Transfer Tax & Stamp Duty at Purchase: The Global Ranked Comparison (2026)
Published on: June 14, 2026
Quick answer: The one-time purchase tax, transfer tax, stamp duty, or acquisition duty, runs from zero (Czech Republic) to a transaction cost that can exceed the deposit (Singapore's 60% foreign-buyer surcharge). For a foreigner, the published rate is rarely the whole story: the UK, Australia, Singapore, Canada and Israel all stack a second surcharge on top. Always get the all-in entry cost before you fall in love with a listing.
Annual property taxes, Spain's IBI, France's taxe foncière, Italy's IMU, get all the attention because you pay them forever. But the tax that actually decides whether a deal works is the one you pay once, at the moment you sign: the transfer tax, stamp duty, or acquisition duty. It can be zero. It can be more than half the purchase price. And for foreign buyers, a second surcharge often stacks on top of the first. (For the recurring side of the ledger, see our annual property-tax guide.)
This is the one-time-purchase-tax comparison, ranked, with the foreign-buyer surcharges that most published "rate tables" quietly leave out. All figures reflect the position as understood in early-to-mid 2026; rates change, so treat this as a map, not a quote.
The ranking, low to brutal
| Market | Headline purchase tax | Foreign-buyer reality |
|---|---|---|
| Czech Republic | 0% (abolished 2020) | Same for foreigners, no surcharge |
| United States | No federal transfer tax; small state/city duties | Generally same as locals; some "mansion taxes" in NYC, etc. |
| Dubai / UAE | ~4% DLD transfer fee | Same for foreigners |
| Switzerland | ~0–3.3%, varies by canton | Mostly same; some cantons restrict foreign buyers (Lex Koller) |
| Romania | ~0.15% registration + ~2–3% costs | Same on buildings; land ownership restricted for non-EU |
| Portugal | IMT, progressive up to ~7.5% (residents) | 2026 reform: flat 7.5% IMT for non-residents (refund if you become a PT tax resident within 2 years or commit to moderate-rent letting) |
| France | generally ~5.8–6.3% droits de mutation (varies by department as of 2026) | Same for foreigners |
| Germany | Grunderwerbsteuer ~3.5–6.5% by state | Same for foreigners |
| Spain | ITP ~6–11% by region (resale) | Same for foreigners (no national surcharge) |
| Israel | 8% then 10% for investors/non-residents | Foreigners pay the high investor brackets |
| Netherlands | 2% owner-occupier; 8% investor (2026) | No nationality surcharge, use-based |
| United Kingdom | SDLT up to 12% | +5% additional dwelling +2% non-resident, stacks |
| Australia | State duty ~4–5% | +7–9% foreign surcharge, plus a ban on established homes |
| Canada | Provincial land transfer tax | Federal ban + 25% speculation tax + Toronto's 10% |
| Singapore | BSD up to 6% | +60% ABSD for foreigners |
The spread runs from literally nothing to a transaction cost that can exceed the deposit. Three patterns are worth understanding.
Pattern 1: the "same for everyone" markets
In a large group of countries, the purchase tax does not care about your passport. The Czech Republic charges nobody (it abolished its 4% acquisition tax in 2020). The United States has no federal transfer tax and only modest state and municipal duties. Dubai's 4% Dubai Land Department fee, France's droits de mutation, Germany's Grunderwerbsteuer and Spain's regional ITP all apply to locals and foreigners alike. The Netherlands is a clever variant: it charges 2% to an owner-occupier and, from 1 January 2026, 8% to an investor (down from 10.4%), the trigger is how you use the property, not your nationality.
For a foreign buyer, these are generally markets where the published rate is close to the real rate and there is typically no nationality-based surcharge, but add notary, registration and legal costs before budgeting.
Pattern 2: the surcharge stack
This is where buyers get hurt. Several countries layer a foreign-buyer or second-home surcharge on top of the standard duty, and the surcharges compound.
- United Kingdom. Standard SDLT rises to 12% on the top band. A second/additional dwelling adds 5% (raised from 3% in late 2024). A non-UK resident adds a further 2%. These stack: a non-resident buying an additional home faces both surcharges, pushing the effective top burden toward 19%.
