Italy vs Spain for Foreign Buyers (2026): Tax Regimes, Buying Costs, Bureaucracy, and Which One Actually Fits You

Published on: June 23, 2026

Quick answer: Italy and Spain look alike but diverge on money. Spain abolished its Golden Visa in April 2025; Italy still has an Investor Visa. For wealthy newcomers, Italy's flat tax (a €300,000/year lump sum on all foreign income for 2026 entrants) suits very large foreign incomes, while Spain's Beckham Law (24% on Spanish income up to €600,000 for six years) suits high employment or remote-work earners. Buying costs run roughly 10–15% in both, structured differently: Italy's registration tax on a low cadastral value versus Spain's regional ITP of 6–11% or 10% VAT on new-builds. Spain's headline "100% tax on non-EU buyers" is a 2025 proposal, not law.

If you are a lifestyle buyer weighing a Mediterranean base, two countries dominate the shortlist: Italy and Spain. They look similar from the outside: sun, food, culture, EU access, healthcare, a notary-led purchase process. But on the things that actually move money, they diverge sharply, and both rewrote significant rules in 2024 to 2025. This is a 2026 head-to-head on the four things that decide the question: the tax regime for new residents, the cost of buying, the bureaucracy, and which buyer each country actually fits.

Residency and visas: the starting point changed

The single biggest recent change is on the Spanish side. Spain abolished its Golden Visa (residency-by-investment) on 3 April 2025. The property-purchase route to residency is gone; existing holders keep their status, but new buyers cannot use property to obtain residency. Spain's remaining routes include the Digital Nomad Visa, the Non-Lucrative Visa (for those with passive income), and work or family routes.

Italy still offers its Investor Visa ("golden visa") for qualifying investments. Italy also applies a reciprocity rule to property purchases by non-EU citizens, you can generally buy only if Italians are allowed to buy in your country, but Investor Visa holders are exempt from that rule. EU citizens face no such constraint in either country.

The tax regimes for new residents: this is where they really differ

Both countries court wealthy and high-earning newcomers, but with completely different mechanisms.

Italy: the lump-sum flat tax (best for large foreign income)

Italy's flat-tax regime for new residents (Article 24-bis) lets you pay a fixed annual lump sum that covers all your foreign-source income, no matter how large. Italian-source income is still taxed normally. The key 2026 facts:

• The lump sum is now €300,000 per year for those who opt in from 1 January 2026, up from €200,000 (Aug 2023 to Dec 2025) and €100,000 before that. Earlier entrants are grandfathered at their original rate.
• You can add family members for €50,000 each per year (doubled from €25,000 in 2026).
• The regime lasts up to 15 years.
• You must not have been an Italian tax resident for at least 9 of the previous 10 years.
• It brings exemption from Italian inheritance and gift tax on foreign assets, a major draw for family-office buyers.
• Watch out: it does not replace Italy's wealth taxes on foreign assets: IVIE (~0.76% on foreign real estate) and IVAFE (~0.2% on foreign financial assets) are still due.

This is a flat fee, so it only makes sense if your foreign income is very large: for a multi-million-euro income, €300,000 can be a fraction of normal tax; for a modest income, it's a bad deal. (We compare it with Portugal's regime in our Italy flat tax vs Portugal IFICI guide.)

Spain: the Beckham Law (best for high Spanish employment income)

Spain's special regime, the "Beckham Law," works differently. Qualifying newcomers are taxed broadly as non-residents:

• A flat 24% on Spanish-source income up to €600,000 (income above that is taxed at 47%).
• Foreign-source income, gains, and dividends are generally not taxed in Spain.
• It runs for six years (the year of arrival plus five).
• You must not have been a Spanish tax resident in the previous five years, and it now extends to remote workers and digital entrepreneurs.

Spain also has a wealth tax, and although several regions (Madrid, Andalusia and others) currently apply 100% relief, the national Solidarity Tax on Large Fortunes still applies to net wealth above €3 million regardless of region. There is also the Modelo 720 foreign-asset reporting obligation to be aware of.

The cost of buying: transfer taxes and fees

This is where many buyers underestimate the bill. Both countries add roughly 10–15% in taxes and fees on top of the price, but the structure differs.

