Two Buyers, Two Answers

A $300,000 apartment usually doesn't need a company. A $2 million one almost always does. The line isn't about wealth — it's about where the setup cost of a structure stops being noise next to the succession or privacy problem it actually solves.

That's the whole question underneath "should I buy this personally or through an entity," and most of what follows is just working out which side of that line a given property sits on.

The Basic Trade-Off

Personal ownership is simple, cheap and direct: sale proceeds come to you, and tax follows the ordinary personal rules of both the property's jurisdiction and your own residence. A structure (a company, foundation or trust holding the property) buys flexibility, privacy and cleaner succession, sometimes a tax advantage, always higher setup cost and an ongoing compliance burden.

Personal ownership tends to win on a property under roughly $500,000, where a structure's setup cost usually exceeds any benefit it delivers; on a primary residence, where personal ownership typically still qualifies for local primary-residence exemptions that corporate ownership loses; on a single property with a single owner and a straightforward exit within five to ten years; and where the estate is simple — one spouse, one set of children, same jurisdiction throughout.

Structure tends to win over roughly $1–2 million, where the setup cost is easily justified; across multiple properties, where one structure consolidates what would otherwise be several separate holdings; across multi-generational succession, where foundations and trusts hold cleanly across generations in a way personal ownership doesn't; in forced-heirship jurisdictions, where a structure can route around rules that would otherwise override a will; for non-resident owners renting the property out, where corporate ownership sometimes optimises rental tax; for unrelated co-owners, where a structure gives cleaner governance than joint personal title; and where beneficial-ownership privacy matters, though CRS and beneficial-ownership registers have eaten into how much privacy a structure still buys.

Where the Line Actually Moves, Country by Country

• Spain
  Forced heirship?: No
  Structure typically helps?: Sometimes — affects wealth-tax base, region-dependent
  The trap to know about: Wealth tax varies by autonomous region; structuring must be region-specific

• France
  Forced heirship?: Yes
  Structure typically helps?: Rarely on tax
  The trap to know about: IFI (real estate wealth tax) generally still applies through a structure; forced heirship also applies regardless

• Italy
  Forced heirship?: No
  Structure typically helps?: Case-by-case

• Portugal
  Forced heirship?: No
  Structure typically helps?: Sometimes
  The trap to know about: Corporate ownership through a Portuguese entity is possible but adds compliance for modest benefit on smaller properties

• United Kingdom
  Forced heirship?: No
  Structure typically helps?: Rarely, for residential
  The trap to know about: Since 2013 reforms, most corporate-owned residential property faces ATED and higher CGT — corporate ownership is largely inefficient here now

• United States
  Forced heirship?: No (but estate tax exposure)
  Structure typically helps?: Usually, for non-US owners
  The trap to know about: Non-US persons get only a $60,000 estate-tax exemption on US-situs assets — punitively low without a structure; FIRPTA reporting applies on sale

• Canada
  Forced heirship?: No
  Structure typically helps?: Sometimes
  The trap to know about: Underused-housing tax and various new foreign-buyer taxes can apply to non-resident structural ownership

• Australia
  Forced heirship?: No
  Structure typically helps?: Rarely
  The trap to know about: Foreign Investment Review Board rules restrict foreign structural ownership

• Colombia
  Forced heirship?: Yes
  Structure typically helps?: Sometimes
  The trap to know about: Personal ownership is straightforward; structuring through a Colombian SAS is possible but regime cambiario compliance is essential

• Panama
  Forced heirship?: No
  Structure typically helps?: Commonly
  The trap to know about: Foreign personal ownership is fine; structure through a Panama corporation is the common choice for privacy and succession

• UAE
  Forced heirship?: No
  Structure typically helps?: Rarely needed
  The trap to know about: Freehold ownership for foreigners in designated areas; personal ownership is standard

• Cyprus, Malta
  Forced heirship?: No (EU rules)
  Structure typically helps?: Sometimes
  The trap to know about: EU regimes plus jurisdiction-specific structural options worth checking case by case

• Singapore, Hong Kong
  Forced heirship?: No
  Structure typically helps?: Rarely
  The trap to know about: Foreign-buyer stamp duties (ABSD in Singapore, BSD in Hong Kong) apply regardless of ownership form

The One Genuine Nationality Exception

Most of the "which country are you from" advice in this space collapses to "personal is usually simpler, structure adds complexity" regardless of passport — including for US persons buying abroad, where a foreign structure typically adds CFC, PFIC and potentially GILTI complexity on top of an already complicated filing picture, so personal ownership is usually the cleaner route.

The one place nationality genuinely flips the answer is the reverse case: a non-US person buying US property. There, structure isn't a nice-to-have, it's close to essential, because the $60,000 US estate-tax exemption for non-US persons turns an unstructured US property purchase into a real estate-tax exposure that a Panama Foundation, offshore company or similar structure is specifically built to avoid.

What a Structure Actually Costs

A basic Panama Foundation plus a property-holding company runs roughly $3,000–5,000 to set up, then $1,000–1,500 a year. A Cook Islands Trust runs $10,000–20,000 to set up, then $5,000–10,000 a year. A Cayman or BVI structure runs $2,000–5,000 to set up, then $2,000–5,000 a year per entity. Singapore holding structures cost substantially more on both counts. At $2 million or more in property value, or across a multi-property portfolio, that cost is usually worth paying. Below it, it's a genuinely marginal call.

The Decision

• Single property under ~$500,000, straightforward exit expected
  Choose: Personal

• It will be your primary residence in that country
  Choose: Personal

• Simple estate — one spouse, one set of children, same country
  Choose: Personal

• Property in France, Colombia or another forced-heirship jurisdiction, and you want your will to control who inherits
  Choose: Structure

• $1–2 million or more in property value
  Choose: Structure

• Multiple properties across jurisdictions
  Choose: Structure

• You are a non-US person buying US property
  Choose: Structure — close to essential

• You are a US person buying property abroad
  Choose: Personal, almost always

• Multiple unrelated co-owners
  Choose: Structure

Talk Through Your Property, Not the General Case

Book a scoping call with the actual property and country already in mind — the personal-vs-structure answer for a $300,000 flat in Lisbon and a $2 million compound in Panama isn't the same answer wearing different numbers, it's a different answer.

This article is general information, not legal, tax or property advice specific to your situation — forced-heirship and estate-tax rules in particular are jurisdiction-specific enough that they need checking against your actual facts before you buy.