The International Real Estate Glossary: 80+ Terms Every Cross-Border Buyer Must Know

Published on: June 20, 2026

Buying property in your own country is mostly a question of money and taste. Buying it abroad is a question of vocabulary. The same transaction, find a home, agree a price, sign, pay, register ownership, runs through a different legal language in every country, and the words are not interchangeable. An escritura is not a contrato de arras. A compromis de vente is not an acte de vente. A fideicomiso is not the same as owning land outright, even though the brochure may not say so.

This glossary collects the terms a cross-border buyer actually runs into, grouped by where you will meet them. Definitions are written to be accurate and stable; where a tax or rate varies by region or year, we say so rather than printing a number that will be wrong by the time you read it. Use it as a reference while you read contracts, talk to agents and lawyers, and compare countries. Every term here connects to a wider topic, title verification, taxes, contracts, ownership structures, that we cover in depth elsewhere on JanusHermes.

A note on method: this is reference material, not advice. Legal terms have precise meanings in their home jurisdiction, and a single word can carry different consequences in different countries (a "notary" in France is a powerful public official; a "notary public" in the United States mostly witnesses signatures). When a term matters to your transaction, confirm how it applies to your property with a local lawyer who represents you, not the seller.

Universal concepts you will meet in almost every country

Title deed. The legal document that proves who owns a property. The form and name change by country (escritura, acte de vente, rogito, tapu), but the function is the same: it is the instrument that transfers ownership and, once registered, your evidence of it.

Land registry. The official public record of who owns what and which debts, mortgages or restrictions attach to a property. Registration, not signature, is usually what makes your ownership enforceable against the world. Country-specific registries below include the Spanish Registro de la Propiedad, French and Italian cadastre/catasto, German Grundbuch and Turkish TAKBIS.

Cadastre. A parallel public record describing the physical property, boundaries, surface area, and an official "cadastral value" used for tax. The cadastre answers what and where; the land registry answers who owns it and what is owed. The two do not always agree, which is something to check.

Notary (civil-law notary). In most of continental Europe and Latin America, a state-appointed legal official who authenticates the sale, verifies identities and title, calculates and often collects taxes, and lodges the deed for registration. The notary is neutral, they do not represent the buyer or the seller, which is exactly why you may still want your own lawyer.

Escrow. A neutral third party (a lawyer, notary, title company or licensed escrow agent) holds the buyer's money and releases it only when agreed conditions are met. Escrow protects both sides and is one of the single most important defences against fraud. Not every country uses formal escrow; where it does not, money often passes through the notary's or lawyer's regulated client account instead.

Conveyancing. The legal process of transferring property from seller to buyer: checks, contracts, completion and registration. In some countries a lawyer does this; in England it is done by a "conveyancer" or solicitor.

Due diligence. The investigation you (or your lawyer) carry out before committing: confirming the seller owns the property, that it is free of debts and planning problems, that it was built legally, and that what is on the ground matches what is on paper.

Encumbrance. Any claim, debt or restriction attached to a property that "travels" with it, a mortgage, a lien, an easement, an unpaid tax. In most civil-law systems, debts can follow the property to the new owner, so an encumbrance check is non-negotiable.

Lien, charge or mortgage (hipoteca). A creditor's secured claim over the property. If a prior mortgage is not cleared at completion, you can inherit it. Always confirm the property transfers free of charges unless you have agreed otherwise.

Freehold. Outright, indefinite ownership of the property and (usually) the land it sits on. The strongest form of ownership in common-law countries.

Leasehold. The right to use a property for a fixed number of years under a lease, after which it reverts to the freeholder. Common in England, Thailand (for foreigners), and parts of the Gulf. A short remaining lease can sharply reduce value and mortgageability.

Usufruct. The right to use a property and enjoy its income for life or a term, while legal ownership ("bare ownership," nuda propiedad) sits with someone else. Used in inheritance and tax planning across France, Spain and Italy.

Power of attorney (POA). A signed, usually notarised authorisation letting someone act for you, for example, to sign a deed while you are abroad. A specific, limited POA (this property, these acts) is far safer than a general one.

