PropertyGainsTax

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Capital gains tax on property compared across five countries, 2026

On the same second-home sale, a gain of 100,000 in local currency by an owner earning 80,000, capital gains tax in 2026 takes 15.0% of the gain in United States (federal) and 32.6% in Ireland, the widest gap of the five. Currencies are not converted, so the effective rate is the fair comparison. Every figure comes from the verified rules of each tax authority.

How much tax is due on the same gain in each country?

A second home, never a main residence, bought for 300,000 and sold for 400,000 in local currency, held five years, one owner with other taxable income of 80,000. Data as of 6 September 2026.

CountryGainEstimated taxEffective rate on the gainHow it is taxed
United Kingdom £100,000 £23,280 23.3% 18% within the basic-rate band, 24% above, after the £3,000 allowance
United States (federal) $100,000 $15,000 15.0% Long-term rate stacked on income; state tax extra
Ireland €100,000 €32,581 32.6% 33% after the €1,270 exemption
Australia $100,000 $16,000 16.0% 50% discount, then marginal rates plus 2% Medicare levy
Canada (Ontario) $100,000 $15,984 16.0% One-half inclusion, federal plus Ontario rates

Currencies are not converted; the comparison is of each system's treatment of a like-for-like gain. Source: each country's rate file, linked from its calculator page and the methodology. For the same figures at four income levels, and what changes when the property is your main home, see which country charges the least.

How do the rules differ by country?

CountryHeadline residential rateAnnual exemptionMain-home reliefReporting deadline
United Kingdom 18% or 24% by band £3,000 Private Residence Relief 60 days
United States 0, 15 or 20 per cent long-term, plus 3.8 per cent NIIT None (main-home exclusion instead) Section 121 exclusion, $250,000 or $500,000 Annual return
Ireland 33% flat €1,270 per person Principal Private Residence relief 15 December or 31 January, by sale date
Australia Marginal rate (15% to 45%) on half the gain after 12 months, plus 2% levy None (50 per cent discount instead) Main residence exemption, six-year rule Annual return, by contract date
Canada Marginal rate (federal 14% to 33% plus provincial) on half the gain None (one-half inclusion rate instead) Principal residence exemption, (1 + years designated) / years owned Annual return, 30 April

United Kingdom figures verified 3 September 2026 against HM Revenue & Customs (gov.uk); United States figures verified 6 September 2026 against Internal Revenue Service (IRS); Ireland figures verified 6 September 2026 against Revenue (revenue.ie); Australia figures verified 6 September 2026 against Australian Taxation Office (ato.gov.au); Canada figures verified 6 September 2026 against Canada Revenue Agency (canada.ca). This is general information, not tax advice.

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