Can two apartments add up to $150,000?
This is one of the questions we are asked most, and the honest answer is that the law and the market say different things. The law describes the property permit in the singular: an alien with the property right to "an immovable thing" whose market value exceeds $150,000. The agency's document list also speaks of "a document of title to an immovable property". Several advisers, on the other hand, write that a portfolio of properties with a combined value above the threshold qualifies. We have not found an official text that allows the values to be added together.
Until our partner lawyer confirms the agency's current practice, this page treats combining as possible but unconfirmed. It sets out what is certain, which situations are clear and which are not, and how to structure a purchase so that the permit does not depend on the open question.
What the texts say
| Source | What it says |
|---|---|
| Law, Article 15(j) | Property right to an immovable thing, other than agricultural land, worth more than $150,000 |
| Agency document list | A document of title to an immovable property, with a value report by an accredited assessor |
| Advisers' guides | A single property, or a portfolio with a total value above the threshold |
| Law, Article 21(13) | Only for the investment permit: the permit survives if the holder shows another property of the same or higher value before the first is sold |
To be added by the team: the partner lawyer to confirm, from recent agency decisions, whether several properties can be combined to pass the $150,000 and $300,000 thresholds, and whether each property needs its own valuation report.
Why the wording matters
The agency decides on the file in front of it, and Article 18(1)(i) allows it to refuse a permit when the requirements of Article 15 are not met. A file that relies on adding two values together relies on a reading the text does not state. If the official dealing with it reads "an immovable thing" literally, the answer is a refusal, a month before a new application and a second fee. That is why the question deserves a firm answer before the purchase, not after the decision. Our page on refusals explains what happens next if it goes wrong.
What is certain either way
- Every property must be in your own name in the public registry; a company's or a relative's property does not count.
- Agricultural land never counts, whatever its value.
- Values come from an accredited assessor, not from the purchase price or an agent's estimate.
- The figure must exceed the threshold; exactly $150,000 is not enough.
- The investment permit is a separate test at more than $300,000.
Common situations
| Situation | Position |
|---|---|
| One apartment valued above $150,000 | Clear: meets the rule |
| Two apartments of $90,000 and $70,000 | Unconfirmed: depends on whether the agency adds values |
| Apartment plus a parking space with its own cadastral code | Unconfirmed: two registered units, so the same question |
| Apartment owned jointly with a spouse | Ask the lawyer: the file must show whose right supports which application |
| A 50% share of an apartment worth $320,000 | Ask the lawyer: how the agency values a share is not set out |
| Apartment plus agricultural land | The land does not count |
Spouses, shares and joint property
Ownership between spouses has its own rules. Under Article 1158 of the Civil Code, property that spouses acquire during their marriage is their joint property unless a marriage contract says otherwise, and this holds even if only one of them earned the money. In the registry, a purchase may therefore appear in one name or in both. For the permit, what matters is that the file shows which person holds the property right that supports the main application; the other spouse then applies as a family member. A purchase in two names, or a share of a property, raises the question of how the agency values each person's part, which is part of what our lawyer is checking.
Three worked examples
- A budget of $200,000. One apartment valued at $175,000 meets the rule on its own and leaves a margin. Two apartments at $100,000 each might produce more rent, but the permit would then depend on the open question.
- An owner who already holds one $90,000 apartment. Adding a second unit of $70,000 reaches the total only if values can be combined. Selling the first and buying one unit above $150,000 avoids that dependency, at the cost of the transaction.
- A couple buying a $320,000 apartment together. One property, one valuation, clearly above the threshold. The file should name the spouse whose right supports the main application, and the other applies as a family member.
How to structure a purchase
Prefer one qualifying property
If the budget allows, a single apartment clearly above $150,000 removes the question entirely.
If you buy two, value both
Order a report from an accredited assessor for each unit, with its own cadastral code, so that the file shows every value separately.
