What Actually Comes With the House: Fixtures, Fittings and Movables Abroad

Published on: August 26, 2026

Last verified: 26 August 2026. The classification of fixtures and movables, and the treatment of price apportionment for transfer tax, vary by country and are subject to change and to case law.

Quick answer:

• Every system uses three categories: the land and building, fixtures that have become part of it, and movables that belong to the seller. The fights all happen in the middle.
• In Germany and Austria, assume the kitchen leaves. Kitchens are furniture there, bought and removed like a sofa.
• The Dutch three-column inventory is the best mechanism anywhere: stays, goes, available for a price. Copy it even where no local equivalent exists.
• Allocating price to movables can lawfully reduce transfer tax in Germany, France, the Netherlands and the UK, but only at genuine second-hand values with evidence, and it reduces what your lender will advance.
• The contract is the answer to almost every question here. Annex a signed, photographed inventory to the binding document, not to an email afterwards.

There is a moment familiar to anyone who has bought abroad. You collect the keys, open the door, and the kitchen is gone. Not the appliances: the kitchen. Cabinets, worktop, sink, the lot, leaving pipe stubs and unpainted wall.

In Germany that is not theft, it is convention. The buyer who assumed otherwise made the same mistake buyers make everywhere: they applied their home country's default rule to somebody else's legal system.

Every jurisdiction has a boundary between what is part of the property and what belongs to the seller personally. Nobody agrees on where the line sits, most contracts handle it in a single unexamined clause, and in several countries the answer also determines how much transfer tax you pay. This guide covers both halves: what actually stays, and how the split is taxed.

The three categories every system uses

The terminology varies but the structure is consistent.

Immovable by nature. The land and the building. Never in doubt.

Fixtures, or immovables by destination. Things that were movable but have been attached to or designated for the building so as to become part of it. Fitted wardrobes, a boiler, plumbed sanitaryware, an alarm system. These generally convey with the property.

Movables, or chattels. Furniture, curtains, rugs, garden pots, freestanding appliances. These belong to the seller and travel with them unless bought separately.

The fights all happen in the middle category, and the tests used to resolve them differ:

• Degree of attachment. How firmly is it fixed, and would removal damage the building? This is the dominant test in common-law systems.
• Purpose and adaptation. Was it made or adapted specifically for this building? A window blind cut to a non-standard opening is a stronger candidate for fixture status than a standard one.
• Intention. What did the parties intend? In practice this is decided by what the contract says, which is why the contract is the answer to almost every question in this article.

Country by country: what actually happens

Germany and Austria: assume the kitchen leaves

The German Einbauküche is genuinely a personal possession in the way a sofa is elsewhere. Kitchens are bought as furniture, fitted to the flat, removed on moving out and re-fitted in the next one. Many rental flats are let with no kitchen at all.

If the kitchen is staying, it is normally sold as a separate itemised item, and there is a tax reason for that. Grunderwerbsteuer, Germany's real estate transfer tax, runs between 3.5 and 6.5 percent depending on the federal state, and it applies to the property, not to movable inventory sold with it. A kitchen, sauna, awnings, freestanding appliances and even the heating oil left in the tank can be priced separately and fall outside the tax base.

Three cautions, because this is a well-worn path with well-known potholes:

• The values must be real. German tax offices check. A used kitchen valued at replacement cost rather than second-hand value invites a reassessment, and in a bad case an allegation of evasion. Keep the seller's original invoices where you can.
• The often-quoted 15 percent figure is an attention threshold, not a safe harbour. Inventory below roughly 15 percent of the price attracts less scrutiny if it looks plausible; it does not entitle you to deduct 15 percent by default, and large absolute amounts draw attention regardless of percentage.
• Your lender only lends against the property. Shifting €30,000 of price onto inventory reduces the amount the bank will finance. Discuss the split with your mortgage provider before it goes in the deed, not after.

Austria applies a similar transfer tax but has taken a notably stricter line on fitted kitchens. Austrian tax jurisprudence has treated a built-in kitchen as Zugehör, an accessory that shares the legal fate of the dwelling, and therefore inside the tax base. The concept and the case law differ across the border, so do not carry a German assumption into an Austrian purchase.

Netherlands: the three-column list

The Dutch have the best mechanism of any market covered here. The standard purchase agreement comes with a lijst van zaken, an itemised inventory in which every item is marked in one of three columns: stays with the property, goes with the seller, or is available to take over for a price.

