In 1453 a twenty-one-year-old sultan took Constantinople and found he'd conquered a ruin. Plague and siege and two centuries of decline had emptied the place long before he arrived, and its walls enclosed fields. Sultan Mehmed II wanted an imperial capital. What he held was a half-abandoned town, so he set about filling it.
He brought people in from across his territories. Some came willingly, drawn by tax exemptions and property. Others were moved under orders, and a number of those were deportees who held the status of prisoners of war and weren't free to leave. They were Muslims, Christians and Jews. In January 1454 he installed Gennadios Scholarios as Orthodox patriarch, and he let the Genoese merchants of Galata carry on trading.
This wasn't religious equality and nobody should present it as such. Non-Muslims held a subordinate legal position, paid a tax Muslims didn't pay, and lived under an authority that could move them at will. The conquest itself gave the army three days of plunder. Mehmed wasn't a pluralist. He was a ruler who needed an economy.
What the policy shows is narrower than tolerance, and more useful. Mehmed didn't think everyone who built his capital had to share his religion, and he didn't think letting them build it put his empire at risk. He was right. The city stayed under Muslim rule for another four hundred and seventy years, until Turkey became a republic in 1923. It's still a predominantly Muslim country, and the mosques his successors built still stand over Istanbul.
On its own that proves very little. A sultan who could relocate a household by decree tells us almost nothing about a modern state with a land registry and an immigration service. Better evidence exists, because several countries have run the experiment inside the last twenty-five years and the paperwork is public.
Dubai decided where, and never whether
In May 2002 Dubai opened freehold ownership to non-Gulf foreigners in specific designated areas. The statutory basis followed four years later in Law No. 7 of 2006, and a separate order published that July listed the areas themselves. The list has been rewritten since. A 2021 decision added plots on Sheikh Zayed Road and Al Jaddaf.
The design is more interesting than the headline. Foreign ownership was never a yes-or-no question there. It was a question of where, answered by an instrument the ruler can rewrite at will. Outside the designated areas the law doesn't merely discourage a sale: article 26 makes a disposition in breach of its provisions absolutely null and void. And the whole arrangement runs through a register the state keeps itself.
Dubai has been selling on those terms for more than twenty years, extending the list of areas as it went. It's still part of the United Arab Emirates, and Sharia still governs the family affairs of Muslims there. One thing did change, and it's worth saying plainly. Since February 2023 non-Muslims in the Emirates have had their own civil regime for marriage, divorce and inheritance, with equal shares for men and women. Opening the property market didn't cost the country its legal identity. It added a second track beside it, and anybody weighing the same bargain should know that in advance.
Johor found out that a deed isn't a visa
In August 2018 the Prime Minister of Malaysia said two things in one breath about Forest City, a new town then going up in Johor largely for foreign buyers. He said the city couldn't be sold to foreigners. Then he said this: "We are not going to give visas for people to come and live here."
Neither half survived the week. His own housing minister said the matter was undecided, and the Johor state government, which holds a stake of about a third in the project, called the edicts unlawful. What the Prime Minister eventually settled on is the part worth keeping: buying property there would not entitle anybody to Malaysian citizenship, and it would not get anybody an entry visa on the strength of ownership alone.
That clarification is the distinction the whole argument turns on, and it came from a head of government. Buying a building and acquiring the right to live in a country are two transactions with two different counterparties. The deed comes from a developer. The visa comes from a state, which can decline to issue it, and no apartment has ever come with one attached.
The episode still cost something. A Forest City executive said in 2019 that international investors had taken a wait-and-see approach, though Malay Mail reported the same year that sales hadn't been badly hurt and that buyers came from more than thirty countries. By September 2021 the developer had cut its Malaysian staff to a third of the 2019 level, with Chinese capital controls and the pandemic also working on it.
Nobody in Johor woke up in a different country. What Malaysia got was an argument conducted in public, a developer that slowed, and a settled principle about what a purchase confers. The fear had the risk the wrong way round.