Reservation agreement or holding deposit. An early agreement, with a small deposit, that takes a property off the market while contracts are prepared. Read the refund terms carefully: some deposits are forfeited if you withdraw.

Preliminary contract. The binding (or partly binding) contract signed before final completion, fixing price and terms and usually accompanied by a substantial deposit (often around 10%). Named differently everywhere: contrato de arras, compromis de vente, compromesso/preliminare, CPCV. This is the document that legally commits you, not the brochure, and often not the final deed.

Completion or closing. The final step where the balance is paid, the deed is signed and ownership passes. Also called escritura, acte de vente, rogito or "completion."

Stamp duty or transfer tax. A government tax on the transfer of property, charged as a percentage of price or value. Rates vary widely by country and region and are one of the biggest hidden costs of buying abroad, budget for total purchase costs, not just the headline price.

Capital gains tax (CGT). Tax on the profit when you sell. For non-residents, many countries also apply a withholding tax: the buyer or notary retains a percentage of the sale price and pays it to the tax authority on the seller's behalf, as a guarantee against unpaid CGT.

Off-plan. Buying a property before it is built, from drawings and a show unit, usually paid in instalments tied to construction stages. Higher potential upside, higher risk: developer insolvency, delays, and a finished product that differs from the render.

Snagging or defects list. The inspection of a newly built property to list faults the developer must fix before you accept it. In some countries (for example Spain, France) new builds also carry a statutory warranty against structural defects.

Title insurance. A policy (common in the US, available in some other markets) that protects you against losses from defects in the title that surface after purchase. Where it is available for cross-border purchases, it can be worth the premium.

Sworn or certified translator. A translator officially authorised to produce legally valid translations of contracts and deeds. Many countries require a sworn translation (or an official interpreter at signing) when a foreign buyer does not speak the language. See our guide to foreign-language contracts.

Apostille. A standardised certificate (under the 1961 Hague Convention) that authenticates a public document, a power of attorney, a birth certificate, for use in another member country, without further legalisation.

Tax identification number (for foreigners). Almost every country requires a buyer to obtain a local tax or identity number before purchasing: Spain's NIE, Italy's codice fiscale, Portugal's NIF. Without it, you usually cannot sign, pay tax or register ownership.

Golden Visa or residence-by-investment. A programme granting residence rights in exchange for a qualifying property purchase or investment. Terms change frequently and several European programmes have been tightened or closed, verify the current rules before buying for a visa. See our Golden Visa comparisons.

Restricted zone. An area where foreign ownership is limited or prohibited, often near borders or coastlines (Mexico's zona restringida) or in designated security or military areas (Turkey, Greece's border regions). Buyers usually need a special structure or government clearance.

Nominee structure. An arrangement where a local person or company holds title "on behalf of" a foreign buyer to get around ownership restrictions. In several countries (notably Indonesia/Bali and Thailand) nominee ownership is illegal or unenforceable and a frequent route to losing your money. Treat with extreme caution.

Survey or valuation. A professional assessment of a property's condition (survey) and market value (valuation or appraisal). Banks require a valuation before lending; a survey is for you, to find problems before you buy.

Spain

NIE (Numero de Identidad de Extranjero). The foreigner's identification number in Spain, required for almost any significant transaction including buying property, opening a bank account and paying tax. You will need it before you can complete a purchase.

NIF (Numero de Identificacion Fiscal). The tax identification number. For Spanish individuals it is based on their ID; for foreigners the NIE generally serves as the NIF for tax purposes; companies have their own NIF.

Escritura (publica de compraventa). The public deed of sale, signed before a Spanish notary. Signing the escritura is the moment ownership transfers; it is then lodged at the Land Registry.

Nota simple. An inexpensive official extract from the Land Registry (Registro de la Propiedad) showing the current owner, the property's description, and any mortgages, charges or restrictions. Pull a fresh one before you commit, it is the quickest way to confirm the seller really owns the property and what is owed on it.

