Capital gains, withholding, exemptions and local taxes for non-resident sellers in Italy, France, Spain, Greece, Portugal, Cyprus, Bulgaria, Turkey and Dubai.
When you sell a property abroad, the tax can arise in three places at once: in the country where the property stands, in the country where you live, and sometimes through a deduction taken from the price at closing. This hub gives the main rules for nine popular destinations so that you can see the differences before you list the property. It summarises our country articles, which are linked below; rates and exemptions are set each year and some details are reported by secondary sources, so confirm them with a local adviser before you sign.
The three layers of tax on a sale
- Capital gains tax in the country of the property, usually on the gain (sale price minus the purchase price and documented costs), not on the price.
- A retention or withholding taken at closing, such as the 3% retained by the buyer in Spain or the tax settled through the notary in France and Italy.
- Local taxes and costs: for example the Spanish municipal plusvalía, or the Dubai transfer fee.
On top of that, your country of residence may tax the same gain and give a credit for the foreign tax, depending on the treaty. Read double taxation treaties for foreign property and our general guide on how to sell property abroad.
Italy
Italy only taxes the gain if you sell within five years of buying (or completing) the property. After five years, no Italian capital gains tax arises on the sale. Inside five years the seller can choose a 26% substitute tax applied by the notary at the deed, or ordinary income tax on the gain. The main-residence exemption is hard to use for a non-resident. See capital gains tax on sale in Italy and the Italian tax agency (Agenzia delle Entrate) at agenziaentrate.gov.it.
France
France taxes a non-resident's gain in two layers: 19% income tax and 17.2% social levies, 36.2% in total before allowances. Sellers affiliated to a social security scheme in an EU or EEA country (or Switzerland) are reported to pay a lower social-levy rate of 7.5%; confirm which applies to you. Allowances grow with years of ownership: income tax is fully exempt after 22 years and social levies after 30, and gains above 50,000 euro attract a surcharge of 2% to 6%. The notary normally settles the tax at the sale, and a fiscal representative may be required for some non-EU sellers above 150,000 euro. See capital gains tax on sale in France and impots.gouv.fr.
Spain
The Tax Agency's guide for non-residents states a flat 19% on property gains. The buyer must retain 3% of the price and pay it to the tax office as an advance (Modelo 211); the final tax is declared on Modelo 210 and any excess can be reclaimed. The municipal plusvalía is a separate local tax. See capital gains tax on sale in Spain and agenciatributaria.es.
Greece
The law provides for a 15% tax on gains, but it has been suspended for individuals until 31 December 2026 and extensions have been granted repeatedly. Companies are taxed differently, and what happens from 2027 is not certain. See capital gains tax on sale in Greece.
Portugal
Under the guidance of Portuguese accountants, a non-resident includes 50% of the net gain in taxable income at progressive rates, and must declare worldwide income to set the rate. Reinvestment relief for non-residents is uncertain. See capital gains tax on sale in Portugal.
Cyprus
Capital gains tax is 20% for every seller regardless of residence, with lifetime exemptions that rose from 1 January 2026 (general 30,000 euro, main residence 150,000 euro). See capital gains tax on sale in Cyprus.
Bulgaria
The tax on the gain is 10%, with holding-period exemptions (generally one home held more than 3 years, or two properties held more than 5 years). Sources differ on whether non-EU/EEA non-residents may use them, so confirm your status. See capital gains tax on sale in Bulgaria.
Turkey
Gains are taxable if you sell within five years of the title-deed registration, with the cost indexed to inflation in some cases; the rate follows a progressive scale from 15% to 40% after an annual exemption. A non-resident may need to file within 15 days. See capital gains tax on sale in Turkey.
Dubai
An individual pays no capital gains tax on a property sale, but the sale has costs (the 4% Dubai Land Department fee, agent commission, developer NOC). A company may be taxed under the 9% corporate tax. Tax can still arise in your home country. See capital gains tax on sale in Dubai.
For residents of the EU and Poland
Russian-speaking owners who live in Poland or elsewhere in the EU should check two things before the sale: whether the foreign tax is credited in your home return, and which year the gain and the foreign tax fall into. A hypothetical example: a resident sells for the equivalent of 300,000 euro a flat bought for 200,000 euro; the same 100,000 euro gain can be taxed at 19% in one country, 0% in another and then again at home, so the home-country treatment decides the net result. Keep the purchase deed, invoices for works and proof of tax paid.
FAQ
Who pays tax when a non-resident sells property abroad? Usually the seller, in the country of the property, and possibly also in the country of residence. Is there always a withholding? No: Spain retains 3% from the price, while in France and Italy the notary settles the tax at the deed; check each case. Which of these countries has no personal capital gains tax? Dubai for individuals; Italy after five years of ownership; Greece currently, because of a suspension to the end of 2026. Do I need a tax number? Often yes, see NIE, NIF and codice fiscale for foreign buyers. Can I credit foreign tax at home? Depending on the treaty and your national law; see the treaties guide linked above.
How we help
We are a trilingual platform that finds properties and coordinates independent local lawyers and tax advisers, including for a sale. This text is informational and is not legal, tax or investment advice; rates and exemptions change, so verify the current rules before you sell.