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REFERENCE · UPDATED 2026.11

Cross-border property terms, explained plainly

Thirty terms that come up when a Chinese household buys property outside China. Each one gets a plain definition, and one line on why the buyer asks it — because the question behind a term is usually more useful than the term itself.

Residency and citizenship

CBI — citizenship by investment

A route to a second passport by investing in a country, usually a government contribution plus a property purchase or a donation. Applicants and family members are vetted before approval. Programmes and thresholds change often; the government gazette, not a brochure, is the reference. Why buyers ask: it decides whether the property is an investment or a means to an end.

RBI — residency by investment

A residence permit granted in exchange for an investment, without leading to citizenship on its own. Most European routes now require a minimum holding period before renewal. Why buyers ask: Chinese families usually want the residence right and the property separately, so they need to know which one they are buying.

Golden visa

The working name for residency-by-investment schemes that were designed to attract capital — Portugal, Greece, Spain, Ireland and others. Several have been closed, narrowed or repriced since 2023, most of them by removing real estate from the qualifying list. Why buyers ask: because advice circulating in China is often a year behind the actual rules.

MPRP — Malta Permanent Residence Programme

Malta's permanent residence route: a government contribution, a qualifying property (rented or bought) and a donation, held for a set period. It grants residence, not citizenship. Why buyers ask: it is one of the few European routes where the property requirement is explicit and the cost is calculable.

SDA — Special Designated Area

Designated zones in Malta where non-EU buyers may purchase without the usual permit. Outside an SDA, a foreign buyer needs an AIP permit. Why buyers ask: the same apartment can be open to them or not, purely by address.

AIP — Active Investor Plus (New Zealand)

New Zealand's investor residence visa, with minimum investment depending on the category chosen, plus a residence requirement. Since late 2025, applicants may also buy residential property above a high threshold. Why buyers ask: it is one of the few routes that combines a stable jurisdiction with an actual home.

Due diligence (in an investment migration file)

The background check run on an applicant — criminal record, civil litigation, sanctions, media, and the plausibility of the declared wealth. It is done by the government, and separately by the agent. Why buyers ask: a failed check is not refundable in most programmes.

Source of funds vs source of wealth

Two different questions. Source of funds is where this specific money came from; source of wealth is how the family accumulated it over time. Most rejections come from the second one. Why buyers ask: Chinese applicants often have clean funds and complicated wealth histories.

Ownership and structure

Freehold and leasehold

Freehold means owning the land and building outright. Leasehold means owning a right to use them for a fixed term, often 99 or 999 years. Why buyers ask: in London and Hong Kong the difference decides resale value, and Chinese buyers are used to 70-year land grants at home.

Title deed

The registered record of ownership. What matters is not that it exists but who is named on it, and whether anything is registered against it. Why buyers ask: names on the deed determine tax, inheritance and, later, the ability to sell.

SPV — special purpose vehicle

A company set up to hold a single asset. It can simplify joint ownership and later transfer of shares, but adds reporting obligations and can change the tax treatment on exit. Why buyers ask: usually because someone suggested it without explaining the exit cost.

Trust and foundation

Legal arrangements where assets are held by one party for the benefit of another. Used for succession and privacy, not for avoiding the tax of the country where the property sits. Why buyers ask: cross-border inheritance is the second question after tax, and the answer is rarely "put it in a trust".

Joint tenancy vs tenancy in common

Joint tenancy passes the property automatically to the surviving owner. Tenancy in common lets each owner hold a defined share, which can be left to heirs. Why buyers ask: couples buying with adult children need this decided before completion, not after.

Escrow

A third party holds the money until agreed conditions are met. In some markets it is mandatory for off-plan purchases; in others it barely exists. Why buyers ask: it is the only real protection against paying a developer who then delays.

Cost

Holding cost

Everything paid every year after the purchase: property tax, service charge, insurance, management, maintenance, and the accountants' fees for filing. Why Chinese buyers ask: because the purchase price is the only number most brochures show, and holding cost decides whether the property can be kept.

Stamp duty

A tax on the purchase, charged as a percentage of price, sometimes with a surcharge for foreign buyers. Why buyers ask: the surcharge can add 15–20% in some markets, which changes the whole calculation.

Capital gains tax

Tax on the profit when the property is sold, based on residence status and holding period. Why buyers ask: it is the number that decides whether the exit was worth doing.

Service charge and sinking fund

The annual fee for shared buildings, plus a reserve collected for future major repairs. A low service charge with no sinking fund usually means a large bill later. Why buyers ask: this is where a cheap-looking building turns expensive.

Letting fee and management fee

What the local agent keeps for finding a tenant and for managing the property — commonly 8–15% and 5–10% of rent respectively, varying by market. Why buyers ask: net yield is calculated after these, and the difference between gross and net is often a third of the income.

Gross yield and net yield

Gross is annual rent divided by price. Net deducts service charge, tax, letting and management fees, insurance, maintenance and vacancy. Why buyers ask: because the gap between the two numbers is the single most common misunderstanding in cross-border purchase.

Vacancy rate

The share of the year a property sits empty, or the share of a building's units unlet. Both matter: the first to the owner, the second to the neighbourhood. Why buyers ask: a building that looks full in photos can be half empty in February.

Process and paperwork

Notarised POA — power of attorney

A document letting someone sign on the buyer's behalf, notarised and usually legalised for use abroad. Chinese buyers often need it because they cannot be in the country for completion. Why buyers ask: without it, every signature requires a trip.

Apostille

A stamp certifying that a public document is genuine, accepted between countries that signed the Hague Convention. China joined in November 2023, which removed a step that used to take weeks. Why buyers ask: because it changed the timeline of every document-heavy purchase.

KYC and AML

Know-your-customer and anti-money-laundering checks: identity, address, the origin of funds, and sometimes the source of wealth. Why buyers ask: the file is requested by the lawyer, the bank and the developer separately, and each wants it in a different format.

Reservation fee

A small payment to take a unit off the market for a stated period. It should come with written terms on what happens if the buyer withdraws. Why buyers ask: because it is the first money at risk, and the terms are often verbal.

Preliminary agreement (CPC, compromesso)

The binding contract before completion, setting price, deposit, deadline and penalties. In many markets the deposit is forfeited if the buyer withdraws. Why buyers ask: this is the document that actually commits them, not the reservation.

Completion

The final transfer: funds move, the deed is registered, keys change hands. Why buyers ask: because everything promised verbally is either in the completion documents or does not exist.

Off-plan

Buying before or during construction, usually at a lower price in exchange for delivery risk. Why buyers ask: it is common in Dubai and Southeast Asia, and the question that matters is who guarantees delivery, not the discount.

Exit

Exit liquidity

How easily the property can be sold, to whom, and how long it takes — measured in months on market and in the number of realistic buyers. Why Chinese buyers ask: it has become the first question since 2024, replacing "where is it rising fastest".

Resale market

The market for second-hand units, as distinct from buying from a developer. A market with almost no resale activity is a market where the only buyer is another foreign investor. Why buyers ask: because a project that cannot be resold has no exit, whatever the brochure says.

How to use this page

If you are a developer or an agent, the useful part is not the definition but the question underneath it. When a Chinese buyer asks what the holding cost is, they are asking whether they can keep the asset for ten years. When they ask about exit liquidity, they are asking who will buy it from them.

If you are a buyer, use these terms to check whether the person advising you is answering the question you actually asked.