Abstract:
Land is a strategic resource closely linked to state sovereignty, public welfare,
and economic stability. In the context of globalization and increasing foreign
investment, Southeast Asian countries face the challenge of opening their
property markets without undermining national interests. This study aims to
analyze restrictions on foreign land ownership under Indonesian and Thai law
and to compare the legal approaches of both countries. This research applies a
normative legal method using statutory and comparative approaches. The
findings indicate that Indonesia allows limited foreign access through use rights
and condominium ownership, whereas Thailand maintains a stricter prohibition
on direct land ownership by foreigners, allowing only narrow exceptions. Both
countries seek to protect national land sovereignty but differ in their level of
openness to foreign property investment.
