NovAsia

Cambodia vs Spain: where does property still work without a visa?

Spain offers mature euro liquidity, tourism and full ownership, but property no longer creates a Golden Visa and non-EU rental taxation can be severe; Cambodia lowers the USD ticket and can lift gross yield, with thinner evidence and exit.

Once Spain closed its property Golden Visa, the apartment had to stand on its own again. A purchase at or above €500,000 no longer opens a new investment-residence application: the relevant provisions ceased to apply to new cases from 3 April 2025. The change removes an artificial threshold but places more weight on neighbourhood value, tax and the legality of the rental strategy.

Spain remains a compelling long-hold and lifestyle market. A foreign buyer can acquire full ownership, use notaries and a mature land registry, access deep resale evidence and sell into a broad local and international audience. The trade-offs are a high all-in cost, regional ITP and stamp duty, annual IBI, and—critically for many buyers outside the EU/EEA—a 24% non-resident tax applied to gross rental income without ordinary expense deductions.

Phnom Penh sits at the other end of the spectrum: a lower USD entry ticket, potentially higher headline gross rent and a direct strata route, but no EU status, fewer comparables and a narrower secondary market. Every rate, index, threshold and price below is indicative and must be re-checked for the region, tax residence, licence, exact unit and transaction date.

Rules and deal terms can change; check the exact unit, current documents and contract before committing.

Expectation vs reality

Expectation

A Spanish apartment still bundles an EU asset, rental income and an investor residence permit.

Reality

The real-estate Golden Visa route closed to new cases from 3 April 2025. The asset and the immigration plan now need to make sense independently.

TipLegacy permits and transitional applications can have separate treatment, but a new purchase should carry no residence premium.

Expectation

A strong gross rental yield is close to what the owner keeps.

Reality

Many non-residents outside the EU, Iceland, Norway and Liechtenstein face a 24% tax on Spanish rental income without the ordinary expense deductions available under the EEA-linked regime.

TipTax residence, treaty position and ownership structure can change the answer; 24% is not a universal foreign-buyer rate.

Expectation

If a city allows holiday rentals, any apartment can obtain the necessary permission.

Reality

The answer can depend on autonomous-community rules, the municipality, the address and the building. Two nearby properties can therefore have different operating rights.

TipVerify the exact address before deposit rather than underwriting a promised future licence.

Expectation

Spain's deep resale market will absorb any premium paid for coastal stock.

Reality

Liquidity helps, but lookalike resort units compete on price. A premium paid for furniture, view or projected occupancy may not survive the resale test.

TipUse transaction evidence and current competing stock from the same micro-market.

Side by side (tap a row for the nuance)

CriterionCambodiaSpain
Foreign ownershipAbove-ground strataFull registered title
Spain requires NIE, registry review and source-of-funds evidence rather than a building quota.
Building foreign capUp to 70% areaNo general cap
Cambodia measures the cap by private-unit floor area.
Operating currencyUsually USDEuro
The buyer selects USD or EUR exposure and conversion costs.
Property Golden VisaNo EU routeClosed 3 Apr 2025
A new purchase no longer creates the former investment-residence application.
Resale purchase taxAbout 4% tax baseRegional ITP
The Spanish rate varies by autonomous community, value and relief.
New-home taxLocal tax regime10% VAT plus AJD
Ordinary new housing normally uses 10% VAT; AJD is regional and must be confirmed.
Non-EU rental taxStructure-dependent24% gross income
This Spanish reference applies to many non-EU/EEA non-residents; treaty and status require advice.
Annual property costProperty taxIBI plus charges
IBI depends on cadastral value and municipality.
Short-term lettingBuilding-specificRegion, city and HOA
A national registration number does not replace local licensing.
Recent price indexFewer official series+12.9% y/y, Q1 2026
INE HPI is national and does not value a coast, street or unit.
Resale depthThinDeep secondary market
Spain has more buyers, but an overpriced resort unit can still be illiquid.

Comparison

Spanish acquisition tax starts with one question: new build or resale? The autonomous community then determines the relevant transfer or stamp-duty rates and reliefs.