Turkey shows that the dangerous link is one a parliament writes
Turkey is the case where buying property really does lead to a passport. It built a citizenship-by-investment route with a property threshold of US$250,000, and in May 2022 it published an amendment in the Official Gazette raising that to US$400,000 from the following month, with a short grace window for applications already filed.
The whole lesson sits in that one instrument. Property converts into political membership only where a legislature has decided it should, and the conversion rate is a dial the state holds and turns. A title deed has no power of its own to make anybody a citizen of anywhere.
Singapore shows the price can double overnight
On 27 April 2023 Singapore's additional buyer's stamp duty on foreign purchasers went from 30 per cent to 60 per cent, announced the previous day by two ministries and the monetary authority together. Companies and trusts went to 65, housing developers excepted. Ministers put the foreign share of private home sales that quarter at about 7 per cent, up from the three or four of recent years.
Singapore sells to almost anyone. It also showed it could reprice foreign demand between a Wednesday and a Thursday, using a tax rate rather than a prohibition.
What the four have in common
Not one of them lost anything at the title deed. What each kept was the power to change the terms afterwards. Dubai redrew a map, Turkey raised a price, Singapore doubled a tax, and Malaysia, after a fortnight of contradicting itself, established what a purchase does and doesn't confer.
So the familiar fears don't survive contact with the evidence. Buyers become citizens only where a law says they may. Owners acquire a right of residence only where an immigration service grants one. And a country's religious character doesn't follow its investors, which four hundred and seventy years of Ottoman Istanbul says plainly enough.
What ought to worry a country is duller. It's also much harder to chant.
A rule written against a travel document rather than against a person is narrower than it looks, because dual nationality is ordinary and a second passport isn't the first one. Dubai's safeguard isn't a slogan. It's a register plus a provision voiding anything done outside it, which is duller than a ban and far more effective.
The rest is about whether a state can still move after it has signed. Turkey and Singapore could change their terms because the terms sat in instruments they owned. Malaysia's announcement collapsed in days because its own state government read the law differently, which is what happens when terms get declared before they're settled. And a term nobody outside the room has read can't be assessed by anybody outside the room, including the people assuring you it's adequate.
None of that is a question about who prays where. Every bit of it is answerable from a document, which is precisely why the documents should be published.
Mehmed needed merchants and didn't much care which God they prayed to. His empire outlasted the arrangement by four and a half centuries, because what governed that city was never the religion of the people trading in it. It was the authority that wrote the rules, and kept the power to rewrite them.
A deed is the least dangerous piece of paper in a transaction like this. The dangerous one is the agreement, and the agreement is the one that tends not to get published.
Sources
Law No. 7 of 2006 on Real Estate Registration in the Emirate of Dubai, article 26
Order No. 3 of 2006 designating areas for foreign ownership, Government of Dubai
Decision No. 6 of 2021 amending the designated areas, Government of Dubai
Dubai Land Department
Law update on real estate ownership rights in Dubai, Al Tamimi and Company
Federal Decree-Law No. 41 of 2022 on Personal Status for Non-Muslims, United Arab Emirates
Press remarks of the Prime Minister of Malaysia, August 2018, and his subsequent clarification
Reports of September 2019 and September 2021, Malay Mail
Report on the Malaysian housing minister’s response, South China Morning Post
Regulation amending the Regulation on the Implementation of the Turkish Citizenship Law, Official Gazette, 13 May 2022
Joint announcement on Additional Buyer’s Stamp Duty rates, 26 April 2023, Ministry of Finance, Ministry of National Development and Monetary Authority of Singapore
The Policy of Mehmed II toward the Greek Population of Istanbul and the Byzantine Buildings of the City, Dumbarton Oaks Papers 23/24, Halil İnalcık
The Ottoman Empire: The Classical Age 1300 to 1600, Halil İnalcık