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