Keep a margin
Do not let the total sit just above the threshold; a cautious report on one unit can bring the sum below it.
Get the lawyer's view before you sign
Especially for shares, joint ownership or a mix of residential and commercial units.
Questions to settle before buying two units
- Is each unit registered separately, with its own cadastral code and extract in your name?
- Is any part of either plot classed as agricultural land?
- Will an accredited assessor value each unit, and by how much does the total clear $150,000?
- If only one unit could ever count, would it pass on its own?
- Who in the family holds the right that supports the main application?
- If you later sell one unit, what will the remaining one be worth?
If the answer to the fourth question is no, the purchase depends entirely on the open point, and the lawyer's view is not optional.
Selling one of several properties
Under Article 21(11), the short-term permit ends when the right of ownership of the property ends, and Article 16(3) spares an owner who still holds the same property the cost of revaluing it at every extension. Neither text deals with an owner whose permit rests on two properties and who sells one of them. If the remaining property is above the threshold on its own, the position is easier to defend; if it is not, the permit may no longer have its ground. Unlike the investment permit, the short-term permit has no rule allowing a replacement property to be substituted before a sale. Our page on selling or a fall in value explains the general sequence.
To be added by the team: the partner lawyer to confirm what happens to a short-term permit based on two properties when one of them is sold.
The same question at $300,000
The investment permit is available to owners of non-agricultural property worth more than $300,000. Investors often reach that figure with two or three apartments, and the same uncertainty applies. The investment permit does have one advantage: Article 21(13) lets the holder keep the permit if, before the right to one property ends, they show a registry extract for another property of the same or higher value. That makes it easier to change properties during the five years than on the short-term permit.
Risks and exceptions
- Relying on advisers' guides alone. The law's wording is singular.
- Including agricultural land. It never counts towards the threshold.
- Thin margins on two reports. One cautious valuation can sink the total.
- Unclear ownership between spouses. The file must show whose right supports the application.
- Selling one unit without a plan. The remaining property may not carry the permit alone.
Frequently asked questions
Can I combine two apartments for the permit?
Advisers say yes, but the law and the agency's list speak of one property. Our lawyer is confirming current practice; until then, treat it as unconfirmed.
Do I need a valuation for each property?
If you rely on more than one, have each unit valued by an accredited assessor so that every value is documented.
Does a parking space count?
If it is a separate unit with its own cadastral code, it raises the same combination question as a second apartment.
Can my spouse and I each own half?
Joint ownership can work, but the file must show clearly whose right supports which application. Ask the lawyer before registering the purchase.
Can an apartment bought before March 2026 count with a new one?
An owner who qualified under the earlier rules keeps renewing on that property. Adding a second property to reach the new figure raises the same combination question.
Is a house and its garden plot one property or two?
It depends on the registry: if the house and the land are one registered unit, they form one property; if they have separate cadastral codes, the combination question applies.
Will the agency tell me in advance?
The agency decides applications, not hypothetical questions. A lawyer who follows its recent decisions is the practical source of an answer before you buy.
What if one of my properties is commercial?
The law excludes only agricultural land, so commercial property is not excluded by the text. Whether it can be combined with residential property is part of the same open question.
What counts as a qualifying property, and how its value is set, is explained in our page on the $150,000 threshold.
Sources
- Law of Georgia on the Legal Status of Aliens and Stateless Persons (Articles 15, 16 and 21), Legislative Herald of Georgia, consolidated 25 June 2026 (accessed 13 October 2026)
- Migration and residence permits: short-term residence permit documents, Public Service Development Agency (accessed 13 October 2026)
- Civil Code of Georgia (Article 1158), Legislative Herald of Georgia (accessed 13 October 2026)
- Residency in Georgia by property investment, ExpatHub (accessed 13 October 2026)
Change log
- - Explainer published from Articles 15(j), 16(3), 21(11) and 21(13) of the Aliens Law, the agency's document list and advisers' guides; combination question with the partner lawyer.