Georgia or Bali: property title, tax and residence compared

What separates Georgia and Bali, row by row?

The deepest gap is title, not price. In Georgia a foreigner owns a flat outright, in their own name in the Public Registry. In Bali the same buyer can hold only a time-limited right or a lease, because Indonesian freehold is reserved for citizens. The other rows follow from that; the choice stays yours.

What does a foreign buyer actually hold in each place?

Indonesia's Agrarian Law (Law 5/1960) lets only citizens hold Hak Milik, full and lasting ownership of land (Article 21(1)). A foreigner may hold Hak Pakai, a right of use for a fixed term, and Hak Sewa, a lease of land for building (Articles 42 and 45). The right to build, Hak Guna Bangunan, is open to an Indonesian company with foreign shareholders but not to a foreign individual.

In Georgia a foreigner buys a flat or house as a citizen does. Only farmland is closed: the Constitution reserves it for the State, municipalities and Georgian citizens (Article 19(4)); see farmland and foreigners. Ownership passes to heirs and appears on a registry extract, explained in our guide on reading a Public Registry extract.

Why is an Indonesian nominee no shortcut?

A nominee holds Hak Milik on paper for a foreigner who pays. Article 26(2) of the Agrarian Law covers any act meant "langsung atau tidak langsung" (directly or indirectly) to pass freehold to a foreigner. Such acts are "batal karena hukum", void by law; the land falls to the State, and payments the owner received cannot be claimed back, as the Ministry of Finance's asset directorate summarises it.

Bali has added Regional Regulation No 4 of 2026, which controls the conversion of productive farmland and prohibits nominee transfers of land ownership, according to RRI and The Jakarta Post. Its text, start date and penalties are not confirmed. In Georgia the foreign buyer is simply the registered owner; see our guide to registering a purchase.

How long does Hak Pakai last, and from what price?

Government Regulation 18/2021 lets a foreigner hold Hak Pakai on state land for up to 30 years, extend it by up to 20 and renew it for up to 30 more, 80 years at most (Article 52(1), as Hukumonline reports it). On land an Indonesian owns as Hak Milik, the term is up to 30 years, renewed by a new deed (Article 52(3)). Further limits, per Hukumonline:

• One plot per person or family, of up to 2,000 m², unless the minister allows more (Ministerial Regulation 18/2021, Article 186).
• A Bali price floor of IDR 5 billion for a landed house, about USD 275,512 or GEL 715,588, and IDR 2 billion for a strata unit, about USD 110,205 (Decree 1241/2022).
• Papers: a passport and a visa or stay permit are enough, a ministry official told detikFinance in May 2023.

The official texts did not open on 3 November 2026, so these figures rest on Hukumonline; older, lower figures still circulate on agency sites.

What does a leasehold villa give the buyer, and what not?

For a foreign villa buyer in Bali, the usual route is a lease. Article 44 of the Agrarian Law lets the holder build on someone else's land for rent, and Article 45 opens the right to "orang asing yang berkedudukan di Indonesia", a foreigner domiciled in Indonesia. The law sets no term; the parties agree it. Indonesian legal writers warn that a lease without a real end, or one that hands the foreigner an owner's control, may be voided as a disguised transfer, and that many leases are never recorded at the land office. That is commentary, not statute.

By our reading, the buyer gets a contract right, not a title. Its value runs down to nil at expiry unless an extension is honoured, and it is not confirmed to open a stay permit. A Georgian flat has no such clock.

Is a foreign-owned company a way round?

A PT PMA, an Indonesian company with foreign shareholders, can hold the right to build and the licences that letting needs. Under BKPM Regulation 5/2025 of October 2025, it must plan more than IDR 10 billion of investment per business line at each project location, excluding land and buildings, and have at least IDR 2.5 billion paid up, according to A&O Shearman and Withers: about USD 551,025 and USD 137,756. Add quarterly reporting, and it is an operating business, not a second-home wrapper. In Georgia a company is optional; see residence through a business.

What do buying and holding add to a USD 250,000 price?

USD 250,000 is IDR 4,537,000,000 or GEL 649,325 at the 3 November 2026 rates. In Bali it falls short of the Hak Pakai house floor but clears the strata-unit floor.

