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Hi all ,

Im thinking of purchasing a property in Southern Thailand for investment purposes . Maybe Hua Hin / Cha-Am .....The plan is to put this up for rent to either tourists and/or locals depending on the area , type of property etc . I am more than a little concerned about the Thai Limited Company ownersip law . Can anyone explain what kind of chances there really are of me loosing part of , or all of my investment under this law ?

I have a condo in BKK , but this is simple in comparison , because I can easily own this freehold without the creation of the company , but for the land on which a property sits , in this case I need a company .

I have a Thai girlfriend whom I love very much , but Im not sure if Im ready to put all of the property into her name as yet .....if you know what I mean !

Thanking you ,

Sadako

( She never sleeps )

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Hi all ,

Im thinking of purchasing a property in Southern Thailand for investment purposes . Maybe Hua Hin / Cha-Am .....The plan is to put this up for rent to either tourists and/or locals depending on the area , type of property etc . I am more than a little concerned about the Thai Limited Company ownersip law . Can anyone explain what kind of chances there really are of me loosing part of , or all of my investment under this law  ?

I have a condo in BKK , but this is simple in comparison , because I can easily own this freehold without the creation of the company , but for the land on which a property sits , in this case  I need a company .

I have a Thai girlfriend whom I love very much , but Im not sure if Im ready to put all of the property into her name as yet .....if you know what I mean !

Thanking you ,

Sadako

( She never sleeps )

This topic has been covered a billion times on here already, in your case putting the land in your GF's name and then leasing it from her or using the USUFRUCT loophole that is becoming the trend. please do a search on this forum for "usufruct" to get the details. the property can be in your name and with usufruct your name will appear on the back of the land title and you have a right of habitation for the rest of your life.

The company route is only easy if you have active business transactions going on in Thailand. the company will have to be seen to be trading properly and submitting monthly vat returns and half yearly and annual audits. this can cost between 50,000 and 180,000 thousand baht per annum. if you just register a company and do nothing but have land titles registered you are taking a huge risk.

either way you need to do a search and read more up on this much discussed topic.

good luck.

and dont just put it in her name!!!! the temptation to do something naughty is just too much for some thai ladies!

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Under the Thai company owning land, it is difficult to believe this would go wrong,

for instance their are real foreign investment companies with factories-retail-condos, to change the ruling it would be saying no more foreign investment in Thailand. If this was to happen the party would be completely over anyway, if they closed this loop hole they would be closing the door to us all anyway.

At the moment every company owning land-house farang owned has to pay tax. The Thai government is receiving tax from this at a fantastic level, for instance in the village the average wage is between 24000-36000bht a year, the tax for a company with a house is about 15000bht a year.

I have looked into buying a property in a Thais name and then leasing it back, let me tell you the catch.

In the lease there is always a buy back clause for the Thai.

(this is a true story) I know a guy who lives in the Royal Park Estate, he lives there

with his Thai boyfriend, the house is in the boyfriends name, my friend has a 30 year lease. He is now 55 so another 30 years should see him through, He purchased the house for 2,5million bht, the houses on this estate now sell for 3.5 million bht, The buy back clause is if the Thai owner wont’s to buy back the lease he has to pay the lease holder (Thai boy friend pay the farang man) 2.5 million bht. The house is already worth more than that, when the Thai boyfriend has had enough he can simply sell the house pay the man off and go back to the village. The farang man may receive the 2.5 million bht but will not be able to buy back into the same market place.

The Thai in this case owns the land and house and will take it back when he is ready, and I would recommend to any person to

seriously think against using this system, it is dangerous and with time the farang will find they are not in control. :o:D

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In the lease there is always a buy back clause for the Thai.

This is absolute terd.

Leases are generally written by farang solicitors for the benefit of farangsand

I have never seen anybody have such a clause in their lease, only a fool would have this added...........or somebody who has been tricked: your "friend"

please see below for a draft of an initial lease that is typical but not exhaustive.

Once this lease is done in English and Thai and taken to the land office there is no "buy back clause for the thai"

LEASE AGREEMENT

AGREEMENT MADE AT_______________

_________________________________

_________________________________

DATE_____________________________

This Lease Agreement is between________________________________________

__________________________________hereafter known as the Lessor and

____________________________________________________________________

__________________________________hereafter known as the lessee

It is hereby agreed as follows

1. The Lessor agrees to lease and the Lessee agrees to rent a____storey home and land,located at_______________________in accordance to Land Title Deed No.______________________Land Number_______________________________

Book number_________________________Page number____________________

Tambon__________________________Total Land Size_____________Sq Wah

hereinafter known as the "Said Premises" for a rent period of 30 years.

