Stamp Duty and Property Transfer Taxes: A Global Comparison

For international property investors, the headline purchase price is rarely the true cost of acquisition. Stamp duty, land transfer taxes, and associated levies can add between 1% and 15% or more to the cost of a property purchase depending on jurisdiction — a significant sum on a multi-million-pound transaction. Understanding these costs before committing to a purchase is essential.

This guide provides a practical comparison of property transfer taxes in the key markets most relevant to internationally mobile HNW buyers, as of 2026.

Tax rates and regulations change. Always verify current rates with a specialist local lawyer before any property transaction.

United Kingdom: Stamp Duty Land Tax (SDLT)

The UK imposes Stamp Duty Land Tax on residential and commercial property purchases in England and Northern Ireland. Scotland has Land and Buildings Transaction Tax (LBTT) and Wales has Land Transaction Tax (LTT) — similar but with different rate thresholds.

Residential SDLT (England and Northern Ireland)

As of 2026, SDLT rates on residential property are:

• 0% on the first £125,000
• 2% on £125,001 to £250,000
• 5% on £250,001 to £925,000
• 10% on £925,001 to £1.5 million
• 12% above £1.5 million

Additional Dwelling Surcharge: A 5% surcharge (increased from 3% on 31 October 2024) applies to purchases of second homes, buy-to-let properties, or properties where the buyer already owns residential property anywhere in the world.

Non-Resident Surcharge: A 2% non-resident surcharge applies to non-UK residents purchasing residential property in England and Northern Ireland. This surcharge is in addition to the standard rates and the additional dwelling surcharge.

The result for a non-UK resident investor purchasing a second residential property in England priced at £2 million (as of 2026):

• Standard SDLT: approximately £138,750
• Additional dwelling surcharge (5%): £100,000
• Non-resident surcharge (2%): £40,000
• Total SDLT: approximately £278,750 (approximately 14% effective rate)

Commercial SDLT

Commercial property SDLT rates are lower:

• 0% on the first £150,000
• 2% on £150,001 to £250,000
• 5% above £250,000

No non-resident surcharge applies to commercial property.

Annual Tax on Enveloped Dwellings (ATED)

For residential properties held through companies (including offshore companies), ATED applies annually based on property value. Properties worth £500,000 to £1 million attract a charge of approximately £4,500 per annum (2026/27); £1-2 million, approximately £9,150; up to approximately £298,500 per annum for properties worth over £20 million. ATED can be significant for high-value properties in corporate structures.

Dubai / UAE: Dubai Land Department Transfer Fee

Dubai's property transaction costs are refreshingly simple compared to the UK:

• Dubai Land Department (DLD) fee: 4% of the transaction value, payable to the DLD at registration
• Agency commission: Typically 2% to the seller's agent
• Registration fee: AED 4,000 to AED 16,000+ depending on property value
• No annual property tax — there is no equivalent to UK council tax or ATED
• No capital gains tax on sale proceeds

The DLD 4% fee is the dominant transaction cost. On a AED 3 million (approximately £650,000) property, DLD is AED 120,000 (approximately £26,000). Competitive with many European jurisdictions but without the graduated surcharges of the UK.

Abu Dhabi has a similar registration fee structure at 2% (paid by the buyer) plus 2% (paid by the seller).

Spain: Transfer Tax and Stamp Duty

Spain's property purchase taxes are among the most complex in Europe, varying significantly by region (autonomous community).

Resale Properties (Impuesto de Transmisiones Patrimoniales, ITP)

For resale (second-hand) residential properties, ITP is charged at regional rates:

• Andalusia: 7% (reduced from higher rates in recent years)
• Catalonia: 10%
• Madrid: 6%
• Valencia: 10%
• Balearics (Ibiza, Mallorca): 8-13% (progressive scale)
• Canary Islands: 6.5%

These rates apply to the declared transaction price or the minimum reference value (valor de referencia) set by the Spanish tax authority, whichever is higher. The introduction of reference values has increased effective ITP costs in many areas.

New-Build Properties (IVA + AJD)

New properties are subject to:

• IVA (VAT): 10% for residential properties (4% for social housing)
• AJD (Stamp duty): 0.5% to 2.5% depending on the region, applied to the notarial value

For a €1 million new-build in Valencia: IVA 10% = €100,000 + AJD ~1.5% = €15,000. Total tax cost = €115,000.

Non-Resident Considerations

Non-residents pay the same transaction taxes as residents. There is no additional surcharge, unlike the UK. However, non-residents are subject to Spanish withholding on sale proceeds (3% of the sale price retained by the buyer and paid to the Spanish tax authority, to be offset against any CGT liability on the gain).

Thailand: Transfer and Taxes

Thailand's property transfer costs are moderate but require careful navigation given the restrictions on foreign ownership.

For a condominium (the primary vehicle for foreign ownership):

• Transfer fee: 2% of the registered value
• Stamp duty: 0.5% of the appraised value (in lieu of specific business tax for individual sellers)
• Specific business tax (SBT): 3.3% of the appraised value (if the property is sold within 5 years)
• Income tax withholding: Variable — based on seller's calculation of gain

The registered value used for Thai transfer tax calculations is typically the Land Department appraised value, which is often below market value. This means effective transfer tax rates as a percentage of market price are often lower than statutory rates suggest.

Foreign buyers should budget approximately 2-3% of the purchase price for transfer taxes and associated legal/registration costs.