Contrato de arras. The private preliminary deposit contract in Spain, typically with a deposit around 10%. It binds buyer and seller to complete on agreed terms.

Arras penitenciales. The most common type of arras: it lets either party pull out, but at a price. If the buyer withdraws, they lose the deposit; if the seller withdraws, they must return double. Check which type of arras your contract uses, because the consequences differ.

ITP (Impuesto de Transmisiones Patrimoniales). The property transfer tax on resale (second-hand) homes, set by each autonomous community, so the rate varies by region. New-build purchases pay VAT (IVA) plus stamp duty (AJD) instead of ITP.

Plusvalia municipal. A municipal tax on the increase in the value of the urban land (not the building) since the previous sale. Historically paid by the seller, though it can be negotiated.

IBI (Impuesto sobre Bienes Inmuebles). The annual local property tax, the Spanish equivalent of council or property tax. Confirm it is paid up to date, as arrears can attach to the property.

Comunidad de propietarios. The homeowners' association for an apartment block or development, funded by community fees. Ask for the minutes and the fee balance: unpaid community debts and looming special levies are common surprises.

Cedula de habitabilidad or licencia de primera ocupacion. The certificate of habitability or first-occupation licence confirming a property is legally fit to live in. Important for resale and for connecting utilities, especially in rural or recently built homes.

Catastro. Spain's cadastre: the physical and fiscal register of properties, source of the cadastral value used to calculate several taxes. The Catastro and the Land Registry are separate systems and should match.

Gestor or gestoria. An administrative agent or firm that handles Spanish bureaucracy (tax filings, registrations, NIE applications) on your behalf. Useful, but not a substitute for an independent lawyer.

France

Notaire. The French notary: a public official, mandatory in every property sale, who drafts the deed, runs legal checks, collects taxes and registers the transfer. One notary can act for both parties, but the buyer can appoint their own at no extra total cost.

Compromis de vente. The most common preliminary sale contract in France. It binds both parties, fixes the price and conditions (conditions suspensives, such as obtaining a mortgage), and is usually accompanied by a deposit of around 10%.

Promesse de vente (unilaterale). An alternative preliminary contract in which the seller commits to sell and the buyer holds an option to buy within a set period, against a deposit. Slightly different mechanics from the compromis.

Acte authentique or acte de vente. The final deed of sale, signed before the notaire, at which the balance is paid and ownership transfers.

Frais de notaire. "Notary fees," which mostly are not the notary's fee at all but the transfer taxes and registration costs the notary collects on the state's behalf, a significant percentage of the price on older properties, lower on new builds. Budget for them up front.

Delai de retractation. A statutory cooling-off period (ten days) after a private buyer signs the preliminary contract, during which they can withdraw without penalty and recover the deposit.

Diagnostics (DDT, Dossier de Diagnostic Technique). A bundle of mandatory technical reports the seller must provide (energy performance, asbestos, lead, termites, electrical and gas safety, natural-risk exposure). Read them; they reveal real costs and hazards.

Cadastre. The French land cadastre recording parcels and boundaries.

SCI (Societe Civile Immobiliere). A French civil property-holding company often used to buy and hold real estate, particularly by couples, families or several investors, for succession and management reasons. Worth discussing with a French notaire or tax adviser.

Taxe fonciere and taxe d'habitation. The two French local property taxes: taxe fonciere is paid by the owner annually; taxe d'habitation (now largely abolished on main homes) can still apply to second homes.

Italy

Codice fiscale. The Italian tax code, a personal alphanumeric identifier required to buy property, open a bank account or sign utility contracts. Foreign buyers obtain one before completing.

Proposta d'acquisto. A written purchase offer. Once the seller accepts and the deposit is handed over, it can already become legally binding, so understand its effect before you sign.

Compromesso or contratto preliminare. The preliminary contract of sale, committing both parties to complete on agreed terms, usually with a deposit (caparra). Registering it gives the buyer extra protection.

Caparra confirmatoria. The confirmatory deposit under the preliminary contract: if the buyer defaults they lose it; if the seller defaults they owe double. (Note the parallel with Spain's arras penitenciales.)