Option 1 of 4

Phnom Penh

Ticket size
Generally below the major Spanish cities, with no purchase-price threshold tied to residence status.
Acquisition tax
Spanish taxes do not apply; Cambodian transfer and registration charges must be calculated from the local title.
Non-resident rental tax
Spain's non-resident tax does not apply; use Cambodian obligations and the owner's own tax position.
Tourist permission
Depends on the building, local rules and operating structure.
Resale depth
Thinner evidence and a narrower buyer pool make project quality and entry price especially important.
Option 2 of 4

Madrid

Ticket size
A high-ticket urban market, especially in central and prime districts; a new purchase does not create a Golden Visa.
Acquisition tax
Resales use the regional transfer-tax regime; most new homes are subject to VAT plus regional stamp duty. Madrid rates and reliefs need a current transaction check.
Non-resident rental tax
For many non-EEA owners, 24% of gross Spanish rental income is the key benchmark; qualifying EEA residents generally use 19% with directly related expense deductions.
Tourist permission
Address-specific and subject to regional and municipal rules; never assume approval.
Resale depth
A deep urban market with substantial domestic and mortgage-backed demand.
Option 3 of 4

Barcelona

Ticket size
High entry values in many supply-constrained districts, again without an immigration benefit from the purchase itself.
Acquisition tax
Same resale-versus-new-build split, but Catalonia's rates and rules differ from Madrid.
Non-resident rental tax
Same national framework, subject to the owner's status and any applicable double-tax treaty.
Tourist permission
Particularly sensitive to local restrictions and building rules, so permission must be checked before purchase.
Resale depth
Deep but highly segmented; city-wide liquidity does not make every unit liquid.
Option 4 of 4

Coast

Ticket size
Extremely wide: mass-market resorts and premium coastal enclaves sit in the same broad category, so a national average is not useful.
Acquisition tax
The autonomous community matters: Andalusia, Valencia, the Balearics and other coastal regions apply different rates and reliefs.
Non-resident rental tax
Same national framework at the coast; a high seasonal nightly rate does not remove the tax.
Tourist permission
Varies by region and municipality; neighbouring resorts can have materially different answers.
Resale depth
Ranges from very active resale markets to oversupply of similar holiday apartments; micro-location is decisive.

Who should pick which

Spain

Owner-occupier seeking a home in an EU country

Full ownership, infrastructure and mature services are stronger. Residence must be solved through a separate immigration route, not the closed Golden Visa.

Cambodia

CIS-linked non-EU landlord focused on retained rent

Spain’s 24% gross-income tax can materially compress net yield for this status. Phnom Penh is simpler in USD but requires more vacancy and exit reserve.

Spain

Buyer prioritising liquidity and bank-supported comparables

Registry evidence, valuations, mortgages and a large secondary market create more potential exits. The address still matters more than the country average.

Neither

Investor relying exclusively on tourist letting

Spanish licensing or community rules can block the case; Phnom Penh tourism is shallower. A lawful long-term fallback is essential.

Cambodia

Long-hold buyer with limited capital

A smaller entry leaves room for reserves and avoids European acquisition taxes. It only works with issued title and demonstrated long-term demand.

Schemes and red flags

A resort unit carries a large premium over comparable homes

How it works

The premium is justified with 'international demand', view, furniture and projected occupancy, without showing recent transactions for genuinely comparable stock.

Red flag

The pitch has a polished yield but no same-building or same-micro-market resale evidence and no discounted exit case.

What to do

Build a comparable set, strip out the value of promises, and test what portion of the price is supported by the real estate itself.

The tourist licence is described as a formality

How it works

The buyer is told the manager will obtain it after closing, without a written address-level check.

Red flag

The entire return depends on short stays, but there is no legal confirmation of the regional, municipal and building position.

What to do

Underwrite the property with no tourist income until counsel confirms that the intended use is available at that address.

Net yield is shown before non-resident tax

How it works

The model deducts management and utilities but ignores the owner's Spanish tax regime.

Red flag

One 'net yield' is shown to buyers from every jurisdiction.

What to do

Rebuild the cash flow for your own tax residence, available deductions and treaty position.

The former Golden Visa is still used to create urgency

How it works

Marketing continues to connect a new property purchase to a route that closed to new real-estate investor cases from 3 Apr 2025.

Red flag

The seller cannot identify a current legal basis and falls back on vague 'European residency through property' language.

What to do

Separate the asset purchase from the immigration objective and obtain independent advice on any current residence route.

The residence shortcut is gone; the asset must stand alone

Spain ended new property-based investor visa applications with effect from 3 April 2025. The date was checked against the official BOE legislation. Existing permits and transitional cases follow their own rules, but a fresh purchase no longer creates an application under the former €500,000 route.

That does not weaken every Spanish home. It removes the immigration premium that may have supported parts of the upper market. A buyer must now assess ordinary property fundamentals: same-street comparables, building condition, IBI, community fees, legal rental use, energy performance and the future buyer pool.

A Cambodian condominium likewise produces no automatic EU residence or citizenship. The distinction is that Phnom Penh never required a high visa-floor purchase. A pure investor can focus on a lower USD ticket, while a family seeking Spanish residence must qualify through a separate route such as work, digital-nomad, non-lucrative or family provisions.