Greece: Transfer Tax

Greece applies a property transfer tax of:

• 3.09% of the objective value of the property for older properties (built before the introduction of the building permit system in many areas)
• For new buildings still subject to VAT, 24% VAT applies instead of transfer tax

Since 2022, VAT on new-build properties has been suspended for a temporary period and subsequently modified. As of 2026, the position should be verified with a Greek lawyer, as the rules have been subject to changes.

Effective transfer costs in Greece, including notarial and registration fees, typically run to 3-5% of the purchase price for resale properties, and can be significantly higher for new builds subject to VAT.

Golden Visa Threshold

Greece's Golden Visa property investment threshold was raised to €800,000 in popular areas (Attica, Thessaloniki, Mykonos, Santorini, and other islands above 3,100 km²) and €400,000 in other areas as of 2023. Transfer taxes apply on top of these thresholds.

Singapore: Buyer's Stamp Duty and Additional Buyer's Stamp Duty

Singapore has a sophisticated and layered stamp duty system designed partly to moderate foreign demand in its property market.

Buyer's Stamp Duty (BSD)

BSD applies to all buyers, Singapore citizens and foreigners alike:

• 1% on the first S$180,000
• 2% on S$180,001 to S$360,000
• 3% on S$360,001 to S$1 million
• 4% on S$1,000,001 to S$1.5 million
• 5% on S$1.5 million to S$3 million
• 6% above S$3 million

Additional Buyer's Stamp Duty (ABSD)

ABSD is the key differentiator by buyer type. As of 2026 (rates subject to change by the Singapore government):

• Foreign purchasers: 60% ABSD on all residential properties
• Singapore Permanent Residents: 5% on first property, 30% on subsequent
• Singapore Citizens: 0% on first property, 20% on second, 30% on third and beyond

The 60% ABSD for foreign buyers makes Singapore residential real estate effectively uneconomic for most non-PR investors. This deliberate policy restricts foreign demand in the residential market.

Commercial property is not subject to ABSD — only residential.

Portugal: IMT

Portugal levies Imposto Municipal sobre Transmissões Onerosas de Imóveis (IMT) on property purchases:

• 0% on urban residential properties up to €92,407
• Progressive rates up to 7.5% for properties above €1.1 million
• 6% flat rate on purchases by entities in jurisdictions on the blacklist (offshore jurisdictions)
• Stamp duty (Imposto do Selo) of 0.8% on the purchase price in addition to IMT

As of 2026, the golden visa for property investment has been suspended in Portugal — residency by property investment is no longer available.

France: Droits de Mutation

France applies property transfer taxes (droits de mutation) of approximately 7-8% of the purchase price for most resale transactions, comprising:

• Département tax (4.5% to 5%, depending on the département)
• Commune tax (~1.2%)
• State surcharge (~2.4%)
• Notary fees and registration

For new-build properties sold with TVA (VAT at 20%), only a reduced transfer tax of ~0.715% applies (plus notary fees).

France's total acquisition cost (transfer taxes + notary fees) for a resale property is typically 7-9% of the purchase price — among the higher rates in Western Europe.

Germany: Grunderwerbsteuer

German real estate transfer tax (Grunderwerbsteuer) varies by federal state:

• Bavaria and Saxony: 3.5%
• Hamburg: 5.5%
• Most other states: 6% to 6.5%
• Schleswig-Holstein and North Rhine-Westphalia: 6.5%

On a €1 million German property, transfer tax ranges from €35,000 (Bavaria) to €65,000 (higher-rate states). Notary and registration fees add approximately 1.5-2%.

Summary Comparison

Jurisdiction	Typical Transfer Tax (Residential)	Non-Resident Surcharge
UK	5-12% (SDLT, graduated)	+2% surcharge
Dubai	4% (flat DLD fee)	None
Spain	6-13% (varies by region)	None
Thailand	~2-3% effective	None
Greece	~3-4% (transfer tax)	None
Portugal	~7-9% (IMT + stamp)	Higher for blacklist entities
France	~7-9% (droits de mutation)	None for individuals
Germany	3.5-6.5% (Grunderwerbsteuer)	None
Singapore	BSD + 60% ABSD for foreigners	Very high surcharge

Key Takeaways for International Buyers

1. Budget correctly — property transfer taxes are a real cost that reduces your effective return, particularly on shorter holding periods.
2. Compare on a total cost of ownership basis — a market with lower transfer taxes may have higher annual property taxes (or vice versa).
3. Structure matters — in some jurisdictions, corporate structures can reduce or affect transaction costs. Take advice before choosing.
4. Reclaim what you can — in some EU jurisdictions, non-EU buyers who are also EU VAT registered may be able to reclaim some VAT on commercial property transactions.
5. Local legal advice is essential — rates change, reference values update, and local rules have nuances that generalist advisers can miss.

How Global Investments Can Help

Global Investments has supported international property buyers in all major markets covered in this guide. We help investors understand the total cost of acquisition, choose optimal structures, and identify opportunities where transaction costs can be legitimately managed. We work alongside specialist local solicitors and notaries in each market.

If you are considering international property investment and want a clear-eyed assessment of transaction costs alongside yield and capital growth potential, contact our team.

Transaction tax information is current as of 2026 but subject to change. Always verify current rates with a specialist local legal adviser before completing any property transaction. This article is for information only and does not constitute advice.