In the jungle of “sun + yield” destinations, three names consistently appear on the radar of French-speaking investors: Bali, Phuket, and Hoi An. Same region of the world, same postcard-perfect climate, same promise of rental income… but in 2026, these three markets have little in common once you look at property rights, taxation, net returns, and risk levels.
Good to know:
Investing in Indonesia, Thailand, or Vietnam is no longer interchangeable. Each country now imposes more rules, more control, realistic yields, and growing performance gaps. For a 2026-2030 horizon, prioritize capital protection and sustainable cash flow.
In this article, we compare Bali, Phuket, and Hoi An on the criteria that truly matter in 2026: legal structure, net yield, market dynamics, regulatory constraints, and risk profile. With a nuanced answer at the end: each destination suits a specific type of investor.
Three Markets, Three Investment Logics
Before diving into the numbers, we need to set the stage: Bali, Phuket, and Hoi An don’t play the same role in a portfolio at all.
Bali has gone from the post-Covid “Wild West” to a market in controlled correction. The island remains ultra-desirable, but the explosion in villa supply, the enforcement of new rules against “gray” structures, and stricter controls on tourist rentals now require a near-hotel-level of professionalism. Bali in 2026 is a growth and risk market.
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Yields in Phuket, though more modest, are actually achieved within a clear legal framework and massive tourist demand.
Finally, Hoi An is a niche, highly regulated market, at the heart of Vietnam’s growth trajectory. It doesn’t offer the liquidity or tourist intensity of Phuket or Bali, but rather an interesting risk/return profile for those playing the long game on a very heritage-oriented asset, in a country where real estate is still seen as a store of value.
Property Rights: What You’re Actually Buying
The first filter in 2026 is not yield, but title deed. Bali, Phuket, and Hoi An differ very clearly here.
Phuket: Freehold on Condos, a Decisive Advantage
In Thailand, a foreigner can own a condo unit in freehold for life, as long as it remains within the 49% foreign quota for the project and funds are transferred in foreign currency. For villas and land, we’re still looking at long-term leases 30+30+30 years, but within a proven contractual framework.
For an apartment:
| Destination | Typical Property Right (Apartment) | Duration | Remarks |
|---|---|---|---|
| Phuket | Freehold | Unlimited | Max 49% of project for foreigners |
| Bali | Leasehold | 25–30 years | Contractual renewal, not guaranteed by law |
| Hoi An | Limited use right | 50 years renewable | Foreign quota limits per building |
This “lifetime” Freehold on Phuket condos changes everything for the long-term investor. It facilitates refinancing, reassures heirs, and makes resale to an international buyer much smoother. In a world where cycles are shortening, an asset that is legally simple to understand has its own value.
Bali: The Kingdom of Regulated Leasehold… and the End of the Gray Zone
In Indonesia, a foreigner cannot hold Hak Milik (freehold land ownership). In Bali, the vast majority of stock available to foreigners is therefore Leasehold 25 to 30 years, sometimes with renewal options, and/or via a foreign investment company (PT PMA) holding rights like Hak Guna Bangunan or Hak Pakai.
To define
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– 83% of supply is Leasehold.
– 87% of stock consists of villas (versus 13% apartments, rapidly increasing).
– 68% of properties are already built, 32% off-plan.
For years, many foreigners tried to circumvent these limits with “nominee” arrangements. That’s over. Provincial Regulation No. 4 of 2026 doesn’t create a new prohibition – these schemes were already void under Indonesian land law – but now adds a criminal component targeting the buyer, nominee, and intermediary. In other words, the “little legal shortcut” can now end in criminal litigation.
At the same time, Jakarta and Bali province have switched to a fully digital system (OSS-RBA), with:
Attention:
Setting up a PT PMA in Indonesia requires a minimum paid-up capital of IDR 2.5 billion, a total investment plan of at least IDR 10 billion per business code (including land and buildings for real estate), a capital lock-up for 12 months, and a restriction of KBLI to low or medium-low risk for PT PMAs domiciled in Bali.
The message is clear: Bali remains open to investors, but only through clean, sufficiently capitalized structures that are perfectly aligned with zoning.
Hoi An: A UNESCO Market Under High Scrutiny
In Vietnam, all land belongs to the state. Individuals – Vietnamese or foreign – receive limited-term use rights, typically 50 years for a foreigner, renewable once, for a possible total of 100 years, subject to continuing to reside or operate in the country.