Rogito (notarile). The final notarial deed of sale, signed before an Italian notaio, completing the transfer.

Catasto. Italy's land cadastre, recording properties and cadastral values (which, for some taxes, are used instead of market price).

Visura catastale. A cadastral search or extract describing the property and its registered data; the visura ipotecaria searches for mortgages and charges. Both are standard due-diligence checks.

IMU (Imposta Municipale Unica). Italy's municipal property tax, generally not charged on a main residence but due on second homes, relevant for most foreign buyers.

Agente immobiliare and REA number. A licensed Italian estate agent must be registered with the local Chamber of Commerce and carry a REA (Repertorio Economico Amministrativo) registration number, plus indemnity insurance. Verify it before you engage one, see our guide to checking an agent is licensed.

Germany and Austria

Grundbuch. The German land register, a meticulously maintained public record of ownership and charges. Entry in the Grundbuch is what legally makes you the owner; until then, you are not.

Notarvertrag. The notarised purchase contract. In Germany a property sale is only valid if signed before a notary, who reads the contract aloud and registers the transfer.

Grunderwerbsteuer. The real-estate transfer tax, set by each German federal state, so the rate varies by region.

Makler and Maklerprovision. The estate agent and the agent's commission. Rules on who pays the commission have changed in recent years; confirm the split before you offer.

Portugal

NIF (Numero de Identificacao Fiscal). Portugal's tax identification number, required before buying property, opening a bank account or signing contracts. Non-residents from outside the EU usually also need a fiscal representative.

CPCV (Contrato Promessa de Compra e Venda). The promissory purchase-and-sale contract: the binding preliminary agreement, with a deposit (sinal). If the buyer defaults they typically lose the deposit; if the seller defaults they may owe double.

Escritura publica de compra e venda. The public deed of sale, signed before a notary or at a Casa Pronta one-stop office, completing the transfer.

IMT (Imposto Municipal sobre as Transmissoes Onerosas de Imoveis). The property transfer tax, charged on a sliding scale; there is also stamp duty (Imposto do Selo) and an annual municipal property tax (IMI).

AMI licence and IMPIC. Portuguese estate agencies must hold an active AMI licence issued by IMPIC (the public institute regulating real estate), displayed on their materials and verifiable on the IMPIC website. A licensed agency also carries mandatory liability insurance.

Caderneta predial. The tax or cadastral record of a property held by the tax authority, showing its registered description and fiscal value; cross-check it against the Land Registry certificate (certidao permanente).

Turkey

Tapu. The Turkish title deed, issued and transferred at the Land Registry Directorate (Tapu Mudurlugu). Ownership transfers when the new tapu is issued in your name, not when you sign a sales contract or pay a deposit.

TAKBIS. The national land-registry and cadastre information system underpinning the tapu records, used to verify ownership and check for encumbrances.

DASK (Dogal Afet Sigortasi). Compulsory earthquake insurance, required to register a tapu and to connect utilities. Given Turkey's seismic risk, it is both a legal requirement and a sensible one.

Iskan (yapi kullanma izin belgesi). The occupancy or habitation permit confirming a building was completed in line with its licence and is legally fit for use. Buying without it is a known risk, especially on older or unfinished buildings.

Military clearance and reciprocity. Foreign purchases in Turkey are checked to confirm the property does not fall within a military or special security zone, and foreign ownership is subject to nationality-based reciprocity rules and per-person area limits. Your conveyancing should confirm eligibility before money moves.

Mexico

Fideicomiso. A Mexican bank trust through which foreigners legally hold residential property inside the restricted zone. The buyer is the beneficiary with full rights to use, sell, lease and bequeath the property; a Mexican bank holds bare title as trustee. It is a recognised, secure structure, but it is a trust, not direct freehold, and it carries setup and annual fees.

Restricted zone (zona restringida). The strip within roughly 100 km of Mexico's land borders and 50 km of its coastlines, where foreigners cannot hold direct title to residential land and must use a fideicomiso (or, for non-residential property, a Mexican corporation).

