: the reservation amount, document-delivery deadline, refund triggers and consequences of withdrawal should be settled before money moves. A contractual promise to convey a unit does not replace registration of title.
For a Portuguese property, obtain a current caderneta predial, permanent land-registry certificate or full registry extract, use licence, energy certificate, housing technical file where applicable, and the condominium no-debt declaration. Any person may request the permanent registry certificate; it remains valid for six months, so its access code should still be current both during due diligence and at completion.
For a Cambodian unit, the pack is different: the seller’s and developer’s legal identities, the project’s underlying land title, documentary status of the co-owned building, exact block-floor-unit identification, evidence that foreign quota remains available, and the SPA route to registration. Article 8 of the 2010 law separates contract from title: an agreed transfer of special co-ownership has no effect until registration. Counsel’s report should distinguish documents that exist now from documents still promised and identify who must obtain each one.
Nov