Likupang Invest for Foreign Buyers: Leasehold, PT PMA, and Legal Setup Basics
I use the phrase “Likupang Invest for foreign buyers” a lot when I talk to clients who fly into Manado, drive past the new toll road, and start asking where they can buy beachfront land. The opportunity is real, but the rules are different from Bali or Jakarta, and mistakes in structure can destroy yields or block your exit.
Likupang is part of the official Special Economic Zone program and one of Indonesia’s five super-priority tourism destinations. That combination – KEK Likupang, the Manado–Bitung toll road, the upgraded Sam Ratulangi International Airport, and the push to develop Minahasa Utara tourism – makes the region interesting for resort developers, villa operators, eco-lodges, and land-bankers.
In this guide I walk through the core decisions foreign buyers need to make: leasehold versus freehold, when to use a PT PMA, how to align the legal framework with projected rental yields, and what practical due diligence should look like as we move toward 2026.
1. Likupang Invest for Foreign Buyers: The Core Decision Tree
When I say “Likupang Invest for foreign buyers”, I am really talking about three questions you need to answer before you transfer a single dollar:
- Do you only want economic exposure (rental yield and capital gain), or do you also need operational control to run a business?
- Is your main asset type land, villas, or an operating hospitality project (hotel, resort, dive operation)?
- What is your holding period: under 7 years, 7–15 years, or 15+ years?
Most foreign investors I advise in Likupang, Bunaken, Manado, and Bitung end up in one of these three setups:
- Personal long-lease (Hak Sewa / contractual lease) for lifestyle villas and small portfolios, with a simple rental-management agreement.
- PT PMA company holding a long lease or usage right, with full licenses to develop and operate hospitality assets.
- Hybrid: PT PMA for operations, with land held by an Indonesian partner and secured by long-term contracts and collateral.
Each path has trade-offs around risk, tax, control, and exit. Let’s go step by step.
2. Why Foreigners Rarely Hold “Freehold” in North Sulawesi
One of the biggest misconceptions in Likupang Invest for foreign buyers is the idea that you can simply buy “freehold” (Hak Milik) land in your own name. Under Indonesian law, non-Indonesian individuals cannot hold Hak Milik directly. PT PMA companies also cannot hold Hak Milik; their strongest right is usually Hak Guna Bangunan (HGB – Right to Build) or Hak Pakai (Right to Use).
In North Sulawesi, especially in Minahasa Utara and coastal Likupang, foreign buyers often get offered three things:
- Nominee freehold: an Indonesian individual holds the certificate, with side agreements that “promise” you control.
- Leasehold (Hak Sewa / contract): a 25–30+ year lease registered or at least notarised, giving you economic rights.
- HGB or Hak Pakai via a PT PMA: the company holds a strong, registrable right over the land.
I almost always tell serious investors and hospitality developers to avoid nominee freehold for three reasons:
- Legal risk: nominee structures are explicitly contrary to the spirit of land rules; courts can treat them as void.
- Family risk: heirs of the nominee can object or refuse to honour side agreements.
- Financing and exit: banks and institutional buyers rarely accept nominee land as clean collateral.
That narrows the conversation to leasehold versus PT PMA with HGB/Hak Pakai. For many projects in Likupang, the right answer is a combination: PT PMA holding a long lease from local owners at a commercial rate, with options to extend.
3. Leasehold in Likupang, Manado, and Bunaken: When It Works
Leasehold is the starting point of Likupang Invest for foreign buyers who want to keep things simple or who are just testing the market. You pay a lump-sum or staged lease fee to the landowner, then secure a contract (and ideally register it) granting rights to use and build.
Typical scenarios I see in North Sulawesi:
- Small villa projects (2–6 keys) in Likupang Timur or around coastal Minahasa Utara, with 25–30 year leases and renewal options.
- Dive or eco-lodges on islands near Bunaken, running on 20–25 year leases, sometimes on village land.
