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THE CITIZENSHIP DESK

Capital Gains Tax by Country

Capital gains tax (CGT) regimes vary dramatically — from comprehensive worldwide-asset taxation (US, Canada, UK) to purely territorial systems (Hong Kong, Singapore, UAE) to holding-period-based exemptions (Germany 1yr/10yr, Switzerland category-based, Czech 3yr/5yr). This reference covers top rates, holding-period rules, principal-residence treatment, and treaty notes across 30+ major destinations.

Last reviewed: 2026-05-13. CGT rules change frequently with national budgets — UK October 2024 (raised from 20%/18% to 24%), Canada June 2024 (inclusion-rate increase above $250k), Italy 2026 (crypto rate increase) are recent examples.

Capital gains tax top rate, holding-period rules, and principal-residence treatment by country
CountryRegimeTop rateHolding periodPrincipal residence / notes
ArgentinaComprehensive CGT15% on most asset disposals (listed shares often exempt for residents on Argentine market); 17.5% withholding on real estate; rate doubles on non-resident sellersNoneExempt if proceeds reinvested within 1 year

Peso-denominated thresholds adjust frequently due to inflation. Bilateral tax-treaty relief limited. Significant administrative complexity.

https://www.afip.gob.ar/

AustraliaComprehensive CGTMarginal rate (top 45% + 2% Medicare) — but 50% CGT discount on assets held >12 months by individuals = effective top rate ~23.5%>12 months for 50% discountMain residence exemption — full exemption on principal-residence sale; partial if income-producing

Foreign residents: no 50% discount on Australian-situs gains since May 2012. Departing residents face deemed-disposition exit tax (see exit-tax reference).

https://www.ato.gov.au/

BrazilComprehensive CGT22.5% on gains >BRL 30M; 20% BRL 10-30M; 17.5% BRL 5-10M; 15% on first BRL 5M (sliding scale)NoneExempt if proceeds reinvested in another residential property within 180 days

Foreign-source gains for Brazilian tax residents at the same rates. Significant cross-border treaty network. Crypto gains follow the same sliding-scale rates.

https://www.gov.br/receitafederal/

CanadaComprehensive CGT50% inclusion rate × top marginal rate (federal + provincial ~53.5% in ON) = effective top CGT ~26.75% on first $250k/yr gains; from June 2024 reform, 66.7% inclusion above $250k threshold = effective ~35.7%NonePrincipal Residence Exemption — full exemption on main home (can only claim one per family per year)

Lifetime Capital Gains Exemption (LCGE) — $1.016M (2024) on qualified small-business corporation shares and farm/fishing property. Deemed disposition at death + on departure (see exit-tax reference).

https://www.canada.ca/en/revenue-agency.html

FranceComprehensive CGT30% flat Prélèvement Forfaitaire Unique (PFU/flat tax) on investment income + capital gains (12.8% income + 17.2% social levies); 19% on real estate + 17.2% social levies on real estateReal estate: full exemption after 22 years for income tax + 30 years for social levies (linear taper)Full exemption on primary residence at sale

Option to elect progressive rates if more favourable. €5,000/yr abatement for retired shareholders. Crypto gains taxed at the same 30% flat rate.

https://www.impots.gouv.fr/

IrelandComprehensive CGT33% (one of EU's higher rates)NonePrincipal Private Residence (PPR) relief — full exemption

€1,270 annual exemption. Entrepreneur Relief reduces rate to 10% on first €1M lifetime business gains.

https://www.revenue.ie/

IsraelComprehensive CGT25% top rate on most capital gains (real estate, shares); 30% for major shareholders (>10% stake)NoneExemption available on principal-residence sales (one every 18 months)

New-immigrant Olim get 10-year exemption on foreign-source capital gains. Aliyah immigrants benefit from this materially — major draw for high-net-worth Aliyah candidates.

https://www.gov.il/en/departments/israel_tax_authority/

ItalyComprehensive CGT26% flat on financial-asset gains (raised from 12.5% pre-2014, increased to 26% for crypto from 2026 — was 26% on excess above €2,000 until 2025)>5 years on real estate → exempt (no other holding-period reductions)Exempt if held >5 years OR used as primary residence majority of holding

HNWI €200,000 flat-tax regime and IFICI Impatriate Regime affect CGT treatment of foreign-source gains. Substantial-shareholder (>2% listed / >25% unlisted) treated separately.

https://www.agenziaentrate.gov.it/

JapanComprehensive CGT20.315% flat on long-term shares (held > 5 years on real estate; no holding-period threshold on listed securities); higher on short-term real estateReal estate: <5 years = 39.63% combined; >5 years = 20.315% combined¥30M deduction on principal-residence sale

Foreign nationals tax-resident in Japan over 10 years face worldwide CGT (and inheritance tax — see IHT reference). Combined with 55% top IHT rate, a notable consideration for long-stay foreign HNWIs.

https://www.nta.go.jp/english/

MexicoComprehensive CGT10% flat on listed-securities gains via Mexican stock exchange (BMV); marginal rate (up to 35%) on real estate and non-BMV gainsNoneUp to UDIS 700,000 (~MXN 5M / $250k) exemption on principal-residence sale