In Hoi An, the UNESCO layer further complicates the picture:
– Zone I, i.e., the core of the classified old town, is off-limits to foreign acquisition;
– in other districts, Vietnamese law imposes standard caps:
– Maximum 30% foreign units in a building,
– Maximum 250 houses per administrative ward for foreigners.
Additionally, each project must have an approved 1/500 plan and certification of no conflict with national defense zones before titles are issued. In practice, the Hoi An market is heavily filtered, with few assets accessible to non-residents, but within a clear legal framework.
Returns: Gross Looks Good, Net Decides
Once this legal foundation is established, we can compare the numbers. And the most important nuance is the difference between advertised gross yield and realizable net yield, after tax, expenses, and vacancy.
Comparative Table of Yields and Prices
| Key Indicator (2026) | Bali | Phuket | Hoi An (Vietnam) |
|---|---|---|---|
| Average price per sqm (overall range) | USD 2,200 – 4,800 | USD 2,800 – 4,500 | VND 20–30 million/sqm (approx. USD 800–1,200/sqm) |
| Min budget studio / 1 bedroom | USD 90,000 – 150,000 (Canggu/Uluwatu) | USD 80,000 – 120,000 | Highly variable, much lower |
| Typical gross yield | 12–18% (villas) | 9–14% (condos/hotels) | 4–6% (Vietnam big cities); Hoi An: fragmented data |
| Realistic net yield | 5–8% | 7–10% | 3–5% in practice (urban Vietnam) |
| Annual appreciation potential 2026–27 | 5–10% (Canggu/Uluwatu) | 10–15% | >15%/year on premium national coastline, including Hoi An |
| Capital gains tax | 20% in Bali (Leasehold exit) | 0% (1% withholding) | Vietnamese regime, entry and exit taxes |
| Foreign rental tax | 10% PB1 + brackets up to 20% | 15% withholding for non-residents | 10% rental income tax + various fees |
The paradox is immediately apparent: Bali shows the highest gross numbers, but once taxes (10% PB1 on rents, 20% on Leasehold exit, high operating expenses) are included, reality is more like 5–8% net.
Phuket, on the other hand, advertises lower on paper – often 7–10% net – but these yields prove stable and predictable, with a lighter tax environment (0% capital gains tax, 1% withholding on cadastral value at resale, about 15% withholding tax on rents for non-residents, plus modest local expenses).
Example:
In major Vietnamese metropolises, gross yields are around 3.5 to 6%, while net yields often drop to between 2.5 and 3.5% after taxes, management fees, and condominium charges. In Hoi An, a beach tourism market, yields are slightly higher but still below those of Bali or Phuket.
Bali: Yields That Depend on Fine Management
Local studies mention for Bali: the richness of its culture, its unique traditions, and the impact of tourism on its environment.
– Gross yields of 12–18% on well-managed villas,
– Realistic net yields of 7–12% in the best locations (Canggu/Berawa, Uluwatu/Bingin, Pandawa/Sawangan),
– Exceptional cases with 15–20% annual ROI in micro-markets like Seseh–Cemagi, combining 6.6–11.5% net rental and 8–12% appreciation.
But these high figures depend on strict conditions:
– Ultra-targeted location,
– Impeccable permits and titles (clear KKPR zoning, valid PBG and SLF),
– Differentiating, eco-conscious design,
– Professional “hospitality-oriented” management (not just concierge service),
– Integrated model (villas in a serviced resort rather than isolated villa amid rice paddies).
In practice, many “self-managed” Airbnb owners are struggling:
Tip:
Beware of PCR yields advertised at 12–15%: in reality, after deducting platform fees, staff, maintenance, and taxes, they often fall to 6–8% net, in a context of fierce hotel competition and occupancy rate declines of up to –30% for some villas in late 2025.
Phuket: Less Sexy on Paper, More Solid in the Numbers
Aggregated data for Phuket in 2026 is surprisingly consistent:
– Average gross yield per Knight Frank: 8.7% on rentals,
– Typical net yield on well-managed condos and villas: 7–10%,
– Occupancy rates between 70 and 90% depending on area and property type,
– Annual appreciation in best micro-markets: 7–10%,
– Overall ROI combining rents and capital gains: 19–28% per year on the best recorded deals.
During high season (7 to 8 months, from November to April plus a summer peak), beachfront condos or those near tourist hubs show:
– Bang Tao / Laguna: 7–9.5% gross, 85–92% occupancy,
– Surin: 7–9% gross, 82–90% occupancy,
– Patong: 8–11% gross, 85–93% occupancy.