2.The Lessee agrees to a one time advance payment for the entire rent period in the amount of________________Baht (_______________) to the Lessor on the date of this Agreement.The Lessor and the Lessee agree to register the leasing terms and conditions at the District Land Office within 7 days after making this agreement. The rent begins on the date of registration at the District Land Office.

3. Both parties agree that the Lessee shall have an option to renew this lease for an additional 30 years, for rental terms and conditions as mutually agreed by both parties.

4. After the date of this agreement the Lessee shall have the right to live in and conduct legal and socially acceptable businesses in the Said Premises during the term of this Lease Agreement.

5. The Lessee agrees to take care of and to preserve the Said Premises as one would do to his/her own and maintain the upkeep of and also attend to repairs of the Said Premises which may be caused by accidental or intentional actions of the Lessee or the Lessee,s subordinates.

6.The Lessee may assign or sublet the Said Premises to other Parties. Should there be the need to make official registration or other legal proceedings,the Lessor agrees to give consent and to assist the Lessee in providing proper documentation and shall not ask for any returns from the Lessee. The Lessee agrees to pay for any fee and other expenses that may arise from such proceedings,

7. The Lessee agrees not to damage or deface the Said Premises or make structural alterations or additions thereto without the written consent in writing of the Lessor and all structural alterations shall be in accordance with government and municipal guidelines. The Lessee agrees to pay any costs involved while the Lessor agrees to provide necessary documentation in obtaining such official permits.

8.Should the Lessor wish to sell the Said Premises, the Lessee shall have the first option to purchase from the Lessor or the option to find other party to purchase from the Lessor. Should the Lessee be unable to find such party to purchase from the Lessor the Lessor may sell Said Premises as he/she so wishes. The Said Premises shall not be sold or Title transferred during the Lease period. Debts accrued by the Lessor to outside parties shall not effect the lease terms.

9.Should Thai laws allow non-Thai citizens to purchase properties, the Lessor shall give the first right to purchase the Said Properties to the Lessee as a special condition.

10. The terms and conditions of this Lease Agreement obligate the heirs of both parties to fulfill to the letter and shall not be altered without mutual consent.

11. The Lessee shall be responsible for paying Building Tax (Rong Ruen Tax) and Land Tax for the duration of the lease period.

12.On the day the Lease Agreement is made, the Lessee shall inspect the Said Premises including all the fixtures and fittings therein to be of good and tenantable condition and accepts lease responsibility henceforth.

13. Should the Lessor be unable to carry out the terms and conditions stated above the Lessee have the right to ask for compensation five times the rent amount and the special condition amount that the Lessee has prepaid.

14 In the event of the Lessee untimely death while the Lease Agreement is still in effect,the rights and obligations of the Lessor shall be transferred to________________________________________________adress________________________

______.

Both parties having read and fully understanding its contents,agree to comply with all the terms and conditions. Ttherefore both parties have hereunder affixed their signatures in presence of two witnesses on the date at the place first written above.

___________________The Lessor

___________________The Lessee

___________________Witness

___________________Witness

The draft lease above is freely available on this forum, i copy and pasted it from another thread.

Sadako

I suggest you take expert legal advice as there is too much barstool anecdotes on here. talk to sunbelt legal, they have a banner at the top of the page and sponsor this forum. they know the facts.

Richard

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terd  :o so i take it you have gone down this route,

any thai solictor that tells you this is ensuring that the money stays in thai hands,

The point i'm making is that your claim that "there will always be a clause that allows Thai's to buy back" is not true. its absolute nonsense to even try and air such a claim on tv.com.

Can you show me a lease that any farang with a brain cell has actually signed that allows a thai lessor to buy his way out of a lease???

no.

please do a search on this forum and get some understanding of the subject before you start offering advice to others.

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Under the Thai company owning land, it is difficult to believe this would go wrong,

for instance their are real foreign investment companies with factories-retail-condos, to change the ruling it would be saying no more foreign investment in Thailand.  If this was to happen the party would be completely over anyway, if they closed this loop hole they would be closing the door to us all anyway.