It covers everything from curtains and rails to garden plants, awnings, light fittings, letterboxes and shed contents. Both parties sign it and it forms part of the contract.

Movable items (roerende zaken) can also be excluded from the base for overdrachtsbelasting, the Dutch transfer tax, on the same principle as Germany, with the same requirement that the values be defensible.

If you are buying anywhere else, the Dutch list is worth copying as a template even where no local equivalent exists.

France: the mobilier deduction, and its limits

France allows the price to be split between the property and meubles meublants, furnishings intended for the use and ornament of the dwelling. Transfer duties (droits de mutation à titre onéreux) apply only to the immovable portion.

The rules are tighter than the folklore suggests:

• Only genuinely movable items qualify. Detachable kitchen units, freestanding appliances, furniture and garden furniture can. Anything sealed to the structure cannot: a bonded parquet floor, a fitted fireplace, shutters, a non-dismountable kitchen.
• Valuation must reflect real second-hand market value, item by item. Invoices or a documented valuation support it. Overvaluation exposes both parties to reassessment with penalties.
• The saving is modest. Departmental duties sit around 5.8 percent in most areas. A €10,000 furniture deduction saves roughly €580, not €800 of "notary fees". It is worth doing, it is not worth distorting.
• The rate itself moved. The 2025 finance act allowed departmental councils to raise the departmental component above 4.5 percent up to 5 percent for deeds concluded from 1 April 2025, on a temporary basis and with an exemption for qualifying first-time buyers. Many departments took it up, so check the current rate for the specific department rather than assuming the old national figure.

A useful contrast: in a French succession, where no notarial inventory is drawn up, the tax administration values the deceased's furniture at a flat 5 percent of the net estate. That flat rate is an inheritance rule and does not transfer to a sale. Nobody is entitled to deduct "5 percent for furniture" from a purchase price.

There is also a non-tax trap. If a public body exercises a pre-emption right over the property, it buys at the price stated for the property alone. The seller keeps the furniture, and anything that was actually attached to the building may be lost without further compensation. Inflating the mobilier figure creates exposure in more than one direction.

United Kingdom

England and Wales handle this through the TA10 Fittings and Contents Form, completed by the seller and covering every room plus the garden, with each item marked as included, excluded, or available for separate sale. It is thorough and it is standard, which makes the UK one of the easier markets on this subject.

For stamp duty, the price attributable to chattels can be excluded from the SDLT base, but the apportionment must be just and reasonable and reflect actual value. Fixtures cannot be apportioned out. HMRC pays particular attention where an apportionment happens to drop the price just below a rate threshold, because the tax saving there is disproportionate to the amount shifted. Scotland and Wales operate their own transaction taxes with the same underlying principle.

Spain

Spanish practice usually treats furnished sales as a single price, with ITP (or VAT on new build) calculated on the whole. Movable goods can be itemised, but the practice is less established than in Germany or France and less likely to be volunteered by the agent. If a purchase is expressly furnished, get an inventory annexed to the private contract before the deed, listing what stays: Spanish holiday-home sales in particular have a history of furniture quietly leaving between the private contract and the handover.

Italy

Italian deeds can itemise movables, but the incentive structure is different. Where the prezzo-valore mechanism applies, registration tax is calculated on the cadastral value rather than the price, so the tax benefit of stripping out furniture is often small or nil. The inventory still matters for a different reason: to establish what is included, particularly with rural and holiday properties sold arredato (furnished). Attach a signed list to the preliminary contract.

Portugal, Greece and Turkey

Portugal charges IMT on the transmission of immovable property; movables sold alongside can be separated but the practice is not routine, and a written inventory is the practical protection. Greece taxes the transfer of the property, with the same principle. In Turkey, the title deed fee is calculated on the declared property value and furniture is customarily dealt with by a side agreement; because underdeclaration of property value carries its own risks there, keep the furniture agreement clearly separate and documented.

United States

American practice distinguishes fixtures (conveying with the real property) from personal property (transferring, if at all, by a separate bill of sale). The classic test looks at the method of attachment, the adaptation of the item to the property, and the intent of the parties. State-standard purchase agreements typically list included items explicitly, and anything not listed is a negotiation.

Transfer taxes are set at state and local level, and personal property is generally outside them, but the amounts are usually small enough that the tax angle is secondary to simply knowing what you are getting.