- Land-banking near the KEK Likupang SEZ boundary, with 20–30 year leases while waiting for infrastructure and zoning clarity.
Advantages of leasehold:
- Lower upfront cost: you pay for the time value, not the full land value.
- Speed: a well-drafted lease contract is often faster to execute than setting up a full PT PMA in the first phase.
- Flexibility: easier for lifestyle-focused investors who want usage and some rental income without running a full business.
Limitations you must account for in your ROI model:
- Finite horizon: if your lease is 25 years with a 10-year option, your DCF and payback period must sit inside that window.
- Unclear extensions: “options” to extend at “market price” are vague and can become disputes during a hot market.
- Licensing: pure personal leases may not support a licensed hotel or restaurant; you still need an operational entity.
For passive foreign investors using a local rental manager, leasehold can still deliver 6–8% net yields on well-located beachfront or river-adjacent land near tourism nodes. In KEK Likupang and the Manado–Bunaken corridor, I see pro-forma models targeting higher, but realistic long-term net is usually under 10% if you include maintenance and realistic occupancy.
4. Why PT PMA Matters for Serious Investors and Developers
Once you move beyond one or two villas, the framework of Likupang Invest for foreign buyers shifts to the PT PMA – Perseroan Terbatas Penanaman Modal Asing, or foreign investment limited liability company. This is the only robust vehicle for foreign investors to operate a business and hold certain land rights in Indonesia.
A PT PMA is essential if you want to:
- Develop a resort or hotel with multiple keys and operate under a brand or as a management company.
- Apply for HGB or Hak Pakai over land, or hold long leases in the company’s name.
- Hire staff, pay taxes, and sign contracts legally in Indonesia.
- Bring in foreign partners and structure equity exits.
Key points when setting up a PT PMA for tourism and property in North Sulawesi:
- Business classification (KBLI): you must select the correct codes, such as accommodation, restaurants, travel services, or property development. This drives what you can legally do.
- Minimum capital: regulations evolve, but a “foreign investment” company is expected to show a meaningful invested capital (commonly discussed figures are in the several billion rupiah range). Do not fabricate; work with a consultant who tracks the latest rules.
- Licensing (OSS system): after incorporation, the PT PMA must obtain business licenses and, for hotels or villas, tourism-related permits at provincial or regency level.
A well-structured PT PMA in Likupang or Manado can hold a long lease over 5,000–20,000 m² for a boutique resort, build under HGB where available, hire staff from nearby villages, and sign management agreements with international operators.
If you plan to scale or raise capital later, I normally recommend building around a PT PMA from day one. That is also where guide-level advice and local legal support become critical.
5. Infrastructure, ROI, and Rental Yields: How the Macro Story Feeds Your Numbers
Legal structure is only half the story of Likupang Invest for foreign buyers. The other half is the pipeline of infrastructure and tourism demand that ultimately drives occupancy and exit values.
Today, the main catalysts in North Sulawesi are:
- Manado–Bitung toll road: already operational, cutting travel time between the port/industrial zone and Manado city to under an hour. It improves logistics and access from cargo and cruise ships.
- Sam Ratulangi International Airport: expanded to handle more passengers and larger aircraft. Before the pandemic, direct international flights from Singapore and charter traffic from East Asia showed what is possible.
- KEK Likupang SEZ: special tax and investment incentives in a defined area, focused on tourism. Details evolve, but the direction is clear: more room keys, more jobs, more demand for land immediately outside the SEZ.
- Marine assets like Bunaken and surrounding dive areas, already globally known through channels like Indonesia.travel.
How that converts into numbers:
- Current boutique villa occupancy in good micro-locations around Manado–Bunaken and Likupang can reach 50–65% annually for well-managed units with smart online distribution.
- Average daily rates (ADR) for mid- to upper-mid-segment villas can sit in the IDR 800,000–2,000,000 range, depending on product and seasonality.