Italy

• Registration tax is around 2% for a "prima casa" (first or primary home) and 9% for a second home, but it is generally calculated on the property's cadastral value, which is often well below the market price, softening the headline rate.
• "Prima casa" relief has conditions: you must move your residence to the property's municipality within 18 months and not own another main home in Italy.
• Add notary (notaio) fees, agent commission (typically 3–5%), and mortgage taxes where relevant.
• Capital gains on a resale are taxable if you sell within five years (unless it was your main home), though a 26% substitute tax option exists.

Spain

• On a resale ("second-hand") property you pay Transfer Tax (ITP), which is set regionally and ranges roughly 6–11%, for example Andalusia ~7%, the Valencia region ~9% (and 11% above €1 million), Madrid ~6%.
• On a new-build you pay 10% VAT (IVA) plus stamp duty (AJD) of about 0.5–1.5%.
• Add notary, land-registry, and legal fees (budget ~1% for a lawyer).
• Spain uses a reference or cadastral value for the ITP base, which can be higher than your purchase price, a trap that surprises buyers who negotiated a good deal.

The Spain "100% tax" headline: what's actually true

You have probably seen alarming headlines about Spain imposing a 100% tax on non-EU buyers. Here is the accurate 2026 position, because getting this wrong is expensive in either direction (we cover it in full in our dedicated explainer on Spain's proposed 100% tax):

• In January 2025, the Prime Minister floated the idea, and in May 2025 the governing Socialist party submitted a draft bill.
• As drafted, it is a complementary state surcharge on top of ITP, aimed only at non-EU, non-resident buyers of resale property. It would not apply to EU residents, to Spanish residents of any nationality, or to new-build purchases (which are taxed under VAT, not ITP).
• It is a proposal, not law. As of 2026 no bill has been adopted. The government lacks a parliamentary majority, several parties oppose it, and tax experts widely doubt it passes in its original form; it also raises serious EU-law (free movement of capital) and Spanish constitutional questions.

In short: monitor it, but do not plan as if it already exists. If you are a non-EU buyer concerned about it, note that new-build purchases sit outside the proposed mechanism entirely, and residency removes exposure.

Bureaucracy: both are notary-led, both can be slow

• Italy: you need a codice fiscale (tax code), the purchase is finalized by a notaio who checks title and pays taxes, and the reciprocity rule applies to non-EU buyers. Our Italy buyer guide walks through the full process.
• Spain: you need an NIE (foreigner identification number), a notary executes the deed, and rules vary by autonomous community: taxes, paperwork, and even short-term-rental licensing differ region to region. See our Spain investment guide for the regional detail.

Neither process is fast, and in both countries a good independent local lawyer (not the seller's or developer's) is the difference between a clean purchase and an expensive surprise.

Quick comparison

Which one fits you?

• Choose Italy if you have very large foreign income (the flat tax is a fixed fee, so it rewards scale), you want inheritance-tax shelter on foreign assets, or you simply prefer the regions and lifestyle.
• Choose Spain if your income is high but employment- or remote-work-based (the Beckham Law's 24% can beat the flat fee for "normal-large" earners), or you're a lifestyle buyer drawn to the coast, just account for regional ITP and the visa change.

There is no universal winner. The right answer depends on the size and source of your income, your residency plans, and which region you actually want to live in.

Frequently asked questions

Does Spain still have a Golden Visa in 2026?
No. Spain abolished it on 3 April 2025. Existing holders keep their status; new buyers must use other visa routes.

How much is Italy's flat tax in 2026?
€300,000 per year for those opting in from 1 January 2026 (with earlier entrants grandfathered at €100k or €200k), plus €50,000 per added family member.

Is Spain's 100% tax on foreigners real?
It is a proposal submitted in 2025, not law. As of 2026 it has not been adopted, applies only to non-EU non-resident resale buyers as drafted, and faces strong legal and political obstacles.

What are total buying costs?
Budget roughly 10–15% on top of the price in both countries, though the components differ (registration tax and cadastral value in Italy; regional ITP or VAT plus AJD in Spain).

Disclaimer. This article is general information for international buyers, current as of 2026, and is not legal or tax advice. Tax regimes, transfer-tax rates, visa rules, and pending legislation in both Italy and Spain change frequently and vary by region and personal circumstances. The Spanish non-EU surcharge described here is a proposal, not enacted law. Always engage an independent local lawyer and tax advisor in the relevant country before buying.

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.