The items that cause the most arguments

Regardless of country, this is where disputes cluster. Put every one of them in writing.

• Kitchen units and appliances. Especially in Germany, Austria and the Netherlands, and increasingly wherever kitchens are modular.
• Light fittings. Extremely common cause of dispute across northern Europe. Sellers take pendants and leave bare wires.
• Curtains, blinds and their rails. The rail and the curtain are often treated differently.
• Garden plants. Planted in the ground usually stays; in a pot usually goes. Mature specimen trees and topiary have been the subject of real litigation.
• Sheds, greenhouses and garden buildings, particularly if not on foundations.
• Wood-burning stoves and free-standing fireplaces.
• Solar panels and batteries, especially where they are leased rather than owned. Check for a third-party lease that survives the sale.
• Water heaters, softeners and filtration units on rental contracts. Rented boilers exist in several markets and the contract may not be assignable.
• Wall-mounted TVs, brackets and speaker systems.
• Awnings, pergolas and outdoor kitchens.
• Swimming pool equipment, robots and covers.
• Fuel in the tank. Heating oil, gas cylinders and pellet stocks are movable property with real value.
• Keys, remotes and fobs. Not a value item, but a genuinely common irritation. Specify how many of each.

How to do this properly

Ask for the inventory before you offer, not after. If a property is being marketed as furnished, the inventory is part of what you are pricing.

Use a three-column list. Stays, goes, negotiable. Copy the Dutch format. Photograph anything valuable and attach the photographs to the list.

Annex it to the binding document. In civil-law systems that is the preliminary contract, and it should be carried through to the deed. A list agreed by email after the preliminary contract has weak standing.

Value movables honestly and keep the evidence. Second-hand market value, item by item, with invoices where the seller has them. Tax authorities in Germany, France and the UK all revalue implausible splits, and interest runs from the original due date.

Talk to your lender before you split the price. The reduction comes off the property value the bank lends against.

Do a final inspection before completion, not after. In most countries your leverage disappears the moment the deed is signed and the money released. Walk the property on the morning of completion with the inventory in your hand.

Where local practice has no formal list, write one anyway. A signed annexe naming forty items costs nothing and resolves the argument before it starts.

Frequently asked questions

Is it legal to allocate part of the price to furniture to reduce transfer tax?
Yes, in the countries where movables are outside the tax base, provided the allocation reflects genuine items at genuine second-hand values and is properly documented. What is not legal is inventing items or inflating values, which is a tax matter rather than a grey area.

How much can I safely allocate?
There is no universal safe percentage. The German rule of thumb of around 15 percent of the price is widely repeated but it describes when authorities look harder, not what they will accept. The correct answer is the actual value of the actual items, whatever percentage that turns out to be.

Will taking the kitchen affect my mortgage?
It can. Lenders value the property, not the contents, so a large inventory allocation lowers the amount they will advance. In Germany specifically, a property sold without a kitchen is also valued differently from one sold with it. Raise this with the lender early.

What if items are missing when I take possession?
Your remedy depends on what was contractually agreed, which is why the annexed inventory matters so much. Where a signed list exists, missing items are a straightforward contractual claim. Where there is nothing but a memory of a conversation with the agent, recovery is difficult in most jurisdictions.

Do I have to buy the furniture if the seller offers it?
No. A furnished sale in most markets is two agreements travelling together, and you can decline the movable half. Be aware that this occasionally changes the seller's willingness to proceed, particularly where they were relying on not having to clear and remove the contents.

Keep reading on JanusHermes

One habit prevents almost every problem in this article: get a signed three-column inventory annexed to the binding contract before you commit, and walk the property with it in your hand on the morning of completion, while you still have leverage. JanusHermes lists property from local agencies in 11 languages, with the local agency's own contact details on every listing.

Related reading: Furnishing a Home Abroad, The Civil-Law Notary System Explained, How to Hire a Real Estate Lawyer Abroad, Renovation Cost Per Square Metre by Country, Cash Payment Limits When Buying Property, The Preliminary Contract and Deposit Trap and Buying Property From an Estate Abroad.

This article is general information for buyers and sellers, not legal or tax advice. The classification of fixtures and movables, and the treatment of price apportionment for transfer tax, vary by country and are subject to change and to case law. Take advice from a qualified local lawyer, notary or tax adviser before allocating any part of a purchase price to movable items.