Foreign-source gains for Mexican tax residents at marginal rates with foreign-tax-credit relief. Trader-classified activity taxed differently.

https://www.sat.gob.mx/

PortugalComprehensive CGT28% flat on financial-asset gains for residents (option to elect progressive rates); 50% inclusion in income for real estate gains (effectively half the marginal rate)None for shares; 24 months for crypto (gains exempt after that)Exempt if proceeds reinvested in EU primary residence within 36 months

NHR closed 2024; IFICI replacement narrower on CGT. Real-estate gains for non-residents: 28% flat (changed from 25% inclusion in 2023).

https://info.portaldasfinancas.gov.pt/

South AfricaComprehensive CGT18% effective top rate (40% inclusion × 45% top marginal); 22.4% effective for companies; 36% effective for trustsNoneFirst R2 million ($110k) of gain on primary residence exempt

R40,000 annual exclusion. Departing residents face deemed-disposition exit tax (see exit-tax reference) — major consideration for HNWI emigration.

https://www.sars.gov.za/

South KoreaComprehensive CGTUp to 27.5% on listed-share gains for major shareholders (>1% stake or >₩5B holding); 40-70% on real-estate gains short-term; from 2025 reform, financial-investment-income tax (FIIT) postponed to 2027Real estate: <1 year 70%; 1-2 years 60%; >2 years standard brackets₩900M exemption on principal residence sold after 2+ year ownership (raised from ₩600M in 2024)

FIIT (financial investment income tax) on listed-securities gains was postponed multiple times; current target 2027. Crypto trading-gains tax also postponed.

https://www.nts.go.kr/english/

SpainComprehensive CGT28% top bracket (19% on first €6,000, 21% on €6,001-€50,000, 23% on €50,001-€200,000, 27% on €200,001-€300,000, 28% above €300,000) — 2024/2025 bracketsNoneExempt if proceeds reinvested in new primary residence within 2 years; over-65s fully exempt on primary residence sale

Non-resident sellers of Spanish real estate face 19% withholding at sale. Beckham regime taxpayers only on Spanish-situs gains. Significant ECJ rulings on cross-border investment-income equivalence with residents.

https://sede.agenciatributaria.gob.es/

United KingdomComprehensive CGT24% on residential property gains; 24% on other assets (from 30 October 2024 reform — was 20%)None — gains taxed in tax year realisedPrincipal Private Residence (PPR) relief — full exemption on main home, prorated if periods of non-occupation

Annual Exempt Amount £3,000 (2024/25). Non-doms historically claimed remittance basis on foreign-situs gains — replaced from April 2025 by 4-year residence-based regime. Business Asset Disposal Relief reduces rate to 10% on first £1M lifetime.

https://www.gov.uk/capital-gains-tax

United StatesComprehensive CGT20% federal long-term (held >1 yr); 37% federal short-term; +3.8% NIIT above $200k/250k MAGI; +state CGT (CA 13.3%, NY ~10.9%, no state CGT in TX, FL, NV, WA, etc.)>1 year for long-term rate; short-term taxed as ordinary income$250,000 single / $500,000 MFJ exclusion on home sale if owned + lived in 2 of last 5 years (Section 121)

Citizens taxed on worldwide CGT regardless of residence. Step-up in basis at death eliminates accumulated CGT for heirs. Section 1031 like-kind exchanges defer real-estate CGT.

https://www.irs.gov/taxtopics/tc409

BelgiumLimited / category-specific0% on most capital gains for individuals (movable property held outside professional context); 33% on speculative gains; new wealth tax framework being debatedNone — exemption is intent-based (professional vs personal management)Generally exempt

Belgium is unusual among Continental European countries in not levying CGT on most individual investment-gain scenarios — historically a strong wealth-management draw. Reform proposed periodically.

https://finance.belgium.be/en

Czech RepublicLimited / category-specific15% on gains held <3 years; exempt if held >3 years (securities) or >5 years (real estate)>3 years for securities = exempt; >5 years for real estate = exempt (if not principal residence — that's exempt after 2 years)Exempt after 2+ years residence

Combination of 15% flat PIT + holding-period exemptions makes Czech Republic one of EU's more CGT-friendly jurisdictions.

https://www.financnisprava.cz/en/

GermanyLimited / category-specific25% flat Abgeltungsteuer (final withholding tax) on investment income + capital gains; +5.5% solidarity surcharge>10 years on real estate → exempt; >1 year on shares purchased before 2009 → exempt (grandfathered)Exempt if used as primary residence in year of sale + 2 preceding years

Crypto gains exempt after 1 year holding period for individuals. €1,000/yr Sparer-Pauschbetrag investment allowance. Significant-shareholder rules (≥1% stake) trigger different treatment.