BPHTB is up to 5% of the price or official value, if higher; the seller owes a 2.5% final tax (PwC). VAT is 12% on 11/12 of the price, so 11%. For 2026, PMK 90/2025 has the state bear (BCA Sekuritas) the VAT on the first IDR 2 billion of a home priced up to IDR 5 billion; whether foreigners qualify is not confirmed, so the table ignores it. The PPAT, the land deed official, charges at most 0.25% above IDR 2.5 billion (Ministerial Regulation 33/2021). Georgia's notary line applies Resolution No 507: GEL 1,162.50 plus 0.1% above GEL 500,000; see buying costs in Georgia.

A lease is a notarial deed with no fixed tariff we could find. The landowner's 10% final tax on rent would be USD 25,000 here (our reading); who bears it, and whether BPHTB applies, is for an Indonesian notary. Each year, Indonesia's PBB is at most 0.5% of the government sale value, at a rate each regency sets; Badung's is not confirmed. Georgia's Law No 1874 taxes an individual's buildings only where the owner's family earned more than GEL 100,000 in the previous year.

Which property, if any, opens a residence permit?

Indonesia's Directorate General of Immigration lists two ways to qualify for the second-home visa without a sponsor: IDR 2 billion in funds, about USD 110,205 on 3 November 2026, or proof of owning property in Indonesia, a "sertifikat kepemilikan properti". ASEAN Briefing gives a stay of 5 or 10 years, with the deposit kept in an Indonesian bank.

By our reading, a certificate fits a Hak Pakai house or unit, which in Bali already costs IDR 5 billion or IDR 2 billion at least. Whether a villa lease counts we could not confirm, nor any change to the IDR 2 billion rule since 2022. The golden visa of July 2024 rests on financial assets: USD 350,000 in bonds, listed shares or deposits for 5 years, or USD 700,000 for 10, for an investor without a company (The Jakarta Post).

Georgia grants residence on the home itself: an accredited valuation above USD 150,000 supports a renewable 1-year permit, and above USD 300,000 a 5-year investment permit; the USD 250,000 example reaches the first. See residence by property, the investment permit and the country comparison tool.

Can the home take holiday guests, and under what licence?

On 27 February 2026 Indonesia's Tourism Minister said accommodation on booking platforms must be licensed by 31 March, Reuters reported. TTG Asia reported on 3 June 2026 that about 1,600 operators were selling without licences, that delisting could begin from 1 August 2026, and that automatic delisting through nine platforms is planned from 1 June 2027.

Consultants' guides say the homestay licence, Pondok Wisata, is reserved for Indonesians and small local firms, so a foreigner lets legally through a licensed operator or a PT PMA, on land zoned for tourism. Guests also pay a regional accommodation tax of up to 10%, set by each regency under the 2022 regional tax law. Bali also charges each foreign visitor IDR 150,000, about USD 8.27 (ANTARA); we found no tourist tax in Georgia.

There is no island-wide ban on new villas. What matters is the ban on villas, hotels and restaurants on productive farmland, announced after the September 2025 floods; Regional Regulation 4/2026 curbs farmland conversion, but its text is unseen. Six regencies (Tabanan, Jembrana, Buleleng, Bangli, Karangasem and Klungkung) also pledged in July 2025 not to push new hotels and restaurants from 2026, for 10% of hotel and restaurant tax from Denpasar, Badung and Gianyar (ANTARA): a pledge, not a law.

Batumi needs no accommodation licence, only tax registration; see Airbnb in Batumi and Airbnb in Tbilisi.

How is rental income taxed in each country?

Indonesia taxes a resident's rent from land or buildings at 10% final on the gross (PwC, citing Government Regulation 34/2017). Payments to non-residents bear 20% withholding unless a treaty and a certified certificate of domicile lower it; PwC does not name rent under that article, so applying the 20% to a foreign landlord is our reading. Indonesia is not among Georgia's 58 tax treaties in force (Ministry of Finance).

Georgia charges 5% on gross residential rent; see rental income tax in Georgia. Nightly lets may instead pay a fixed GEL 10 per m² a month for chosen months, until 1 January 2028. On USD 10,000 of yearly rent, an illustration rather than a forecast, the bill is USD 1,000 for a Bali resident, USD 2,000 for a non-resident and USD 500 on a long-term Georgian let (our calculation).

What do the official numbers say about each market?

Statistics Indonesia's Bali office counted 6,948,754 direct foreign arrivals in 2025, up 9.72% (ANTARA). January to July 2026 brought 3,900,965, down 1.98% on a year earlier. Bank Indonesia's new-house survey puts Denpasar at 106.04 in the second quarter of 2026 (2018 = 100), up 1.02% in a year against 0.69% nationally; it tracks city houses bought mostly by Indonesians, and no official index for Bali villas exists.

