Buying a home in Portugal, Spain or England as a US citizen (2026): what you pay
Being American does not change the purchase tax in Portugal, Spain or England: each taxes by residence, not nationality. A US citizen who does not live in the country pays Portugal's flat 7.5% IMT for non-residents or England's 2% stamp duty surcharge, both refundable after a move in time. Spain charges every buyer the same taxes, but a non-resident owner from outside the EU pays 24% each year on an imputed income from the home.
Key facts
- No country on this site sets a purchase tax by nationality; tax residence is what counts.
- Portugal: a buyer who is not tax resident pays IMT at a flat 7.5% plus 0.8% stamp duty, with the difference refunded on becoming resident within two years.
- England: a buyer who spent fewer than 183 days in the UK in the 12 months before buying pays 2% of the price on top of stamp duty.
- England: a home owned in the US counts for the 5% higher rates, unless the English home replaces it as the main home and it is sold.
- Spain: the same purchase taxes for everyone; a US buyer needs a NIE, and pays 24% non-resident income tax each year on a home that is not let, against 19% for EU residents.
- Portugal: a buyer living outside the EU and EEA needs a fiscal representative unless they sign up for the tax authority's electronic notifications.
Do Americans pay more to buy a home in Portugal, Spain or England?
Not for being American. None of the three countries sets its purchase taxes by nationality. What changes the bill is whether the buyer is tax resident in the country where they buy, and a US citizen living in the US is not:
| Portugal | Spain | England | |
|---|---|---|---|
| Extra purchase tax for a non-resident | IMT at a flat 7.5%, with no reductions | None | 2% of the price on top of stamp duty |
| Who counts as non-resident | Not tax resident in Portugal, and never was | Fewer than 183 days in the UK in the 12 months before buying | |
| Refund after moving | The difference, if resident within two years | The surcharge, if the 183-day test is met within a year after completion | |
| Number needed to buy | Portuguese tax number (NIF) | Foreigner’s identity number (NIE) |
The same rules apply to a US citizen who lives in a third country. A US citizen who is already tax resident in Portugal or the UK pays the same as a local buyer.
What does a US citizen pay to buy a home in Portugal?
A buyer who is not tax resident in Portugal pays IMT, the property transfer tax, at a flat 7.5% of the price on any home bought since 25 May 2026, with no exemption or reduction (IMT Code, article 17(10), added by Decree-Law 97/2026). Stamp duty of 0.8% is added, as for every buyer. On a €300,000 home:
| Line | Kind | Amount | Estimate range | Share of price |
|---|---|---|---|---|
| IMT, non-resident buyer (flat 7.5%) | Tax | €22,500 | 7.50% | |
| Stamp duty (Imposto do Selo, 0.8%) | Tax | €2,400 | 0.80% | |
| Lawyer (market rate) | Fee, estimate | €3,750 | €3,000 to €6,000 | 1.25% |
| Deed and land registration (Casa Pronta) | Fee, estimate | €375 | €375 to €700 | 0.13% |
| Taxes | €24,900 | 8.30% | ||
| Fees, typical | €4,125 | €3,375 to €6,700 | 1.38% | |
| Total on top of the price | €29,025 | €28,275 to €31,600 | 9.68% |
A buyer who is tax resident in Portugal and buys their own permanent home pays €12,942.04 in tax on the same home, against €24,900 for the non-resident. Three exceptions narrow that gap (article 17(10) to (12)):
- a buyer who was ever tax resident in Portugal before pays the normal rates from the start;
- a buyer who becomes tax resident within two years of the purchase can ask for the difference back, within 6 months of becoming resident;
- a buyer who lets the home at a moderate rent for long enough can also ask for the difference back.
Every buyer needs a Portuguese tax number, the NIF, which anyone can ask for, resident or not (gov.pt). Because the US is outside the European Union and the European Economic Area, a buyer living there must also appoint a fiscal representative in Portugal, unless they sign up for the tax authority’s electronic notifications (General Tax Law, article 19(6) and (15)). The Portugal guide for non-resident buyers has the full rules, including couples.
What does a US citizen pay to buy a home in Spain?