https://www.bzst.de/EN/

MalaysiaLimited / category-specificReal Property Gains Tax (RPGT) up to 30% on property sold within 3 years (5% from year 6+); 10% flat on Capital Gains Tax for unlisted-shares disposal from 2024 reformProperty: 30% if <3 years; 20% year 4; 15% year 5; 10% year 6+; 5% after for citizensCitizens: once-in-a-lifetime exemption on principal-residence sale

Until 2024, Malaysia had no general capital gains tax — only property-specific RPGT. The 2024 budget introduced 10% CGT on unlisted-shares disposal for companies and individuals.

https://www.hasil.gov.my/

NetherlandsLimited / category-specificBox 3 deemed-yield system (effective 1.5%-2% of asset value annually) — actual gains not taxed but assets above €57,000 face annual deemed-return taxationN/A — no traditional CGT on shares for box-3 holdersBox 1 — primary residence taxed via imputed rental income, not on disposal

Substantial-shareholders (≥5% stake — box 2) face 24.5% on gains up to €67,000 + 31% above (2024). Hoge Raad ruled deemed-yield unconstitutional; actual-yield reform pending for 2027.

https://www.belastingdienst.nl/

New ZealandLimited / category-specificMarginal rate (top 39%) applied to bright-line residential property sales within 2 years (down from 10 years in 2024); no general CGTBright-line residential-property test: 2 years from July 2024 (was 10 years 2021-2024)Family home exempt from bright-line test

NZ famously has no general CGT. Trader-classification, dealer-classification, and bright-line residential rules catch specific scenarios. Property speculation captured; long-term equity holdings not.

https://www.ird.govt.nz/

ThailandLimited / category-specificIncome tax brackets (up to 35%) applied to gains classified as taxable; many capital gains exempt under Thai system (listed-share sales on SET, certain real-estate)Specific holding-period rules for propertySpecific business tax (3.3%) on property sold within 5 years

Thailand's capital-gains landscape is highly category-specific. SET-listed share sales by individuals often exempt. Real-estate sales attract specific business tax + transfer fee + withholding.

https://www.rd.go.th/

Hong KongNo personal CGTNot taxed — Hong Kong does not impose capital gains taxN/AN/A

Pure territorial system. Combined with no estate tax and salaries-only income tax, Hong Kong is among the world's most CGT-favoured jurisdictions.

https://www.ird.gov.hk/

KuwaitNo personal CGTNo personal CGTN/AN/A

Pure no-personal-tax jurisdiction. Foreign-company taxation only.

QatarNo personal CGTNo personal CGTN/AN/A

Pure no-personal-tax jurisdiction. Foreign-investor 10% income tax on Qatar-source business income only.

https://www.gta.gov.qa/

Saudi ArabiaNo personal CGTNo personal CGT; Zakat (2.5% annual) applies to Saudi/GCC nationals on net worthN/AN/A

Foreign residents face no CGT. Corporate tax (20% standard / 15% in special zones) does not extend to individual capital gains.

https://zatca.gov.sa/

SingaporeNo personal CGTNot taxed for individuals on capital gains generally; gains classified as trading income (frequency, intent) are taxed at ordinary ratesN/AN/A — Singapore property gains generally not taxed unless trader-classified

No traditional CGT regime. Combined with absence of estate tax and territorial taxation, makes Singapore extremely tax-favoured. Stamp duty on property purchases offsets some advantage.

https://www.iras.gov.sg/

SwitzerlandNo personal CGTNot taxed for individuals on movable property (except professional traders); cantonal real-estate gains tax appliesN/A on movable; cantonal real-estate gains tax often tapered (Geneva: 50% in year 1, taper to 0% after 25 years)Real-estate gains tax applies on disposal; deferral on reinvestment in own-use property

Major draw for HNWIs — no personal CGT on share / crypto / commodity gains for non-professional investors. Forfait fiscal lump-sum-taxation regime overlays.

https://www.estv.admin.ch/

United Arab EmiratesNo personal CGTNo personal CGT for residents; new 9% federal corporate tax applies to businesses above AED 375,000 profit (since 2023)N/AN/A

Pure no-personal-income-tax jurisdiction; CGT does not apply to individuals.

https://tax.gov.ae/

Reading this matrix

  • Comprehensive = worldwide-CGT systems where most disposal gains are taxed regardless of asset class.
  • Limited = systems where CGT applies only to specific categories (real estate only, professional traders only, deemed-yield models like the Netherlands box-3).
  • None = jurisdictions with no personal CGT on most individual investment activity (Switzerland for movable property, Singapore, Hong Kong, UAE, Qatar, Kuwait, NZ for non-bright-line property).
  • Holding-period exemptions are a major planning factor. Germany's 1-year crypto / 10-year real-estate rule and Czech's 3-year/5-year rules are notable.
  • Principal-residence exemptions vary widely — US $250k/$500k (with 2-of-5-year residence test), UK full PPR relief, France full exemption, Spain conditional reinvestment relief.
  • Departing-resident exit taxes (US, Canada, Australia, Germany, Norway, etc.) are a separate matrix — see exit tax by country.

See also: Exit tax matrix · Inheritance tax matrix · Wealth tax matrix.