Owner-occupier seeking a home in an EU country
Spain
Full ownership, infrastructure and mature services are stronger. Residence must be solved through a separate immigration route, not the closed Golden Visa.
With a tighter budget and a preference for a modern condominium → Cambodia is usually more accessible.
If you prioritise market maturity, location choice and broader foreign ownership rights → Spain has the advantage.
It depends on your objective and time horizon; this compares markets, not two specific properties.
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.
| Criterion | Cambodia | Spain |
|---|---|---|
| Foreign ownership | Above-ground strata | Full registered title |
| Spain requires NIE, registry review and source-of-funds evidence rather than a building quota. | ||
| 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 buyer selects USD or EUR exposure and conversion costs. | ||
| Property Golden Visa | No EU route | Closed 3 Apr 2025 |
| A new purchase no longer creates the former investment-residence application. | ||
| Resale purchase tax | About 4% tax base | Regional ITP |
| The Spanish rate varies by autonomous community, value and relief. | ||
| New-home tax | Local tax regime | 10% VAT plus AJD |
| Ordinary new housing normally uses 10% VAT; AJD is regional and must be confirmed. | ||
| Non-EU rental tax | Structure-dependent | 24% gross income |
| This Spanish reference applies to many non-EU/EEA non-residents; treaty and status require advice. | ||
| Annual property cost | Property tax | IBI plus charges |
| IBI depends on cadastral value and municipality. | ||
| Short-term letting | Building-specific | Region, city and HOA |
| A national registration number does not replace local licensing. | ||
| Recent price index | Fewer official series | +12.9% y/y, Q1 2026 |
| INE HPI is national and does not value a coast, street or unit. | ||
| Resale depth | Thin | Deep secondary market |
| Spain has more buyers, but an overpriced resort unit can still be illiquid. | ||
Full ownership, infrastructure and mature services are stronger. Residence must be solved through a separate immigration route, not the closed Golden Visa.
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.
Registry evidence, valuations, mortgages and a large secondary market create more potential exits. The address still matters more than the country average.
Spanish licensing or community rules can block the case; Phnom Penh tourism is shallower. A lawful long-term fallback is essential.
A smaller entry leaves room for reserves and avoids European acquisition taxes. It only works with issued title and demonstrated long-term demand.
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 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.
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.
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.
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 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.

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
Not for new applicants. The relevant provisions ceased to apply from 3 April 2025. Existing permits and transitional cases require separate review.
Not automatically. Work, digital-nomad, non-lucrative, family and other routes have their own conditions and do not arise from title alone.
Spanish IRNR generally applies that treatment to many non-EU/EEA non-residents without ordinary expense deductions. Residence and treaty position must be confirmed.
Ordinary new housing generally carries 10% VAT plus regional AJD, with notary, registry and legal costs. The exact regime must be checked before arras.
Not automatically. Licence validity, transfer, municipal plans, national registration and community restrictions must be verified for the address.
It is a national Q1 2026 index. A particular unit can be overpriced, restricted, expensive to maintain or weak outside the holiday season.
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.
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