The same as anyone else. Spain’s transfer tax (ITP) on a resale home, and VAT plus stamp duty (AJD) on a new build, are set by the national law and each region, and none of them changes with residence or nationality. A non-resident buying a €300,000 resale home pays the region’s rate:
| Rank | Place | Buyer | Taxes | Fees, typical | Total on top | Share of price |
|---|---|---|---|---|---|---|
| 1 | Spain, Madrid | Resale, second home, price €300,000 | €18,000 | €4,148.54 | €22,148.54€20,348.54 to €24,248.54 | 7.38% |
| 2 | Spain, Andalusia | Resale, second home, price €300,000 | €21,000 | €4,148.54 | €25,148.54€23,348.54 to €27,248.54 | 8.38% |
| 3 | Spain, Valencian Community | Resale, second home, price €300,000 | €27,000 | €4,148.54 | €31,148.54€29,348.54 to €33,248.54 | 10.38% |
| 4 | Spain, Catalonia | Resale, price €300,000 | €30,000 | €4,148.54 | €34,148.54€32,348.54 to €36,248.54 | 11.38% |
What differs is the paperwork and the yearly tax:
- NIE. A foreigner buying in Spain needs a NIE, the identity number Spain gives foreigners with economic interests there (Real Decreto 1155/2024, article 205). It is asked for at a police station in Spain or at a Spanish consulate abroad. The notary records every signer’s tax number, and the Land Registry will not register a deed without them (Ley Hipotecaria, article 254.2).
- Yearly non-resident income tax. A non-resident who owns a home that is not let pays tax each year on an imputed income: a percentage of the home’s cadastral value, 1.1% or 2% depending on when the town’s values were last revised (Ley 35/2006, article 85, applied by Real Decreto Legislativo 5/2004, article 24.5). The rate is 24% for a resident of the US or any other country outside the EU and EEA, against 19% for residents of the EU or EEA (article 25.1).
- No tax on foreign buyers. A tax on non-EU buyers who are not resident has been proposed in Spain, but on 2 November 2026 it was not law: the national transfer tax law contains no such rate.
The Spain guide for non-resident buyers covers the 3% withholding when the seller is also non-resident, and how a non-resident pays the tax.
What does a US citizen pay to buy a home in England?
Stamp Duty Land Tax (SDLT) looks at days spent in the UK. A buyer who was not in the UK for at least 183 days during the 12 months before the purchase is non-resident and pays a surcharge of 2% of the price on top of the normal bands (GOV.UK; SDLTM09880). On a £300,000 home bought by a US citizen who owns no other home:
| Line | Kind | Amount | Estimate range | Share of price |
|---|---|---|---|---|
| SDLT non-resident surcharge (+2%) | Tax | £6,000 | 2.00% | |
| Stamp Duty Land Tax | Tax | £5,000 | 1.67% | |
| Conveyancing solicitor (market rate) | Fee, estimate | £1,000 | £500 to £1,500 | 0.33% |
| Local searches | Fee, estimate | £350 | £250 to £450 | 0.12% |
| HM Land Registry fee (Scale 1) | Fee | £150 | 0.05% | |
| Taxes | £11,000 | 3.67% | ||
| Fees, typical | £1,500 | £900 to £2,100 | 0.50% | |
| Total on top of the price | £12,500 | £11,900 to £13,100 | 4.17% |
Two rules matter for American buyers in particular:
- A home in the US counts. England’s higher rates for additional homes, 5% of the price, apply when the buyer owns another home worth £40,000 or more anywhere in the world (Finance Act 2003, Schedule 4ZA, paragraph 17). A US citizen living in the US who keeps a house there and buys a flat in London pays both surcharges: £26,000 on a £300,000 home. The higher rates do not apply if the English home replaces the US home as the buyer’s main home and the US home is sold.
- The surcharge comes back after a move. A buyer who spends 183 days in the UK in a 365-day period around the purchase can reclaim the 2% by amending the return within 2 years. A US citizen already living in the UK for at least 183 days of the previous 12 months does not pay it at all.
The non-resident surcharge guide has the day count and the refund, and the second homes guide the higher rates.
Which country costs least for an American who does not live there?