At the moment every company owning land-house farang owned has to pay tax. The Thai government is receiving tax from this at a fantastic level, for instance in the village the average wage is between 24000-36000bht a year, the tax for a company with a house is about 15000bht a year.

I have looked into buying a property in a Thais name and then leasing it back, let me tell you the catch.

In the lease there is always a buy back clause for the Thai.

(this is a true story) I know a guy who lives in the Royal Park Estate, he lives there

with his Thai boyfriend, the house is in the boyfriends name, my friend has a 30 year lease. He is now 55 so another 30 years should see him through, He purchased the house for 2,5million bht, the houses on this estate now sell for 3.5 million bht, The buy back clause is if the Thai owner wont’s to buy back the lease he has to pay the lease holder (Thai boy friend pay the farang man) 2.5 million bht. The house is already worth more than that, when the Thai boyfriend has had enough he can simply sell the house pay the man off and go back to the village.  The farang man may receive the 2.5 million bht but will not be able to buy back into the same market place.

The Thai in this case owns the land and house and will take it back when he is ready, and I would recommend to any person to

seriously think against using this system, it is dangerous and with time the farang will find they are not in control. :D  :D

Wow, didn't this guy say "hold on a minute" when he read the clause. Seems like the worst case of a "post coital" signature I've ever come across :D Never the less, the lawyer could have worked for me anytime, seems slippery even by thai standards. :o

It is not the case that Companies could be stopped acquiring land, just bogus ones. The tax is irrelevant as total income to the Government, they'd make more by reforming the visa run nonsense.

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terd  :o so i take it you have gone down this route,

any thai solictor that tells you this is ensuring that the money stays in thai hands,

The point i'm making is that your claim that "there will always be a clause that allows Thai's to buy back" is not true. its absolute nonsense to even try and air such a claim on tv.com.

Can you show me a lease that any farang with a brain cell has actually signed that allows a thai lessor to buy his way out of a lease???

no.

please do a search on this forum and get some understanding of the subject before you start offering advice to others.

thank you for answering the question you asked me, such a lease does exsist, why else would i give the information,

A question for you, if the goverment changes the rule on farang company land ownership, do you believe that the leases will be worth the paper they are written on, If the goverment no longer wishes us to live there, it wont matter how it is arranged.

and my advice to you is get some understanding of the subject before you start offering advice to others, many farangs are getting ripped in thailand, this type of advice does not help...

Thai solicitors even working for a farang have the interest of the thai people first.

What would happen if the Thai landlord moved you out of the house and sold it. It is there house, the lease is not on the land title, what could you do, take them to court? get the police? come on, giving anythink to a Thai in anyway and you have lost it, you may get use of it, but only until they change there mind...

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What would happen if the Thai landlord moved you out of the house and sold it. It is there house, the lease is not on the land title, what could you do, take them to court? get the police? come on, giving anythink to a Thai in anyway and you have lost it, you may get use of it, but only until they change there mind...

Putting your irratinal fears of Thai's aside you are very poorly informed on this subject to a level where you are embarrasing yourself.

Please get yourself a copy of the Thai Civil and Commercial Code and pay partiular attention to sections 538 to 540.

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I would have thought that Sections 564 and 569 of the CCC applied more to the scenario.

Section 564

A contract of hire is extinguished at the end of the agreed perios without notice

Section 569

A contract of hire of immovable property [land] is not extingusihed by the transfer of ownership of the property hired.

The transferee is entitled to the rights and is subject to the duties of the transferor towards the hirer.

So, a contract of hire of land (lease), provided it is lawfully made under the provisions of the CCC quoted above, is enforceable until such time as it is extingusihed, regardless of whether or not the land in question is sold in the interim period, as the new owner of land would be obligated to honor the lease contract.

In the West, I understand this concept is known as a "sitting tennant".

Edited by Sumitr Man
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I have owned my own house via the company route for several years.

The authorities are more suspiscious now and you will need a rental agreement

with your company, for you to live in the house.

This establishes a rental income for the company.

If the company is inactive it will automatically be closed after 2 or 3 years.

Make sure you get a reliable lawyer with a good track record with farangs.

Remember the Golden Rule:

Do not invest more money in Thailand, than you are prepared to walk away from!