A 24% gross-income tax can erase a headline yield

A Spanish non-resident who is not resident in the EU or EEA generally faces IRNR at 24% of gross rental income, without ordinary deductions for finance, repairs, community fees or management. The rate was checked against Agencia Tributaria guidance on 3 August 2026 and must be confirmed for the owner, treaty and income period. EU/EEA residents generally use a different 19% framework with qualifying expenses.

The distinction can turn an attractive gross rent into a modest retained return. Vacancy, IBI, insurance, community charges, repairs, agency and tax all belong below the headline number. Even an unlet home can create imputed-income and filing obligations for a non-resident.

Cambodian tax depends on ownership and operating structure, but it does not mirror Spain’s broad 24%-of-gross treatment for many non-EU landlords. That can be an advantage. It does not rescue weak occupancy or management, so both markets must be compared on full-year net cash flow.

ITP, VAT and stamp duty start with asset classification

A Spanish resale normally attracts ITP set by the autonomous community, with rates and relief varying by value and buyer circumstances. Ordinary new housing is generally subject to 10% VAT plus regional AJD. These are references checked on 3 August 2026; the exact calculation depends on the community, contract and completion date.

Before signing an arras agreement, the buyer needs an all-in budget covering tax, notary, registry, lawyer, bank, valuation, renovation and furniture. Arras can expose a material deposit, so finance, due diligence and rental legality should be resolved first.

Cambodia’s transfer-tax reference is approximately 4% of the prescribed taxable base, subject to current relief and structure. The system can be more compact, but the base, payer and registration still need confirmation. Spain wins on procedural depth; Cambodia wins on the absolute amount of capital required.

A short-let licence belongs to an address

Spain does not have one national answer to Airbnb. The autonomous community, municipality, planning zone, housing type, national registration and community-of-owners rules can all change the result. Barcelona plans to let existing tourist-apartment licences expire by late 2028, while the Balearics and other markets apply their own restrictions. Dates and the exact address must be checked before purchase.

A national short-let registration number improves traceability but cannot legalise a home that lacks regional or municipal permission. The buyer needs the current licence, transferability, community consent position and filing history. The seller’s licence may not automatically follow the asset.

Phnom Penh has a shallower tourist market, and condominium rules or an operator can restrict short stays. Long-term corporate leasing is often the stronger fallback. In either country, ask what rent the unit can earn if nightly letting becomes unavailable.

Deep resale markets still punish overpaid coastal stock

Spain has a vast number of transactions, mortgage valuations and public indicators. INE reported the national House Price Index up 12.9% year on year in the first quarter of 2026, including 9.1% for new homes and 13.5% for resales. These Q1 2026 data are market references, not a valuation of an individual coastal complex. Registradores uses a different dataset and methodology.

A strong index does not make a weak resort unit liquid. Buyers examine transport, year-round services, community fees, energy performance, rental restrictions and competing supply. A home sold to an overseas buyer at a premium may need a discount to re-enter the local market.

Phnom Penh provides far less official evidence. That weakness should lead to stricter building-level comparables, not reliance on a developer price list. Real competing units, achieved rent and marketing periods should be provided on client request.

Phnom Penh simplifies dollars; Spain broadens the exit universe

Phnom Penh commonly uses USD for price, rent and payment schedules. A dollar investor can model the asset without a separate operating-currency translation and at a smaller ticket. The resale may be slow, while the owner competes with new launches, instalments and developer incentives.

Spain operates in euros but offers a broader buyer universe: domestic households, EU buyers, mortgage borrowers, lifestyle purchasers and investors. A strong address can have several exit routes. Costs are higher, and a non-resident seller is generally subject to a 3% withholding from the gross sale price as an advance against final tax; applicability must be confirmed at disposal.

The trade-off is simple currency modelling versus market depth. Cambodia is stronger on capital efficiency and potential gross yield; Spain is stronger on evidence and exit audiences. Both should be stress-tested with no appreciation and a long marketing period.

Expert view

Elvira Shamuratova

Spain gives a buyer a broad completed market, but it is a collection of regional tax, tenancy and tourism regimes rather than one uniform investment product. Phnom Penh is easier to enter and harder to exit. I would focus on lawful use, community liabilities, net income under a long-term tenancy and recent closed sales in the exact micro-market.

Elvira Shamuratova

Founder of Elvira Cambodia · Associate Director at Pointer Property · strategic partner of NovAsia

Expert page →

Frequently asked questions

Is Spain’s property Golden Visa still available?

Not for new applicants. The relevant provisions ceased to apply from 3 April 2025. Existing permits and transitional cases require separate review.

Can property ownership still produce Spanish residence?

