Nationality, residence and status: three different tests
Lenders and governments look at three separate facts: your citizenship, where you are tax resident, and the immigration permission you hold. A Brazilian with permanent residence in Portugal faces different rules from a Brazilian on a two-year work visa, even though both hold the same passport.
This guide focuses on the rules triggered by nationality and visa status. Questions about buying where you do not live, or about expats settled in a new country, are covered in dedicated guides on non-resident and expat mortgages.
When the state restricts the purchase itself
Some countries limit whether a foreign national may own a home at all. The mortgage question then comes second: a bank cannot lend on a purchase that the law forbids, and a deposit paid on such a contract may be hard to recover.
Restrictions also appear in places better known for open markets. Several US states have passed laws since 2023 limiting land purchases by citizens of specified countries, while Gulf states such as the UAE and Qatar confine foreign freehold ownership to designated zones, so the exact address matters.
Examples of foreign-buyer restrictions in 2026
| Country | Rule for foreign nationals | Practical effect on borrowing |
|---|---|---|
| Canada | Prohibition on residential purchases by non-Canadians, extended to 1 January 2027, with exemptions for some work-permit holders and refugees | Lenders ask for proof of an exemption before issuing an offer |
| Australia | FIRB approval needed; established dwellings closed to most foreign persons from 1 April 2025 to 31 March 2027 | Financing focuses on new-build homes with approval in hand |
| New Zealand | Since 2018, most non-residents cannot buy existing homes; Australian and Singaporean citizens are exempt | Residence class visa often decisive |
| Switzerland | Lex Koller limits purchases by persons abroad, especially holiday homes | Permit must precede any mortgage commitment |
| Thailand | Land ownership barred; condominiums allowed within a 49 % foreign quota per building | Funds usually must arrive from abroad in foreign currency |
| Mexico | Restricted zone near borders and coasts; ownership through a bank trust | Trust costs add to the loan budget |
Extra taxes on overseas buyers
Where ownership is allowed, a surcharge may apply. Singapore levies additional buyer’s stamp duty of 60 % on foreigners since April 2023, England adds a 2 % stamp duty surcharge for non-residents, and several Australian states and Canadian provinces charge foreign purchaser duties on top of standard transfer taxes.
How lenders treat foreign nationals
In most open markets, including the UK, Ireland, Germany, Spain and the United States, no law bars a foreign citizen from obtaining a mortgage. Banks instead set internal policies on visa type, residence history and credit records, so two lenders can treat the same applicant very differently.
Visa type and remaining validity
Permanent residents and EU citizens living in another Member State are usually assessed like locals. Holders of temporary work visas often face a minimum residence period, a requirement for a set number of years left on the visa, and lower maximum loan-to-value ratios than citizens receive.
Students, seasonal workers and applicants on visitor visas are rarely financed. Some lenders accept a pending renewal, others refuse until the new permit is issued, which matters when a purchase date is tight.
Credit history that does not travel
Credit bureaus are national, so a strong record in Lagos or Toronto is invisible in Madrid or London. Newcomers compensate with longer local banking history, larger deposits, international credit reports where a lender accepts them, and evidence of rent paid on time.
Sanctions, FATCA and passport-specific barriers
Citizenship can also matter for compliance reasons. Banks screen applicants against sanctions lists, and many non-US institutions decline US citizens because of FATCA reporting duties. Nationals of high-risk jurisdictions may face enhanced due diligence that lengthens approval considerably.
Who these options suit
Foreign-national mortgages suit buyers with a secure, long-term residence status or a clear exemption from ownership rules, verifiable income and a deposit larger than locals usually need. Those on short or uncertain permits often do better renting until their status stabilises.
They also suit applicants whose nationality gives them treaty or bloc rights, such as EU citizens moving within the Union or Australians buying in New Zealand. In those cases the mortgage application usually looks much like a citizen’s, apart from the newcomer credit-history issue.
Typical conditions and documents
Expect requests for a passport, residence permit with expiry date, local tax number, employment contract, recent payslips, bank statements and, where relevant, the government approval for the purchase. Deposit levels, margins and fees vary by lender and change frequently, so compare written offers.
- Check whether foreigners with your status may legally buy the type of property you want, and whether a permit is needed.
- Calculate any foreign-buyer surcharge, approval fee or trust cost and add it to the purchase budget.
- Ask lenders directly about visa types accepted, minimum validity left and maximum loan-to-value for your situation.
- Confirm each lender in the national regulator’s register, such as the FCA, the Banco de España, OSFI-supervised bank lists or the CFPB’s guidance for US state lenders.
- Obtain the government approval or exemption proof before signing a binding purchase contract.
- Compare annual percentage rates across at least two offers and read the full terms in a language you understand.
Pitfalls and warning signs
- Signing a purchase contract before checking that foreign ownership is permitted.
- Using a nominee or local front owner to bypass ownership limits, which can void the purchase and expose you to penalties.
- Assuming a visa renewal will be granted when the loan term depends on it.
- Forgetting foreign-buyer taxes that cannot be financed by the mortgage.
- Paying an agent who promises to arrange FIRB or permit clearance plus a guaranteed loan for a fee upfront: approvals come only from the authority, and upfront loan fees to strangers are a known fraud pattern.
If a lender refuses because of status
Ask which criterion failed and whether it changes after a longer residence period. Specialist lenders, banks from your home country with branches abroad, or a larger deposit sometimes resolve the gap. Unlawful discrimination by nationality can be reported to the relevant ombudsman.
Can a work-permit holder get a mortgage in Canada before 2027?
Possibly. The ban contains exemptions for certain temporary residents meeting work, tax and occupancy conditions, plus refugees and some others. Lenders will ask for documents proving the exemption, so confirm eligibility with a Canadian lawyer before making an offer.
Does a foreign passport mean a higher interest rate?
Not directly. Pricing reflects risk factors such as deposit size, income currency and residence status. Because foreign nationals more often present those risks, they frequently receive higher margins, but a permanent resident with local income may obtain standard pricing.
Can I buy in Australia as a temporary resident?
Temporary residents generally need FIRB approval and, during the restriction running to 31 March 2027, are largely limited to new dwellings or vacant land for building, subject to exceptions. Check the ATO guidance and conditions before applying for finance.
Does dual nationality help?
Often. If one of your passports is from the property country or a favoured bloc, such as an EU passport for buying in Spain, you are usually treated as a national. Declare both citizenships truthfully, because banks check them for compliance.
Useful organisations and resources
- Banco Santander Spain: non-resident mortgages — Official page of a Spanish bank lending to buyers of any nationality, with documentation requirements for foreign applicants.
- UBS Wealth Management: financing solutions (Singapore) — Global private bank describing property and secured lending for internationally mobile clients, regardless of where they hold citizenship.
- CIC News: Canada extends foreign home buyer ban — Immigration news outlet explaining which newcomers, students and work-permit holders are affected by Canada’s foreign-buyer ban.
Official and legal references
- Australian Taxation Office: foreign investment in residential property (FIRB) — Official ATO guidance on approval, fees and the temporary restriction on foreign persons buying established homes in Australia.
- Bennett Jones: Canada extends ban on foreign home buyers to 2027 — Law-firm summary of the extension of Canada’s prohibition on residential purchases by non-Canadians and its main exemptions.
- Herbert Smith Freehills Kramer: FIRB update 2025 — Legal briefing on the 2025 changes to Australian foreign-investment rules for residential land and established dwellings.