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If you go the company route one thing you may not think much to is the VAT man, but he can be as mean a bastard here as he is in the UK.If you don't file they use estimates which can be enormous and give you grief for years to come.

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I would have thought that Sections 564 and 569 of the CCC applied more to the scenario.
Section 564

A contract of hire is extinguished at the end of the agreed perios without notice

Section 569

A contract of hire of immovable property [land] is not extingusihed by the transfer of ownership of the property hired.

The transferee is entitled to the rights and is subject to the duties of the transferor towards the hirer.

So, a contract of hire of land (lease), provided it is lawfully made under the provisions of the CCC quoted above, is enforceable until such time as it is extingusihed, regardless of whether or not the land in question is sold in the interim period, as the new owner of land would be obligated to honor the lease contract.

In the West, I understand this concept is known as a "sitting tennant".

Sitting tenant, in thailand and you are a farang. So when the Thai family turn up and move in you really belive that you will be able to call the sitting tennant card, no way. If the family turn up and tell you to leave, they own the land and the building, you say no, get the police then what, wait to have hands tied behind back and bag over head and the police say it is the worse case of suicide ever, come on this is thailand not america, thailand is still the wild west.

Sitting tenant my a**.

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I would have thought that Sections 564 and 569 of the CCC applied more to the scenario.
Section 564

A contract of hire is extinguished at the end of the agreed perios without notice

Section 569

A contract of hire of immovable property [land] is not extingusihed by the transfer of ownership of the property hired.

The transferee is entitled to the rights and is subject to the duties of the transferor towards the hirer.

So, a contract of hire of land (lease), provided it is lawfully made under the provisions of the CCC quoted above, is enforceable until such time as it is extingusihed, regardless of whether or not the land in question is sold in the interim period, as the new owner of land would be obligated to honor the lease contract.

In the West, I understand this concept is known as a "sitting tennant".

Sitting tenant, in thailand and you are a farang. So when the Thai family turn up and move in you really belive that you will be able to call the sitting tennant card, no way. If the family turn up and tell you to leave, they own the land and the building, you say no, get the police then what, wait to have hands tied behind back and bag over head and the police say it is the worse case of suicide ever, come on this is thailand not america, thailand is still the wild west.

Sitting tenant my a**.

Intimidation can happen in all Countries, no more so than in The States. You seem to have the impression, from anecdotal experience presumably, that all Thai families are involved in some mafia type organization. Whilst the truth is that the vast majority are law abiding, except when it comes to gambling :o

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Well said sir , so I guess it comes down to trust of my girlfriend really , whether or not I put a property in her name and get her to give me a 30 year lease . But this effectively means that I can rent out that property for 30 years , and sell the property should I choose ?

Intimidation ? LOL Growing up in Northern Ireland taught me a lot about intimidation , a few bent Thai cops and the likes will not be intimidating me .....And corruption ? LOL again . The UK is one of the most corrupt countries in the world ...How did they get away with bombing Iraq for example ? Anyway , different subject ....Cheers

I would have thought that Sections 564 and 569 of the CCC applied more to the scenario.
Section 564

A contract of hire is extinguished at the end of the agreed perios without notice

Section 569

A contract of hire of immovable property [land] is not extingusihed by the transfer of ownership of the property hired.

The transferee is entitled to the rights and is subject to the duties of the transferor towards the hirer.

So, a contract of hire of land (lease), provided it is lawfully made under the provisions of the CCC quoted above, is enforceable until such time as it is extingusihed, regardless of whether or not the land in question is sold in the interim period, as the new owner of land would be obligated to honor the lease contract.

In the West, I understand this concept is known as a "sitting tennant".

Sitting tenant, in thailand and you are a farang. So when the Thai family turn up and move in you really belive that you will be able to call the sitting tennant card, no way. If the family turn up and tell you to leave, they own the land and the building, you say no, get the police then what, wait to have hands tied behind back and bag over head and the police say it is the worse case of suicide ever, come on this is thailand not america, thailand is still the wild west.

Sitting tenant my a**.

Intimidation can happen in all Countries, no more so than in The States. You seem to have the impression, from anecdotal experience presumably, that all Thai families are involved in some mafia type organization. Whilst the truth is that the vast majority are law abiding, except when it comes to gambling :o

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Well said sir , so I guess it comes down to trust of my girlfriend really , whether or not I put a property in her name and get her to give me a 30 year lease . But this effectively means that I can rent out that property for 30 years , and sell the property should I choose ?