Developers market villa yields of as much as 17%, The Jakarta Post reported in June 2026: a sales claim, not a measured return. Colliers Indonesia's research head said such double-digit figures often reflect best-case scenarios. No official villa yield exists. On the Georgian side, Batumi turnkey prices gained 9.8% to June 2026 and Galt & Taggart's gross yields are 8.7% for Tbilisi (August 2026) and 7.1% for Batumi (June 2026); see our price index, rent index and Batumi market review.

Which priorities point to which place?

More comparisons outside Europe: Georgia or Thailand and Georgia or Dubai; for a European coast, Georgia or Montenegro.

Risks and exceptions

• Paying through a nominee. Article 26(2) voids the deal; the land goes to the State and the money stays with the owner.
• Calling a lease ownership. A leasehold villa is a contract that ends.
• Expecting a visa from a villa. A lease is not confirmed to count for the second-home visa.
• Using an old floor or rate. Bali's minimums are IDR 5 billion and IDR 2 billion; convert on the day.
• Letting without a licence. Unlicensed listings can be removed from 1 August 2026.
• Reading an advert as a forecast. A 17% yield is a developer's sales claim, not a measured one.

Frequently asked questions

Can a foreigner own land in Bali?

Not as freehold. A foreigner can hold Hak Pakai on state land for up to 80 years in stages, or lease land from an Indonesian owner.

What is the minimum price for a foreigner in Bali?

IDR 5 billion for a landed house and IDR 2 billion for a strata unit, about USD 275,512 and USD 110,205 on 3 November 2026.

Does a Bali villa bring a residence visa?

Not confirmed. The second-home visa needs an IDR 2 billion deposit or certified property; a lease is not confirmed to count.

Has Bali banned new villas?

Not island-wide. Bali has moved to bar them from productive farmland, and six regencies pledged not to push new hotels from 2026.

Sources

1. Foreigners' land ownership, Ministry of Finance (DJKN), 18 January 2023, and Law 5/1960, Article 26, Pasal.id (accessed 3 November 2026)
2. Hukumonline: minimum prices, 8 February 2023; land rights, 30 March 2021; lease rights, 4 July 2019; deed fees, 7 May 2025 (accessed 3 November 2026)
3. Foreigners' homes, detikFinance, 16 May 2023 (accessed 3 November 2026)
4. Regional Regulation 4/2026, RRI Denpasar, 6 March 2026 (accessed 3 November 2026)
5. The Jakarta Post: farmland ban, 17 September 2025; developers' yields, via The Star, 7 June 2026; golden visa, 26 July 2024 (accessed 3 November 2026)
6. PwC tax summaries, Indonesia: other taxes, income, withholding, reviewed 11 June 2026 (accessed 3 November 2026)
7. PMK 90/2025, BCA Sekuritas, 6 January 2026; accommodation tax, Pajak.com (accessed 3 November 2026)
8. BKPM Regulation 5/2025, A&O Shearman, 27 October 2025; foreign capital rules, Withers, 10 October 2025 (accessed 3 November 2026)
9. Second-home visa, Directorate General of Immigration, 28 December 2022, updated 17 January 2024; requirements, ASEAN Briefing, 13 February 2023 (accessed 3 November 2026)
10. Rental rules, Reuters via The Star, 28 February 2026; unlicensed listings, TTG Asia, 3 June 2026 (accessed 3 November 2026)
11. ANTARA: six regencies, 28 July 2025; tourist levy, 3 January 2026; arrivals 2025, 2 February 2026; arrivals 2026, 1 September 2026 (accessed 3 November 2026)
12. Bank Indonesia: Residential Property Price Survey, Q2 2026, August 2026; JISDOR (accessed 3 November 2026)
13. Galt & Taggart: Tbilisi, August 2026; Batumi, 2Q26 (accessed 2 November 2026)
14. Legislative Herald of Georgia: Constitution, Law on Aliens, Tax Code, Resolution No 507; fees, Public Registry; rates, National Bank of Georgia; double tax treaties, Ministry of Finance of Georgia (accessed 3 November 2026)

Change log

• 3 November 2026 - Comparison published from Indonesian land and tax rules as reported by Hukumonline and PwC, Bank Indonesia and BPS Bali data, and Georgian law and market data.