This master's thesis provides a comparative legal analysis of real estate investment in Slovenia and in Dubai. It proceeds from the premise that legal certainty and predictability are among the key criteria when making an investment decision. Following a uniform analytical framework, it examines real estate legislation, the property purchase process, investor protection, financing options, taxation, restrictions on foreign investors, and the returns and market trends in both
jurisdictions. The thesis finds that, despite their different legal traditions, the two systems are structured similarly, as ownership rights in both jurisdictions are acquired only upon
constitutive registration in a central public register, namely the land register (slo. zemljiška knjiga) in Slovenia and the register maintained by the Dubai Land Department. The systems
differ, however, in their institutional implementation. In Slovenia, investor protection is distributed among the land register, property and contract law, and the notarial system, whereas in Dubai it is concentrated within the administrative oversight by the Dubai Land Department and the Real Estate Regulatory Agency. Dubai stands out for its lower tax burden, broader and more innovative financing options, and higher rental yields, while Slovenia is distinguished by its well-established legal tradition and more stable property price growth. The hypothesis that neither system is superior in absolute terms and that the choice depends on the profile and
objectives of the individual investor is confirmed.
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