Not automatically. Work, digital-nomad, non-lucrative, family and other routes have their own conditions and do not arise from title alone.

Why does a non-EU landlord pay 24% on gross rent?

Spanish IRNR generally applies that treatment to many non-EU/EEA non-residents without ordinary expense deductions. Residence and treaty position must be confirmed.

What taxes apply to a Spanish new build?

Ordinary new housing generally carries 10% VAT plus regional AJD, with notary, registry and legal costs. The exact regime must be checked before arras.

Can I buy a licensed tourist apartment and continue Airbnb?

Not automatically. Licence validity, transfer, municipal plans, national registration and community restrictions must be verified for the address.

Why does 12.9% INE growth not guarantee profit?

It is a national Q1 2026 index. A particular unit can be overpriced, restricted, expensive to maintain or weak outside the holiday season.

Which market has the higher net yield?

There is no country-level answer. Spain has deeper demand but heavier tax and entry costs; Cambodia can show higher gross rent but carries more vacancy and exit risk.

How long it really takes

1

Obtain a foreigner identity number

Typical timingPractical guide: from several days to several weeks once an appointment and complete filing are available

What slows it downAppointment scarcity, consular filing, incomplete documents or weak evidence of the economic reason for the request.

2

Open a Spanish bank account if the transaction needs one

Typical timingFrom one appointment to several weeks

What slows it downSource-of-funds review, tax-residence checks, translations and the bank's own compliance process. A Spanish account is not a universal legal condition for every purchase.

3

Complete due diligence and prepare the notarial closing

Typical timingOften 2–6 weeks for a clean cash transaction

What slows it downRegistry/cadastre mismatches, debts, tenants, powers of attorney, financing, missing seller documents or cross-border fund checks.

4

Sign before the notary and lodge the title for registration

Typical timingSigning happens on the agreed date; once properly filed with tax requirements met, the Property Registry's general processing period is 15 business days

What slows it downUnpaid taxes, document defects, corrective deeds or additional registry requirements.

5

Secure tourist-rental authorisation, where the address can qualify

Typical timingSeveral weeks to months; new operation may be unavailable at some addresses

What slows it downAutonomous-community and municipal restrictions, building rules, planning use, caps and regulatory changes.

Decision helper

Situation

Owner-occupier seeking a home in an EU country

Next step

Spain

Keep in mind

Full ownership, infrastructure and mature services are stronger. Residence must be solved through a separate immigration route, not the closed Golden Visa.

Situation

CIS-linked non-EU landlord focused on retained rent

Next step

Cambodia

Keep in mind

Spain’s 24% gross-income tax can materially compress net yield for this status. Phnom Penh is simpler in USD but requires more vacancy and exit reserve.

Situation

Buyer prioritising liquidity and bank-supported comparables

Next step

Spain

Keep in mind

Registry evidence, valuations, mortgages and a large secondary market create more potential exits. The address still matters more than the country average.

Situation

Investor relying exclusively on tourist letting

Next step

Neither

Keep in mind

Spanish licensing or community rules can block the case; Phnom Penh tourism is shallower. A lawful long-term fallback is essential.

Situation

Long-hold buyer with limited capital

Next step

Cambodia

Keep in mind

A smaller entry leaves room for reserves and avoids European acquisition taxes. It only works with issued title and demonstrated long-term demand.

Comparison checks

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Sources (9)

Primary documents and datasets, with issuing body and date.

  • Spanish Official State Gazette (BOE) — repeal of Articles 63–67 of Law 14/2013 and closure of new property Golden Visa applications from 3 April 2025 — checked 03 Aug 2026
  • Agencia Tributaria — IRNR: 24% gross rental-income treatment for many non-EU/EEA non-residents and 19% EU/EEA framework — checked 03 Aug 2026
  • Agencia Tributaria — 10% VAT on ordinary new housing, regional ITP on resales and AJD — checked 03 Aug 2026
  • Agencia Tributaria — 3% withholding on a non-resident seller’s gross consideration — checked 03 Aug 2026
  • Instituto Nacional de Estadística — House Price Index, Q1 2026, +12.9% year on year — checked 03 Aug 2026
  • Colegio de Registradores de España — Q1 2026 Real Estate Registry Statistics, prices and transactions — checked 03 Aug 2026
  • Idealista Data — city asking prices and rents; secondary listing evidence rather than completed transactions — checked 03 Aug 2026
  • Spanish regional and municipal tourist-accommodation registers — Barcelona, Balearic and other address-level licence rules — checked 03 Aug 2026
  • Cambodia Law on Foreign Ownership in Co-owned Buildings and General Department of Taxation — strata ownership, cap and transfer tax — checked 03 Aug 2026

Cambodia: the shared legal checks

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

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