Joe McAlister's Blog

One of the striking disparities between different countries is who owns rental properties. In general terms, landlords may be listed as public bodies, private companies or other organisations (for profit) (Figure 2). The proportion of rentals in each of the 3 sectors varies greatly, as do the types of entities in each.
Each country has public housing (called "public" or "social"), owned by local or state authorities. Each country has its own housing. Social housing (owned by local councils or housing associations) accounts for about 17% of the United Kingdom housing sector, down from 30% in 1980. In France, public housing accounts for about 17% of the housing sector and 43% of the rental market, serving both households of medium and low income. In comparison, less than 5% of US rental housing is held by municipal government agencies and all subsidized housing accounts for less than 10% of the rental market.  doha property finder
Two groups of private property owners fall into: individual and institutional owners. Individual owners make up about half the rental market in Germany, the rest of them in Spain and Japan and more than 90% of the rental market in France. Institutional ownership, like big asset management companies, REIT trusts and private equity firms, is most common in the USA. In most countries, the limited position of corporate owners can represent higher risks and reduced returns on strong tenants (discussed below) and differences in Corporate Tax Policy.
Companies beyond conventional public-private categories have part of each country's rental housing. Japan has quasi-public national and regional bodies providing middle income rental housing. There are more than half of U.K. housing associations that offer affordable housing. German housing cooperatives contributed to the lack of reasonably priced housing during the Second World War and now make up about 25 per cent of the rental stock. In the US, non-profit organisations, which have built a large share of subsidized homes under the Low-Income Tax Credit programme.
Every country offers some kind of household subsidy in addition to social housing. The proportion of pensioners who receive help and the overall budget for these services differ widely. France is spending about $15.5 billion on tenant rental assistance. The US spends just about 24 billion dollars on vouchers for a population five times the size of France. Leasing assistance is guaranteed in Germany for all eligible households, while in the United States most low-income households are not supported.
It can be tricky to balance tenant rights with financial rewards for landlords
Even before the COVID-19 pandemic, housing insecurity deteriorated for low income renters, tenant advocates and some U.S. elect officials called for better legal safeguards for tenants. The methods of other countries to regulate leases and tenant relations give some valuable lessons – both in their success and their failures.
National legislation regulates core provisions of landlord-tenant relations in all studied countries other than the US, including the procedure of termination or renewal for leases and eviction proceedings. (U.S. delegates state government landlord-tenant law) Even if the exact type of regulation is different, the national tenant rights legislation in other countries makes it harder for landowners to terminate leases in order to ensure more security for tenants. Multi-year or open-ended bonds are common in France, Germany, Japan, and Spain, with mainly one-year bonds issued by the United States and the United Kingdom.
Case studies from three countries – Japan, Spain, and the United Kingdom – show how significant the security of tenants has led to insufficient rental supplies on a regular basis. Excessively tight restrictions on the right of landholders to terminate rentals or expel tenants – including for failure to comply with rental conditions – increase the risks involved in investing in rental properties. Long-term leases can also limit the opportunity to increase rents and further reduce the motivation for prospective landlords. Then, all three of these countries tried to loosen national laws which were seen as inhibiting private rental markets.
Germany and France both have strong national tenancy rights, but they do not, at least when combined with tax benefits, seem as much of a disincentive for private tenants, to make owning rent housing an appealing investment for individuals.
More knowledge-sharing could lead to better policies across countries
The COVID-19 crisis has prompted policymakers worldwide to take rapid action to protect public health and reduce economic harm. Many minds working together are more likely to come up with workable ideas in the face of these immense challenges. Far too often, however, politicians across countries – including at local or regional level in the same country – work alone instead of learning from their neighbours.
Cross-country research on housing markets is not easy—it needs to understand specific legal and financial structures that fund real property markets and how they emerged from the unique background of each country. It is not possible to simply copy and paste policies from one country to another. However, it is obvious that every country has tried to solve long-term household problems, including providing good, low- and high- and middle-income housing that is affordable. We hope that international talks between researchers and scholars – as seen in these case studies – will contribute to this.