- Net rental yields on a well-run villa or small resort can reach 7–10% for operators who control costs and keep capex disciplined, but I advise clients to underwrite at 6–8% and treat upside as a bonus.
On the capital gain side, land in Minahasa Utara near planned or active tourism corridors has historically moved in steps: flat, then a jump when a new road, resort, or zoning announcement lands. That is why legal certainty and zoning checks are central to long-term plays.
Platforms like Likupang Invest track how these macro trends affect real on-the-ground pricing and demand, rather than projecting a straight line from government slides.
6. Legal Due Diligence in 2026: What You Absolutely Check
As we move toward 2026, land and tourism regulation continues to evolve. The basics of legal due diligence in North Sulawesi still apply, but enforcement and documentation expectations are tightening.
For any Likupang Invest for foreign buyers project, I insist on at least these checks:
- Land certificate and type: verify with BPN (Land Office) whether the land is Hak Milik, HGB, Hak Pakai, or other category, and ensure the boundaries match the survey.
- Ownership chain: confirm seller’s identity, family consent where needed, and that there are no overlapping claims from relatives or neighbouring villages.
- Zoning and spatial plan (RTRW/RDTR): confirm that tourism accommodation, villas, or resort use is allowed under the local plan for the specific plot.
- Environmental considerations: check setback rules from the coastline, mangroves, rivers, and any conservation areas, particularly relevant near Bunaken and sensitive coastal zones.
- Road access and right of way: secure legal access in writing; do not rely on verbal village understandings alone.
- Village and customary agreements: for land linked to adat or village-owned land, ensure minutes of meetings, approvals, and payment records are properly documented.
- Tax and compliance checks on seller: outstanding property tax (PBB), unpaid transfer tax risks, and building permit issues.
At the company level (PT PMA), you also need:
- Proper shareholder structure with clear rights, reserved matters, and drag/tag clauses for exits.
- Up-to-date NIB and business licenses under the OSS system, matching what the company actually does on-site.
- Contracts for leases, construction, management, and distribution that align with Indonesian law and are enforceable locally.
Using a specialised Likupang Invest advisory approach can help coordinate lawyers, notaries, accountants, and local government offices so that due diligence is integrated – not just “checked” at the last minute.
7. How to Choose Your Structure: Practical Scenarios
To make Likupang Invest for foreign buyers concrete, I reduce choices to a few practical scenarios:
-
Scenario A – Lifestyle plus yield (1–3 villas):
You are an expat entrepreneur or HNW buyer who wants a villa near Likupang or Bunaken, some rental income, and usage a few months a year. A long leasehold, plus a simple management contract with a local operator or PT PMA you co-own, can work well. Focus on location, contract clarity, and tax treatment. -
Scenario B – Boutique resort (8–40 keys):
You are a hospitality developer raising external capital. You must set up a PT PMA, secure either HGB/Hak Pakai or a long lease, and obtain all tourism and building permits. Your financial model should factor in conservative occupancy, realistic ADR, and all compliance costs. -
Scenario C – Land banking around KEK Likupang and Manado–Bitung corridor:
You want exposure to capital growth more than operations. Building a PT PMA holding company with leasehold or HGB over several parcels can position you for an exit to a larger developer or REIT-like vehicle as the region matures.
Across all scenarios, the questions I ask clients at Likupang Invest are the same:
- How much control do you really need?
- What is your realistic holding period?
- Who is your likely buyer when you exit – individual, operator, or institutional capital?
- How comfortable are you with regulatory and currency risk?
Once those are clear, the choice between pure leasehold, PT PMA, or a hybrid structure usually answers itself.
If you are evaluating a project in Likupang, Minahasa Utara, Manado, Bitung, or the Bunaken marine area and want structured help on leasehold, PT PMA setup, ROI modelling, or legal due diligence for 2026 and beyond, contact our team. Reach us via WhatsApp at +62 811-9994-1919 or email sales@indonesiajuara.asia and we can walk through your plan, numbers, and risk profile before you commit capital.