Many countries have implemented a capital gains tax, but capital gains tax rates and the tax structure itself vary greatly from one country to the next.
Capital gains taxes are generated when you sell an asset for a profit. Assets can be real property, precious metals, stocks, bonds, cryptocurrency, land, and similar holdings or resources.
In this article we’ll take a closer look at how capital gains taxes work in the U.S. and other countries, and we’ll also discuss some similarities and incongruities this tax shares among different government tax entities.
Capital Gains Taxes in Different Countries
In the U.S., capital gains taxes are capped at 20 percent if you’ve held an investment asset longer than one year and you are in the highest income bracket for married or single taxpayers.
Capital gains taxes are much higher in many European countries. In Denmark, for example, the highest top capital gains tax is 42 percent – the highest rate across the globe. Finland caps its capital gains tax at 34 percent, while France caps it at 30 percent with a 4-percent increase for high-income earners. Meanwhile, Belgium, Luxembourg, and Slovenia place no capital gains tax on profits generated from the sale of investment assets.
The way income is taxed varies greatly as well. In the U.S. you’ll generate a capital gains taxable event if you sell something for more than you paid for it – although many real estate investors use 1031 exchanges to defer paying their capital gains tax liabilities. In Great Britain, investors pay 28 percent capital gains tax from the sale of residential property, and 20 percent on “chargeable” assets such as business machinery and equipment, personal possessions, and business shares not held in a tax-free Individual Savings Account or Personal Equity Plan – the British equivalents of U.S. tax-preferred/tax-exempt Individual Retirement Accounts.
How often you’ll have to pay capital gains taxes when you sell certain investments in other countries varies as well.
Capital Gains Tax Exemptions in Certain Countries
For many U.S. taxpayers, their home is their largest capital asset. Homeowners typically are exempt from paying capital gains taxes on the sale of their homes under the Taxpayer Relief Act of 1997. This act provided an exemption of $250,000 for single taxpayers and $500,000 for married couples who file a joint return. In order to claim this important exemption, you must have lived in your home for two of the last five years, and you can only take the exemption once every two years.
Rules are different in other countries, though. In Australia there’s a six-year rule. Here’s how it works:
- Taxpayers can claim a full capital gains tax exemption for their principal place of residence (PPOR). They also can claim this exemption for up to six years if they moved out of their PPOR and then rented it out. There are some qualifying conditions that have to be met for leaving your principal place of residence, though, such as taking a job overseas, caring for a sick relative, or taking an extended holiday. If you move back into the residence and leave again, the six-year rule is re-established from the date of your last move-out. If you own a property and don’t rent it out, you can take the exemption for longer than six years, the Australian Tax Office notes.
The Bottom Line
Capital gains taxes are determined by the country in which your investment assets are held and are subject to that country’s rules governing capital gains taxation. Consult with tax professionals experienced in domestic and foreign tax policies to determine your potential capital gains tax liabilities for assets held in other countries.
This material is for general information and educational purposes only. Information is based on data gathered from what we believe are reliable sources. It is not guaranteed as to accuracy, does not purport to be complete and is not intended to be used as a primary basis for investment decisions. It should also not be construed as advice meeting the particular investment needs of any investor. Realized does not provide tax or legal advice. This material is not a substitute for seeking the advice of a qualified professional for your individual situation. All investments have an inherent level of risk. The value of your investment will fluctuate with the value of the underlying investments. You could receive back less than you initially invested and there is no guarantee that you will receive any income.
FAQs
The capital gains tax property six-year rule allows you to treat your investment property as your main residence for tax purposes for up to six years while you are renting it out. This means you can rent it out for six years and still qualify for the main residence capital gains tax exemption when you sell it.
What is the 6 year rule for capital gains tax? ›
The capital gains tax property six-year rule allows you to treat your investment property as your main residence for tax purposes for up to six years while you are renting it out. This means you can rent it out for six years and still qualify for the main residence capital gains tax exemption when you sell it.
How long do you have to reinvest money from sale of primary residence? ›
If the home is a rental or investment property, use a 1031 exchange to roll the proceeds from the sale of that property into a like investment within 180 days.13.