Among the euro places, for a non-resident buying a resale home, Spain’s regions with the lower transfer tax come out ahead of Portugal, because Portugal’s flat rate for non-residents is higher than Madrid’s and Andalusia’s. England works in pounds, so it is compared on the share of the price, never converted. The non-resident buyers section has the full comparison.
Compare what a non-resident pays in Madrid, Portugal and EnglandDoes buying a home give an American the right to live there?
No. Buying property no longer leads to a residence permit in Portugal or Spain, and the UK has no visa based on buying a home. The guide does buying property give residency? has the laws and dates.
What this guide does not cover
- US taxes on owning or selling a home abroad (such as FATCA, FBAR reporting and US capital gains tax) are not covered.
- Visas, residence permits and how to become tax resident.
- Mortgages, and buying through a company or a trust.
- Tax on rental income, and the yearly property taxes paid by every owner.
Questions people ask
Do Americans pay more tax to buy a house in Portugal, Spain or England?
Not for being American. All three charge purchase taxes by residence. A US citizen living in the US is a non-resident, so pays Portugal's flat 7.5% IMT or England's 2% surcharge. A US citizen who is tax resident in Portugal or the UK pays the same as a local. Spain charges residents and non-residents the same.
How much does an American pay to buy a house in Portugal?
As a non-resident, IMT at a flat 7.5% plus 0.8% stamp duty, plus deed and legal fees. On a €300,000 home that is €24,900 in tax, against €12,942.04 for a resident buying their own permanent home. The difference is refunded if the buyer becomes tax resident in Portugal within two years and asks within 6 months.
Does a US citizen need a NIE to buy property in Spain?
Yes. The NIE is the identity number Spain gives foreigners with economic interests there. The notary records every signer's tax number in the deed, and the Land Registry will not register a purchase without them. It is asked for at a police station in Spain or at a Spanish consulate in the US.
Does an American living in London pay the non-resident stamp duty surcharge?
No, if they were in the UK for at least 183 days in the 12 months before buying. The surcharge depends on days spent in the UK, not on nationality or visa. A US citizen who arrived recently pays the 2% and can reclaim it once they reach 183 days in a 365-day period around the purchase.
Does buying a home give an American the right to live in Portugal, Spain or the UK?
No. Portugal stopped accepting golden visa applications based on buying property in October 2023, Spain abolished its investor visa from 3 April 2025, and the UK has no visa based on buying a home.
Sources
- Código do IMT, article 17 (the 7.5% rate for non-residents, n.º 10 to 12)Portal das Finanças (Autoridade Tributária e Aduaneira)
- Decreto-Lei n.º 97/2026, de 20 de maioDiário da República
- Lei Geral Tributária, article 19 (fiscal representative, electronic notifications)Portal das Finanças (Autoridade Tributária e Aduaneira)
- Real Decreto 1155/2024, Reglamento de Extranjería (article 205, NIE)Boletín Oficial del Estado (Spain)
- Ley Hipotecaria (article 254, tax numbers on the deed)Boletín Oficial del Estado (Spain)
- Real Decreto Legislativo 1/1993, ITP y AJD (consolidated text: no rate by residence or nationality)Boletín Oficial del Estado (Spain)
- Real Decreto Legislativo 5/2004, Impuesto sobre la Renta de no Residentes (articles 24.5, 25.1 and 25.2)Boletín Oficial del Estado (Spain)
- Ley 35/2006 del IRPF (article 85, imputed income from property)Boletín Oficial del Estado (Spain)
- Stamp Duty Land Tax: residential property rates (non-UK residents)GOV.UK (HM Revenue and Customs)
- SDLTM09880: non-resident individuals, basic ruleHMRC Stamp Duty Land Tax Manual
Behind the figures
Every amount on this page is worked out by the engine from rule files that cite these pages.
- Agència Tributària de Catalunya: ITP ratesOfficial source
- Which?: Conveyancing, what it is and what it costs (29 May 2026)Secondary source
- The Land Registration Fee Order 2024 (SI 2024/931)Official source
- GOV.UK: Stamp Duty Land Tax, residential property ratesOfficial source