- Australia. State stamp duty is only the start. Foreign buyers pay a surcharge of roughly 7–9% on top, depending on the state (New South Wales went to 9% in 2025; Victoria and Queensland sit at 8%; South Australia 7%). On top of that, Australia restricted foreign purchases of established (resale) homes from April 2025, so for many foreigners the new-build market is the only open door.
- Israel. The bracket system itself is the surcharge: residents buying their only home get a zero-rated first tier; investors and, in practice, foreign buyers generally start at 8% and rise to 10%; as of 2026 these investor brackets have been frozen in nominal terms, so bracket creep can push more of each deal into the 10% band.
Pattern 3: the markets that go beyond tax to a ban
Two flagship markets decided surcharges weren't enough and effectively closed the door.
- Canada runs a federal Prohibition on the Purchase of Residential Property by Non-Canadians, extended to 1 January 2027, covering most urban areas. For the narrow cases where a non-resident can still buy, provincial speculation taxes of 20–25% (Ontario and British Columbia) apply, and the City of Toronto added a further 10% municipal surcharge in 2025, a combined 35% in the city.
- Singapore keeps the market technically open but prices foreigners out with the world's heaviest buyer surcharge: a flat 60% Additional Buyer's Stamp Duty on any residential purchase, on top of Buyer's Stamp Duty of up to 6%. As of 2026, a foreigner without an applicable exemption buying a S$1 million condo would generally pay about S$600,000 in ABSD alone; certain nationalities (for example US nationals under a free trade agreement) may be treated differently. The rate has held since April 2023 and was left unchanged in Budget 2026.
A counter-trend is worth noting: not every market is tightening. Some jurisdictions that piled on foreign-buyer duties during the 2010s boom have since rolled them back to revive demand. The lesson is that these surcharges are policy levers, not fixed features, they move with the political wind, in both directions.
How to actually use this
- Get the all-in entry cost before you fall in love with a listing. The purchase tax is the biggest variable, but add notary, registration and legal fees on top.
- Check for a second surcharge. The headline rate is rarely the whole story for a foreigner. UK, Australia, Singapore, Canada and Israel all hide the real number in a surcharge.
- Watch the trigger. Some surcharges key off nationality, some off residency, some off how many homes you own, and some, like the Netherlands, off whether you'll live there. Same property, different buyer, wildly different bill.
Frequently asked questions
Which country has the highest property transfer tax for foreigners?
By a wide margin, Singapore, a flat 60% Additional Buyer's Stamp Duty for foreigners on top of standard duty. Canada effectively goes further with an outright ban on most foreign residential purchases through 2026.
Which countries have no property transfer tax?
The Czech Republic abolished its acquisition tax in 2020. The United States has no federal transfer tax (only modest state/local duties). Several others keep entry taxes low and apply them equally to foreigners.
Do foreign buyers always pay more transfer tax?
No. In many markets, the US, France, Germany, Spain, Dubai, the rate is the same regardless of nationality. The surcharge markets are mainly the UK, Australia, Singapore, Canada and Israel, plus use-based systems like the Netherlands.
What is the UK "surcharge stack"?
A non-UK resident buying an additional dwelling pays standard SDLT plus a 5% additional-dwelling surcharge plus a 2% non-resident surcharge, both stack, which can push the effective top burden toward 19%.
Price the entry cost before you buy
The purchase tax can swing your all-in cost by double digits. Compare markets, prices and the full cost stack across 50+ countries on JanusHermes, and read our hidden-costs breakdown before you budget.
This article is general information and reflects rates as understood in mid-2026. It is not legal or tax advice, and transfer-tax rates and foreign-buyer surcharges change frequently and vary by region within a country. Confirm the current rate with a local tax adviser or conveyancer before budgeting a purchase.
A note on the numbers: where no source is named, the market figures in this article (prices, yields, costs) are indicative estimates compiled from publicly available market data and industry reporting at the time of writing. Markets move and rules change, so treat them as a starting point and verify current figures with official sources before acting on them.
