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 look at how capital gains taxes work in the U.S. and other countries. We will 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 higher in many European countries. In Denmark, for example, the highest 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 do not impose capital gains taxes 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 on 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 selling 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 provides 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 move out of their PPOR and then rent it out. There are some qualifying conditions for leaving your principal place of residence. These conditions include taking a job overseas, caring for a sick relative, or going on 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
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 move out of their PPOR and then rent it out. There are some qualifying conditions for leaving your principal place of residence.
What is the 6 year rule for capital gains tax? ›
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 move out of their PPOR and then rent it out. There are some qualifying conditions for leaving your principal place of residence.
How do I reset my 6 year rule? ›
You have to re-establish the property as your main residence if you want to use the 6-year rule again. This can only be achieved if you move back in, and you consider and make it your main home. Just remember rules and guidelines may change and in 12 years' time there could be different rules in place.
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? ›
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.
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 to avoid capital gains tax over 65? ›
Utilize Tax-Advantaged Accounts: Tax-advantaged retirement accounts, such as 401(k)s, Charitable Remainder Trusts, or IRAs, can help seniors reduce their capital gains taxes. Money invested in these accounts grows tax-free, and withdrawals are not taxed until they are taken out in retirement.
What is an example of the 6 year rule? ›
If you use your former home to produce income (for example, you rent it out or make it available for rent), you can choose to treat it as your main residence for up to 6 years after you stop living in it. This is sometimes called the '6-year rule'.
How to avoid capital gains tax when inheriting property? ›
How to Avoid Paying Capital Gains Tax on Inheritance
- Sell the inherited property quickly. ...
- Make the inherited property your primary residence. ...
- Rent the inherited property. ...
- Disclaim the inherited property. ...
- Deduct selling expenses from capital gains.
How Often Can I Use the Capital Gains Tax Exclusion? If you meet all the requirements for the exclusion, you can take the $250,000/$500,000 exclusion any number of times. But you may not use it more than once every two years.
Capital Gains Tax for People Over 65. For individuals over 65, capital gains tax applies at 0% for long-term gains on assets held over a year and 15% for short-term gains under a year. Despite age, the IRS determines tax based on asset sale profits, with no special breaks for those 65 and older.
Can I sell my house and buy another without paying capital gains? ›
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.
Can I reinvest my capital gains to avoid taxes? ›
Reinvest in new property
The like-kind (aka "1031") exchange is a popular way to bypass capital gains taxes on investment property sales. With this transaction, you sell an investment property and buy another one of similar value. By doing so, you can defer owing capital gains taxes on the first property.
How do I pay zero capital gains tax? ›
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.
When selling a primary residence property, capital gains from the sale can be deducted from the seller's owed taxes if the seller has lived in the property themselves for at least 2 of the previous 5 years leading up to the sale. That is the 2-out-of-5-years rule, in short.
Where should I put money to avoid capital gains tax? ›
Investing in retirement accounts eliminates capital gains taxes on your portfolio. You can buy and sell stocks, bonds and other assets without triggering capital gains taxes. Withdrawals from Traditional IRA, 401(k) and similar accounts may lead to ordinary income taxes.
Who is eligible for the 6 year rule? ›
If you use your former home to produce income (for example, you rent it out or make it available for rent), you can choose to treat it as your main residence for up to 6 years after you stop living in it. This is sometimes called the '6-year rule'. You can choose when to stop the period covered by your choice.
How many years to stay in a house to avoid capital gains tax? ›
You must have lived in the house for at least two years in the five-year period before you sold it. Owning the home isn't enough to avoid capital gains on the sale — the IRS also wants to make sure that you actually intended to live in the house, at least for a certain period of time.
How many years do you have to pay capital gains tax? ›
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.