The low season obviously impacts flows, but the depth of demand (Russian, European, Chinese, Middle Eastern tourists, plus long-term residents via LTR and Elite visas) gives a much more stable cash-flow curve than in Bali.
Hoi An: A Decent Yield in a Wealth Management Logic
Micro-data on Hoi An is more scattered, but some benchmarks emerge:
Key Airbnb Figures in Hoi An
Median annual revenue is around USD 7,000, with an occupancy rate of 32–34% and an average daily rate of USD 70–75. The top 10% of properties generate about USD 2,600 per month with 78% occupancy.
Median Annual Revenue
Median annual revenue for an Airbnb in Hoi An is around USD 7,000.
Median Occupancy Rate
Median occupancy rate is between 32 and 34%.
Average Daily Rate
Average daily rate (ADR) is approximately USD 70 to 75.
Top 10% Performance
The top 10% of properties achieve around USD 2,600 per month with 78% occupancy.
Meanwhile, the Vietnamese residential market as a whole shows:
– Compressed gross yields in big cities: 3.5–4.5% in Ho Chi Minh City, 4–5% in Hanoi, 4.5–6% in Da Nang,
– Net yields after taxes and expenses reduced to 2.5–3.5%.
Hoi An performs slightly better thanks to tourism, but without spectacularly exceeding this range on average. However, appreciation potential is real:
– National tourist coastal areas are expected to see >15% annual increase in 2025–2026,
– The Hoi An – Cu Lao Cham coastline benefits from the highest land price revisions in Quang Nam province.
So the logic is more “I’m betting on the upscaling of the Vietnamese coast and the growth of tourism” rather than massive rental cash flow.
Market Dynamics: Where Is the Cycle?
At equivalent gross yield, the timing of the cycle often makes the difference. An overheating market doesn’t offer the same risk/return ratio as a disciplined recovery market.
Bali: From Post-Covid Rush to Normalization
After 2020–2023, when villa prices in Canggu and Uluwatu surged 60–80% (up to +47% for some areas between 2019 and 2023), Bali enters a correction/consolidation phase:
– New launches dropped from a peak of 244,000 sqm in 2024 to around 160,000 sqm in 2025, a sign of cooling on the developer side,
– Total sales value nevertheless increased by 10% thanks to the rise of smaller units (1–2 bedrooms, <USD 250,000),
– International arrivals recovered and then exceeded pre-Covid levels (over 6.3 million visitors in 2024, over 7 million combined air/sea arrivals in 2025),
– Overall revenue nonetheless fell by 15% despite a slight increase in occupancy (+2%), under pressure from hotels and increased coordination of players on OTA platforms.
At the same time, the market is structuring:
– Rise of a “legality premium”: villas with zoning, permits (PBG/SLF), and tax compliance sell and rent for significantly more,
– Stricter controls: immigration, licenses, zoning, compliance of Airbnb listings (NIB mandatory since March 2026, otherwise delisting),
– End of the “build anywhere and it rents out” era: the oversupply of generic 4–6-bedroom villas has shown its limits.
2026 forecasts are sober: +5 to +10% annual price growth in established areas (Canggu, Seminyak, Uluwatu), with more potential in emerging belts west of Canggu, to the east and north. This is clearly a mature, data-driven market where asset selection makes the difference between double-digit returns and disappointment.
Analysis of the Balinese real estate market
Phuket: End of the Rebound, Start of the Maturity Phase
Phuket, for its part, has already digested its post-pandemic catch-up phase. In 2025–2026:
– Project volumes were voluntarily moderate (around THB 81–82 billion in 2025),
– The market is described as in a “disciplined, capital-selective” cycle,
– Prices rose 35–45% between 2023 and 2025, and are expected to increase another 10–15% in 2026–2027 in key areas (Bang Tao, Layan, Kamala, etc.),
– Demand is driven not only by tourism (14.2 million visitors in 2025, with a trajectory towards 12 million for Phuket alone soon) but also by long-term residents: expat families, high-income teleworkers, retirees.
By comparison, Bali saw more violent increases (60–80% over three years in some neighborhoods), and the probability of a correction is explicitly mentioned for 2026–2027 (expected increase of 5–10%, but with risk of decline) in overheated areas like Canggu/Uluwatu.
