Spain vs France in 2026: Where Foreign Buyers Win

Published on: June 29, 2026

Spain and France are Europe's two largest markets for foreign property buyers, the sun-and-coastline heavyweights. Yet they are rarely compared head-to-head, partly because both have made headlines lately for the wrong reasons. Spain "banned" foreign buyers; France is "impossible to buy in as a foreigner." Both claims are myths. Here is what is actually true in 2026, and which country wins for which buyer.

Two headlines you've seen, both misunderstood

Before the comparison, clear the two pieces of misinformation that dominate this topic.

Myth 1: "Spain has a 100% tax on foreign buyers." In January 2025, Spain's prime minister floated a tax of "up to 100%" on resale-property purchases by non-EU, non-resident buyers. It generated worldwide headlines, but as of mid-2026 the bill has never been formally debated or voted on in Congress, it has stalled, and it was quietly dropped from the government's January 2026 housing package. It is not law. Even the draft version exempted new-builds and off-plan property entirely. We cover this in full in Spain's 100% tax on non-EU buyers.

Myth 2: "Foreigners can't buy in France." False. Foreigners can buy French property freely, in their own name, with the same transfer duties and rights as locals. What France has never had is a golden visa, owning property there grants no residency.

With those cleared, here is the real picture.

At a glance

Figures are indicative and change. Confirm current rates before acting.

Residency: neither country gives it for buying

This surprises buyers coming from a golden-visa mindset.

Spain ended its Golden Visa on 3 April 2025. You can no longer obtain Spanish residency by buying property. Existing holders keep and renew their permits, but new buyers get nothing toward residency. To live in Spain, non-EU citizens now use other routes, the Non-Lucrative Visa (for retirees/passive-income holders) or the Digital Nomad Visa (for remote workers), which we map in Spain's golden visa alternatives.

France never offered a property-based visa. Owning a French home is a lifestyle asset, not an immigration tool. Non-EU owners are limited to the Schengen 90-days-in-180 rule and must apply for a standard long-stay visa (visitor, retirement, work, family) to spend longer.

So on residency the two are level: buy for the home, not the visa.

Buying costs: France is more predictable, Spain more regional

France runs every purchase through a notaire, a neutral public officer who verifies title, holds funds, and collects taxes. "Notaire fees" are misleading, most of the bill is transfer tax to the state. Budget roughly 7-8% of the price on an existing (ancien) property and 2-3% on a new-build (VEFA), where reduced duties apply and 20% VAT is already in the price. Note that from April 2025 many departements raised their transfer-tax share, nudging older-property costs toward the top of that band.

Spain varies by region. On resale homes you pay ITP (transfer tax) of roughly 6-10% depending on the autonomous community; on new-builds you pay 10% VAT plus ~1.5% stamp duty (AJD), plus notary, registry, and legal fees. Spain's costs are competitive but less uniform than France's.

In both countries: use your own independent lawyer, never the seller's or developer's.

Ongoing taxes: watch France's wealth tax

Spain. Owners pay annual municipal property tax (IBI). Non-resident landlords pay income tax on rental income at 24% (non-EU) or 19% (EU), file the annual non-resident return (Modelo 210), and pay capital gains tax on sale (24% non-EU / 19% EU). Some regions also levy a wealth tax, though several have effectively neutralised it.

France. Owners pay annual taxe fonciere, plus taxe d'habitation on second homes (it was abolished only on primary residences, and many tourist communes add a surcharge). The one to plan around is IFI, France's real-estate wealth tax: non-residents owe it on net French real estate above 1.3 million euros, at progressive rates, though mortgage debt on the property is deductible from the base (a key reason leveraged buyers stay below the line). See our deep dive on the wealth tax on international property. Rental income is taxed at a minimum of 20-30% plus social charges, and capital gains at 19% plus social charges, with taper relief reaching full exemption after long holding periods.

Lifestyle and market

Both offer world-class food, climate, and coastline. Spain skews toward value, strong rental yields in coastal and city markets, and an established expat infrastructure on the Costas. France skews toward prestige and resilience, Paris and the Cote d'Azur hold value across cycles, with a culture that treats a French home as a long-hold lifestyle asset rather than a yield play. Spain is generally cheaper to buy and to live in; France carries higher prestige and, often, higher carrying costs.

Who should choose which?

• You want the best value and rental yield → Spain, especially the coastal new-build markets the (still-only-proposed) tax would have exempted anyway.
• You want a prestige long-hold and aren't chasing yield → France, budgeting for taxe fonciere and, above 1.3M euros of French property, IFI.
• You're a non-EU buyer worried about Spain's "100% tax" → it isn't law, and new-builds were exempt in the draft regardless; a new-build purchase sidesteps the concern entirely.
• You need residency → neither delivers it through property; line up the right visa (Non-Lucrative/Digital Nomad in Spain, a long-stay visa in France) separately.

Compare live Spanish and French listings, with full cost context, across 50+ markets on JanusHermes. For the neighbouring Mediterranean matchup, see Italy vs Spain.

Frequently asked questions

Did Spain really ban foreign property buyers?
No. Foreigners can still buy freely. Spain ended its Golden Visa (April 2025) and a "100% tax" was proposed but never passed and has stalled.

Can I get residency by buying property in Spain or France?
No, in both. Spain's Golden Visa ended; France never had one. Use a separate long-stay visa to live in either country.

What is France's IFI and will it affect me?
IFI is France's wealth tax on real estate. As a non-resident you only owe it if your net French property exceeds 1.3 million euros on 1 January; mortgage debt reduces the taxable base.

Are buying costs higher in France or Spain?
Comparable. France runs ~7-8% on resale (lower on new-builds); Spain runs ~6-10% ITP on resale (10% VAT + ~1.5% stamp on new-builds), varying by region.

A note from JanusHermes

We wrote this because the two biggest European markets are clouded by two myths, that Spain banned foreigners and that France is closed to them, when the real decision is about cost, tax, and lifestyle. JanusHermes is a cross-border real estate platform, not a legal, tax, or immigration adviser. You can browse Spanish and French listings side by side, or explore both across 50+ countries on JanusHermes.

Disclaimer. This article is general information current as of mid-2026, not legal, tax, or immigration advice, and does not create any professional or advisory relationship. Tax rates, wealth-tax thresholds, transfer duties, and any proposed legislation can change and depend on your nationality, residency, and the region/departement. Always confirm the current position with a qualified Spanish or French lawyer and a cross-border tax advisor before committing funds. JanusHermes accepts no liability for any action taken in reliance on this content.

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.