What is a simple trick for avoiding capital gains tax on real estate investments? ›
You can avoid paying this tax by using the 1031 deferred exchange or tax harvesting. Alternatively, you can convert your rental property to a primary residence or invest through a retirement account. Don't forget to insure your property with Steadily to avoid making losses after investing in real estate.
Do I pay capital gains when I sell my house and buy another? ›
You can avoid capital gains tax when you sell your primary residence by buying another house and using the 121 home sale exclusion. In addition, the 1031 like-kind exchange allows investors to defer taxes when they reinvest the proceeds from the sale of an investment property into another investment property.
What is the IRS 6 year rule? ›
6 years - If you don't report income that you should have reported, and it's more than 25% of the gross income shown on the return, or it's attributable to foreign financial assets and is more than $5,000, the time to assess tax is 6 years from the date you filed the return.
How many years to stay in a house to avoid capital gains tax? ›
As long as you lived in the property as your primary residence for 24 months within the five years before the home's sale, you can qualify for the capital gains tax exemption. And if you're married and filing jointly, only one spouse needs to meet this requirement.
At what age do you not pay capital gains? ›
The capital gains tax over 65 is a tax that applies to taxable capital gains realized by individuals over the age of 65. The tax rate starts at 0% for long-term capital gains on assets held for more than one year and 15% for short-term capital gains on assets held for less than one year.
Can you roll capital gains into another property? ›
If you're selling an investment property and planning to reinvest the profits into another, it is possible to defer capital gains tax. Under IRS Section 1031, if you reinvest your gains in a 'like-kind' property within 180 days of the sale, you may qualify for a deferral of capital gains tax.
Do I pay capital gains if I reinvest the proceeds from sale? ›
Do I Pay Capital Gains if I Reinvest the Proceeds From the Sale? While you'll still be obligated to pay capital gains after reinvesting proceeds from a sale, you can defer them. Reinvesting in a similar real estate investment property defers your earnings as well as your tax liabilities.
Use a 1031 exchange for real estate
Internal Revenue Code section 1031 provides a way to defer the capital gains tax on the profit you make on the sale of a rental property by rolling the proceeds of the sale into a new property.
How to pay zero tax on capital gains? ›
A capital gains rate of 0% applies if your taxable income is less than or equal to:
- $44,625 for single and married filing separately;
- $89,250 for married filing jointly and qualifying surviving spouse; and.
- $59,750 for head of household.
To limit capital gains taxes, you can invest for the long-term, use tax-advantaged retirement accounts, and offset capital gains with capital losses.
Do I have to pay capital gains tax immediately? ›
It is generally paid when your taxes are filed for the given tax year, not immediately upon selling an asset. Working with a financial advisor can help optimize your investment portfolio to minimize capital gains tax.
What are the two rules of exclusion on capital gains for homeowners? ›
What Are the Two Rules of the Exclusion on Capital Gains for Homeowners? Here's the most important thing you need to know: To qualify for the $250,000/$500,000 home sale exclusion, you must (1) own and occupy the home as your principal residence (2) for at least two of the five years before you sell it.
How do I calculate capital gains tax on sale of a home? ›
Capital gain calculation in four steps
- Determine your basis. ...
- Determine your realized amount. ...
- Subtract your basis (what you paid) from the realized amount (how much you sold it for) to determine the difference. ...
- Review the descriptions in the section below to know which tax rate may apply to your capital gains.
Long-Term Capital Gains Tax: Explained
Owning your home for more than a year means you pay the long-term capital gains tax. After 2 years, you'll qualify for the personal exemption – more on that below. Unlike the seven short-term federal tax brackets, there are only three capital gains tax brackets.
How do I calculate capital gains on sale of property? ›
Subtract your basis (what you paid) from the realized amount (how much you sold it for) to determine the difference. If you sold your assets for more than you paid, you have a capital gain.
What will the capital gains tax be in 2024? ›
For the 2024 tax year, individual filers won't pay any capital gains tax if their total taxable income is $47,025 or less. The rate jumps to 15 percent on capital gains, if their income is $47,026 to $518,900. Above that income level the rate climbs to 20 percent.