Hoi An and Vietnam: A National Normalization Cycle
Vietnam is also entering a phase of stabilization after several years of rapid rises:
Good to know:
Nationally, prices have soared and yields have compressed while speculation has cooled. For 2026, analysts predict more selective growth, without major widespread increases. Construction, land, and financing costs remain high, limiting sharp corrections but favoring an upscaling trend. Furthermore, revised land and housing laws, effective in 2025‑2026, enhance transparency and reduce room for purely speculative projects.
For Hoi An in particular, signals are:
– a significant increase in land values in tourist coastal areas,
– an increased role for the city in projections for FDI targeting the coastline (Halong–Hanoi–HCMV–Danang–Hoi An–Sa Pa),
– limited supply, especially in sectors accessible to foreigners and outside the UNESCO zone.
In summary, Vietnam is not in a Bali-Canggu type of overheating, but rather in structured consolidation, with an emphasis on legally impeccable projects oriented towards real demand (tourism, retirement, primary residence).
Regulation, Visas, and Taxation: The True Cost of Ownership
All three countries have one thing in common in 2026: the state has regained control over its real estate markets. But the way they do it, and the consequences for the investor, differ strongly.
Bali: Targeted Tightening, End of Informality
The Balinese turning point unfolds in several acts:
Attention:
Since 2026, Bali has strengthened regulation of foreign-owned companies (PT PMA): minimum capital lowered to IDR 2.5 billion but locked for 12 months, OSS access blocked for low-risk activities in Bali, seasonal rentals via pseudo-consulting companies impossible, and Airbnb, Booking, or Expedia require a valid NIB since March 2026. Additionally, all companies must migrate their KBLI codes by June 2026, particularly for villas, hotels, and glamping, on penalty of non-compliance, and the crackdown on nominee practices is reinforced by provincial regulation with clear criminal risk.
At the same time, Indonesia has launched Golden Visas (5 years for USD 350,000 in bonds, stocks, or funds; 10 years for USD 700,000 or USD 1 million via apartment purchase) and a Second Home Visa (5 years renewable against IDR 2 billion in property or deposit). But these pathways do not change the basic logic: no freehold land for foreigners, and obligation of a clean, well-capitalized structure to commercially operate a property.
Phuket: Lenient Taxation, But Watch Out for Tax Residency
On the Thai side, the structure is more favorable, but it is also becoming more complex on one point: taxation of de facto residents.
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Beyond 180 days per year in Thailand, a person is considered a tax resident and taxable on their worldwide income.
For the investor who does not spend six months a year in Phuket, the total tax burden is often around 1–3% of gross rents, which is very competitive globally. The 2026–2027 unknown lies in ongoing reforms regarding taxation of foreign income for long-term residents, but most buyers of seaside second homes are not affected.
Hoi An: A Country in Full Legal Overhaul
In Vietnam, the trend is towards increased protection of individuals and strengthening safeguards:
Good to know:
Buyer deposits are capped at 70% in an escrow account for the buyer’s benefit. Only approved projects outside defense zones are accessible. Foreigners pay the same property taxes as locals, but must manage currency risks, capital restrictions, and keep proof of funds, local income, and contracts.
On the rental tax side, an Airbnb in Hoi An will be hit by rental income tax (about 10%) and various charges; after management fees and condominium expenses, it often falls back to around 3–5% net, which, compared to yields in Phuket or Bali, reinforces the idea that Hoi An’s main appeal lies in capital appreciation and the wealth management dimension, more than in immediate cash flow.
Investor Profiles: Who Should Go Where in 2026?
At this point, it’s clear that the question “Bali or Phuket or Hoi An?” has no universal answer. It depends on what you are looking to optimize: legal security, income, capital gains, personal use, risk tolerance.
To clarify, we can summarize the winning profiles for each market.
Phuket: For the Investor Who Prioritizes Stability and Protection
Phuket ticks a series of very clear boxes:
– Freehold for life on condos, with a proven condo ownership framework.
– Very liquid market in premium areas (Bang Tao / Laguna, Kamala, Surin, Kata/Karon, Rawai/Nai Harn), driven by global demand.
– Net yields of 7–10% realistic on the best well-managed assets, with projected appreciation of 10–15% for 2026–2027 in good sectors.
– Predictable and moderate taxation, especially for non-residents with limited stay duration.
Phuket is therefore the choice for: its tropical climate, beautiful beaches, and festive atmosphere.
Good to know:
This type of investment suits people seeking stable income rather than exceptional gain, wanting to preserve capital in a tangible asset in a context of strong tourist demand, and favoring a smooth resale exit thanks to an international secondary market.