Ejido land. Communally owned agricultural land. Ejido parcels are a frequent trap for foreign buyers because they often cannot be sold to outsiders or transferred with clean title unless formally "regularised." Verify the land is fully titled private property before you go near it.

Notario publico (Mexico). A highly qualified, government-appointed notary (very different from a US notary public) who formalises the deed, verifies title and taxes, and registers the transfer. Their involvement is mandatory and central to a safe purchase.

United Kingdom

Stamp Duty Land Tax (SDLT). The property purchase tax in England and Northern Ireland (Scotland and Wales have their own equivalents). Foreign and additional-property buyers generally pay surcharges on top of the standard rates.

Exchange of contracts. The point in an English purchase at which signed contracts are swapped and the deal becomes legally binding; the deposit is paid and neither side can walk away without penalty. "Completion" follows later.

Conveyancer or solicitor. The qualified professional who handles the legal side of an English property purchase (searches, contracts, registration with HM Land Registry).

Gazumping. When a seller accepts a higher offer from another buyer after already accepting yours, before contracts are exchanged. Legal in England because nothing binds until exchange, a nasty surprise for international buyers used to binding offers.

Gazundering. The reverse: a buyer lowers their offer at the last minute, just before exchange, gambling that the seller is too committed to refuse.

How to use this glossary

Three habits turn this vocabulary into protection rather than trivia:

First, never sign a document whose name you do not recognise on this list without knowing what it commits you to. In most civil-law countries, the preliminary contract, not the final deed, is the document that legally binds you, and the deposit is at stake from that moment.

Second, match the words to the registry. Whatever the title deed is called in your country, your ownership usually becomes real only when it is entered in the land register. Confirm registration, do not just collect signatures.

Third, get the terms checked by someone on your side. A notary is neutral and an agent works for the seller (and is paid on the sale). When a term carries real money or risk, have your own lawyer confirm how it applies to your specific property.

Frequently asked questions

What is the difference between a preliminary contract and the final deed?
The preliminary contract (arras, compromis, compromesso, CPCV) is signed first and legally commits both parties to complete, usually with a 10% deposit at risk. The final deed (escritura, acte de vente, rogito) is signed later before a notary and is the moment ownership actually transfers and is registered. People are often surprised that they are fully committed at the preliminary stage.

Do I need a tax number before I can buy property abroad?
In most countries, yes. Spain's NIE, Italy's codice fiscale and Portugal's NIF are all prerequisites: you generally cannot sign the deed, pay the taxes or register ownership without one. Apply early, because it can take time.

Is a "notary" the same everywhere?
No. In continental Europe and Latin America the notary is a powerful, neutral legal official who is central to making the sale valid and registering it. In the United States and some other common-law places, a "notary public" mainly witnesses signatures and has no comparable legal role.

Does owning through a fideicomiso or a leasehold mean I do not really own my home?
You hold genuine, transferable rights, the right to live in, rent out, sell and bequeath the property, but they are not the same as outright freehold. A Mexican fideicomiso is a secure trust structure; a Thai or Gulf leasehold is time-limited. Understand exactly what you are getting, and be very wary of informal "nominee" arrangements, which can be unenforceable.

A note from JanusHermes

JanusHermes covers cross-border property across 50+ countries with a single editorial rule: no hype, no half-truths. If a term in your contract is not on this list, or you want to see how the rules differ between two specific countries, explore our country guides and comparisons.

Disclaimer. This article is provided for general information only and does not constitute legal, tax, or immigration advice, nor does it create any professional or advisory relationship. Legal terms, taxes, and procedures change over time and vary by region and jurisdiction, and the details here, believed accurate as of June 2026, move over time. Always confirm how a term applies to your specific property with a licensed lawyer or tax professional who represents you before committing to any purchase. JanusHermes is a property information and listing platform and accepts no liability for any action taken in reliance on this content.

A note on the numbers: where no source is named, the market figures in this article (prices, yields, costs) are indicative estimates compiled from publicly available market data and industry reporting at the time of writing. Markets move and rules change, so treat them as a starting point and verify current figures with official sources before acting on them.