Intimidation ? LOL Growing up in Northern Ireland taught me a lot about intimidation , a few bent Thai cops and the likes will not be intimidating me .....And corruption ? LOL again . The UK is one of the most corrupt countries in the world ...How did they get away with bombing Iraq for example ? Anyway , different subject ....Cheers

I personally have the house in my wife's name as I live in an area where properties are relatively inexpensive. If we split up I will just walk away, she will have the house and the mortgage( subject to Thai divorce laws). You can lease the property from your girlfriend for 30 years and maybe extend it for another 30 years, but you would not be able to sell the property as you are really only renting it.You would probably be able to include a sub-lease clause in the original lease as you are in the driving seat. You can lease the land from her and build your own property which you could in theory sell. But you would be unlikely to find someone wishing to buy a leasehold property.

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But you would be unlikely to find someone wishing to buy a leasehold property.

Is that right Dragon? In the Uk selling Leasehold (with 999 year lease) is just as common as selling Freehold houses. Is it because the max lease you can have is 30 years with an option. Or is that <deleted>?

MrBoJ

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Sadoko, you make a good valid point, you would only put a house-land into your

girlfriends name and lease it back if you trust her, and are prepared totally to lose all

the money.

Intimidation ? LOL growing up on the south side of the border of Ireland taught me a

lot about intimidation, but nothing compared to what these smilely face people can

do, they have much less to lose than the people Shankle Road in the 70’s.

One guy from England last year thought he could stand up to the intimidation, He

owned the Skydivers bar on soi 6. Anyway he was found in a river floating with

bullets in the back of his head. He then had some of his lets say business partners

from the UK fly into Pattaya to collect the money invested and products. These

business partners are quiet respected among certain narcotic rings within the UK.

When they arrived, they where asked to leave by a Thai man holding a machine. I am

led to believe they where back at the airport heading for Heathrow on the same day.

Intimidation Thai style. It dosent cost much to pay for a man with a gun to pull the

trigger.

And to answer your question, ...How did they get away with bombing Iraq for

example ? We didn’t we are losing solders every day. Europe is being bombed by the

month and it hasn’t finished yet. We are paying deeply with our own blood.... And the

loss of our human right liberties......Anyway , different subject

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i would like to tell yous lads a little story that i know as fact , a friend of mine bought a house in Khon kaen in a small village , he bought it in his girl friends name and took out a 30 year lease with the option of another 30 years , after a bout 6 months he realised his thai girl friend was fleeceing him for everything he got so he forked her out of the house , then one night comming back to his 30 year lease house he was meet by a mob of smiling thais who set about him and stoned him to the floor on awakening in the hospital some weeks later he was told by the police in Khon kaen never to come back , or else there was nothing they could do to protect him , so i hope this will give you some idea of your 30 year lease its worth fork all , so the way i see it if you own a house in a company name adleast you can sell it with out ever having to go back , and the Chineese are always willing to by land in Thailand and dont have the same problems as a westener , but if you are going to buy land in your thai wifes name say for 3 million baht just give her 1.5 million and go back to a bar and get a cheaper women

and before anyone starts running me down , this is just my oppinion

if you dont like it fork off regards Poppa

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i...... then one night comming back to his 30 year lease house he was meet by a mob of smiling thais who set about him and stoned him to the floor on awakening in the hospital some weeks later he was told by the police in Khon kaen never to come back , or else there was nothing they could do to protect him , so i hope this will give you some idea of your 30 year lease its worth fork all , so the way i see it if you own a house in a company name adleast you can sell it with out ever having to go back .......

So please explain how, if this property had been in a company name, it would have been different!

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Because you can give it to a Thai estate agent to sell it, and you have less chance of this happening becasue the Thai dosent believe they own it.

well done rocky 10 out of 10 , what happens is they auction the land off and from what i have been told the Chinese buy every bit of land that comes up , you dont get a fraction of what you paid but atleast you dont have to walk away and let the bastards get away with it . have a nice day Poppa

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Because you can give it to a Thai estate agent to sell it, and you have less chance of this happening becasue the Thai dosent believe they own it.

If you have a lease, you can sell the lease, surely?

