'Long Leasehold System' Equivalents Abroad

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    'Long Leasehold System' Equivalents Abroad

    I am interested in the 'Long Leasehold System' equivalents in countries abroad England and Wales. I am aware that the 'Long Leasehold System' is special to England and Wales, and that generally, foreigners are rather surprised when they find themselves unable to purchase a full freehold, but rather a long leasehold. However, as far as the equivalent systems in other countries are concerned, my knowledge is not extensive. Would anyone be able to provide me with details of the 'Long Leasehold' system equivalents within any countries abroad England and Wales (for example, the USA, China, France, Russia, Italy, etc.)? Under what systems does one buy property in countries abroad England and Wales (since the owner of a leasehold is usually unable to alter the exterior of his/her property, one can find many instances of rows of regimented old buildings on the streets of England and Wales, as opposed to irregular rows of new and expanding blocks of flats on streets in many part of the USA, for example - I am interested to discover whether or not the systems of property acquisition would explain the variation in the general appearances of buildings in different countries around the world). Thank you very much in advance for any information on the matter.

    #2
    Google Search the wikipedia website which has information on condominiums .

    http://en.wikipedia.org/wiki/Condominium

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      #3
      Abroad it is "commonhold" so that you automatically have a share in the freehold. A situation that I feel needs to be changed here in the UK. Leasehold is outdated and feudal

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        #4
        Thank you very much for that information. However, could you please be slightly more specific? For example, could you provide me with a list of countries that use the 'condominium' and 'commonhold' property acquisition systems?

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          #5
          In theory we have commonhold already, not that I've ever seen one.

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            #6
            Originally posted by surreygirl View Post
            Abroad it is "commonhold" so that you automatically have a share in the freehold. A situation that I feel needs to be changed here in the UK. Leasehold is outdated and feudal
            Feudal, yes, outdated, probably not.

            While clunky at times, a lot of that comes through the variety and uniqueness of leases. What ever system were to replace it, there still has to be a contractual relationship between the unit owner and the owner of the remainder.

            In many respects my experience of condo in California was that as effective as it is for dealing with problem occupiers, it can be very easily criticized by handing too much power to the condo board, who have the power to vote you out and sell the unit under you. Just as it does here, it works best with honest hard working individuals and sensible occupiers.

            For a different look at Australian strata title see here;
            http://www.27bslash6.com/strata.html

            It is not new to the web but still makes me cry with laughter.
            Based on the information posted, I offer my thoughts.Any action you then take is your liability. While commending individual effort, there is no substitute for a thorough review of documents and facts by paid for professional advisers.

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              #7
              Commonhold property title for flats is common in Spain & Germany ( and probably in most parts of Europe ).

              Copied from Wikipedia (Re - Strata Title ) :
              Other countries that have adopted the Australian system (or a similar variant) of apartment ownership include
              • Canada (British Columbia)
              • Singapore
              • South Africa
              • Indonesia
              • Malaysia
              • Fiji
              • The Philippines[1]
              • India
              • Dubai
              • Abu Dhabi (under draft as at 2010)
              Other countries have legislation based on similar principles but with different definitions and using different mechanisms in their administration.
              Strata Title Schemes are composed of individual lots and common property. Lots are either apartments, garages or storerooms and each is shown on the title as being owned by a Lot Owner. Common Property is defined as everything else on the parcel of land that is not comprised in a Lot, such as common stairwells, driveways, roofs, gardens and so on.

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