For a European couple or a CIS investor who wants:
– a proven 7–10% net rather than a theoretical 15%,
– full freehold ownership that can be passed on,
– world-class infrastructure (healthcare, schools, air connectivity),
Bali: For the Offensive, Highly Selective Investor Capable of Managing Complexity
Bali, on the other hand, attracts a different profile:
– an investor willing to accept the legal uncertainty of Leasehold and the complexity of PT PMA,
– ability to finance (or co-finance) a structure with at least USD 150,000 in capital and a heavy investment plan,
– appetite for near-hotel management, with digital marketing, enhanced customer experience, attention to online reviews and reputation.
In exchange for this complexity, Bali can still offer:
8–12%
Net yields on the best-structured Bali projects reach 8 to 12%.
But in 2026, you can no longer come to Bali to “buy by feel”. You must:
– systematically verify land certificates, KKPR zoning, PBG, SLF, access easements, drainage,
– refuse any nominee operation,
– consider a 2–4 year horizon for opportunistic operations (buy, upgrade, resell) in a market that is normalizing quickly.
For the investor who loves complex but potentially very rewarding deals, who also wants a lifestyle pied-à-terre on an iconic island, Bali remains a high-risk, high-reward yield laboratory.
Hoi An: For the Patient, Wealth-Oriented, Long-Term Vietnam Investor
Finally, Hoi An suits a third type of profile:
Good to know:
This investment fits investors who believe in the long market cycle (economic growth, FDI, middle class), aim for value preservation and gradual appreciation rather than immediate cash flow, and are ready to manage a tight legal framework: ownership caps, 50-year renewable lease, UNESCO constraints.
Strengths:
– a growing tourist rental market with Airbnbs capable of generating over USD 2,600/month for the best units,
– a national trend of rising prices on tourist coasts (>15% per year expected in certain sub-markets),
– an improving regulatory framework (bank escrow for deposits, clarification of foreign ownership rules).
Limitations:
– net yields that struggle to sustainably exceed 3–5%, in a context of rising costs and regional competition,
– lower liquidity than Phuket or Bali, especially for resale to international buyers.
For an investor already exposed to Thailand or Indonesia, Hoi An can serve as a complementary bet on the rise of the central Vietnamese coast, rather than a cash flow pillar.
How to Decide: A Simple Reading Grid
To conclude, we can simplify the decision into a “priority” matrix. Ask yourself: what do I want to optimize first?
| Priority #1 | Most Consistent Destination in 2026 |
|---|---|
| Legal security & Freehold | Phuket |
| Stable net yield | Phuket |
| High ROI potential (but volatile) | Bali |
| Lifestyle + project creativity | Bali |
| Long-term bet on an emerging country | Hoi An / Vietnam |
| Second home + moderate profitability | Phuket |
| 2–4 year operation with rebranding | Bali |
| UNESCO / heritage positioning | Hoi An |
In practice, many investors end up combining: diversification strategies and investment in long-term assets to maximize returns and reduce risks.
Example:
A safety base in Phuket, via one or two freehold condos in a managed residence, offering 7 to 9% net yield. An opportunistic bet in Bali, with a leasehold villa in an up-and-coming area, aggressively managed for rental and a 3–5 year exit plan.
Hoi An, meanwhile, is more for those who already understand Vietnam, often through Ho Chi Minh City or Hanoi, and wish to diversify into a more tourist-oriented asset while staying within the same national legal framework.
In Conclusion
In 2026, talking about “Bali vs Phuket vs Hoi An” only makes sense if you specify the type of game you want to play.
– Phuket has become the most rational platform for a foreigner seeking Freehold, stable net yield, and a smooth resale in a very clear fiscal, legal, and tourism environment. It is the destination of predictable income and capital preservation.
– Bali remains the emotional star, but now clearly targets sophisticated investors capable of navigating restrictive land law, shifting regulation, and a market entering a normalization phase. You go there for superior performance potential, at the cost of significantly higher risk and structuring effort.
Tip:
Hoi An positions itself as a niche market in Vietnam, offering moderate yields but interesting long-term appreciation potential. Within a rigorous and highly controlled legal framework, this investment fits a wealth management logic of long cycles rather than immediate profitability.
The right decision in 2026 is not whether Bali “beats” Phuket or whether Hoi An will “catch up” to its neighbors. The real question is: what role should each market play in your overall portfolio, given your horizon, risk tolerance, and liquidity needs?
Those who answer this question honestly will, much more than others, have a chance to turn a tropical dream into a truly high-performing real estate strategy.
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