If a lease is drawn up properly, it will include an option for the leaseholder to purchase the freehold for a nominal sum. So if the lease is purchased by a Thai, he /she would legally be able to aquire the freehold.

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But you would be unlikely to find someone wishing to buy a leasehold property.

Is that right Dragon? In the Uk selling Leasehold (with 999 year lease) is just as common as selling Freehold houses. Is it because the max lease you can have is 30 years with an option. Or is that <deleted>?

MrBoJ

Mainly due to 30 years really being too short a time to give any significant value to the lease, other than you being able to live there for nominal rent. It is not an ideal option, and is only an attempt to give the farang a bit more protection. Would anyone really want to live on their ex wife's land for up to 30 years, I don't know. It also depends on what clauses you have included in the lease re. rent reviews, etc. How much the lease is worth depends a lot on clauses within.

Also in the Uk, subject to provisions, you can buy the freehold under the Leasehold Reform Act, whilst you cannot in Thailand.

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Also in the Uk, subject to provisions, you can buy the freehold under the Leasehold Reform Act, whilst you cannot in Thailand.

As long as the lease is worded accordingly, the lease could be sold to a thai and then the thai would then have the option to purchase the freehold for a nominal sum.

Is this not true?

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Because you can give it to a Thai estate agent to sell it, and you have less chance of this happening becasue the Thai dosent believe they own it.

If you have a lease, you can sell the lease, surely?

If a lease is drawn up properly, it will include an option for the leaseholder to purchase the freehold for a nominal sum. So if the lease is purchased by a Thai, he /she would legally be able to aquire the freehold.

In theory yes. However options do not have the legal status of a formal lease. I never same across an option I could not have nullified when I worked in property law in Uk. Thailand probably even easier.

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Hi.

I'm new to this forum, but have about 24 years experience in and out of Thailand and years of business experience, including international investment expertise. On the subject of a foreigner owing land for investment purposes in Thailand, I just spoke with a Thai attorney in Chiang Mai on the subject. Basically, after her counsel, the best strategy (for guys like me) is to rent in Thailand, investing your money in real estate in your country.

If you are from the US, for example, in certain markets real estate jumps in price every year (so it seems!). You are much better off purchasing property in the US, renting out the property, and living in Thailand on the equity as your property in the US rises in value.

Having said that, real estate is market driven. In Thailand, foreigners are disadvantaged in the Thai market place (the laws are written to make it so), and supply greatly out numbers demand. Hence, for most purposes, you are better to keep your investments in your mother country and rent in Thailand.

This strategy was confirmed by my very capable Thai attorney who represents many farangs in Chiang Mai. Most have very sad stories about their investment experience(s) in Thailand, as you, as a foreiger, are significantly disadvanged in the marketplace in Thailand. Invest where you are not a disadvanaged farang and be happy!

The best overall strategy is to keep as little as your money in Thailand as possible, or, as someone said, only money you are willing to walk away from.

If you wish to retire in Thailand, and want to own vis-a-vis rent, that is another story, but even in this case, renting with your retirement money invested in your home country is a safer, less risky strategy. If, on the other hand, you simply want to buy a condo, go ahead, but make sure you have your financial goals outlined before jumping in, and consult a Thai attorney with your goals in mind.

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In theory yes. However options do not have the legal status of a formal lease. I never same across an option I could not have nullified when I worked in property law in Uk. Thailand probably even easier.

Yes, I can quite see that this is possible.

I have recently had problems in Uk due to a badly written document ( written by a lawyer, who was paid for his incompetence)

That cost me £27,000 in all.

I no longer trust the legal system in Uk and certainly would not put too much faith in it in Thailand.

I can imagine it quite possible that a clever lawyer could get around a farang's bogus company property ownership as well. Has this ever been tried?

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If you wish to retire in Thailand, and want to own vis-a-vis rent, that is another story, but even in this case, renting with your retirement money invested in your home country is a safer, less risky strategy. If, on the other hand, you simply want to buy a condo, go ahead, but make sure you have your financial goals outlined before jumping in, and consult a Thai attorney with your goals in mind

I agree,

One thing though. If someone is doing the calculations as to whether or not he/she can retire on the rental income.

Do remember that if the Baht strengthens, you will effectively be getting a cut in income.

I did my calculations working on 50 Baht to the Uk pound, so as it is around 72, I have a fair margin.

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