Restrictions on the foreign ownership of property: Indonesia and Singapore compared

Many countries have restrictions on the foreign ownership of property in their territory and there have been attempts to circumvent such restrictions. This article looks into the restrictions and shows how various methods have been used to try to circumvent them. It focuses on the situation in two Asian countries, namely Indonesia and Singapore. These two countries represent two stages of legal development and two of the main families of legal systems, i.e. Indonesia coming from a civil law system and Singapore from a common law one. The article also shows how the differences in laws and treatment of legal issues have resulted in different situations in each country. However, it would seem that despite the differences in the two countries, arrangements to circumvent restrictions on the foreign ownership of property would be considered illegal in both countries and therefore would not be enforced.