The tax you pay when you sell a Golden Visa or citizenship property depends entirely on where it is, and the rules vary more than most investors expect. Greece currently charges no capital gains tax on private property disposals while its suspension remains in force. Portugal and Cyprus tax the gain directly, but with different calculations and reliefs. Spain withholds money from the sale price before your final gain has even been calculated. St Kitts and Nevis is the outlier, where the main issue is usually the citizenship holding period rather than capital gains tax.

This article sets out what UK sellers actually pay, or do not pay, in five common residency and citizenship property markets, and where the timing of a sale matters as much as the country you are selling in.

The quick comparison

Country	Non-resident CGT position	Key relief or mechanism	Timing point to watch
Greece	0% currently for most private sales	15% CGT exists in law but is suspended	Current suspension runs to 31 December 2026
Portugal	50% of the real estate gain is taxable, with the final rate depending on the Portuguese return	Same 50% inclusion now applies to non-residents; pre-1989 property is exempt	New UK-Portugal tax treaty applies from 2026, with UK CGT effects from 6 April 2026
Spain	19% for non-resident sellers	Buyer withholds 3% of the sale price at completion	Refunds of excess withholding can take months
Cyprus	20% flat rate	Indexation allowance for inflation; lifetime exemptions increased in 2026	Main residence relief rarely applies to investment property
St Kitts and Nevis	No CGT issue in a normal CBI exit after the required holding period	CBI real estate must be held for the programme’s minimum period	Seven-year minimum hold for CBI-linked property

Greece: a closing window, not a permanent exemption

Do you pay capital gains tax when you sell Greek property? Not currently, in most private-sale cases. Greece has a 15% capital gains tax written into law for real estate disposals, but it has been suspended repeatedly, and the current suspension runs to 31 December 2026. For a private seller today, the practical rate is 0% on the uplift between what you paid and what you sell for.

That date matters because the suspension is not the same as a repeal. It has been renewed before, but there is no guarantee it will be extended again. If you are weighing up when to sell a Greek Golden Visa property, completing before the end of 2026 removes that particular uncertainty. Selling after that depends on whether Greece renews the suspension again. Our Greece Golden Visa cost guide covers the wider cost picture, and it is worth checking your position against Greek tax residency and the Golden Visa too, since your own tax residence affects more than this one transaction.

One further point: repeated buying and selling can be treated differently from a normal private disposal if the activity looks commercial. That is worth checking before assuming the suspended CGT position tells the whole story.

Portugal: the 2023 reform that evened the playing field

How much capital gains tax do non-residents pay on Portuguese property? Since 2023, non-residents selling Portuguese real estate have benefited from the same 50% capital gains inclusion that applies to residents. In simple terms, only half of the real estate gain is brought into the Portuguese tax calculation, rather than the whole gain being taxed in the way many non-resident sellers previously expected.

The final rate depends on the return, the seller’s wider income position and the Portuguese tax treatment applied, so it should not be treated as a simple blanket 28% charge on the entire gain. Property acquired before 1 January 1989 remains exempt. Main-home reinvestment relief can eliminate or reduce the tax where proceeds are reinvested in another qualifying primary residence in Portugal, the EU or the EEA within the relevant period, but it is of limited use to most Golden Visa investors because the property is rarely their main home.

If your exit involves a fund rather than direct property ownership, the calculation is different again, and our Portugal Golden Visa exit strategy guide and choosing a compliant fund and understanding its risks cover that separately.

A new UK-Portugal double taxation treaty applies in Portugal from 1 January 2026 and for UK capital gains tax from 6 April 2026. Portuguese real estate gains can still be taxed in Portugal, while the UK can tax UK residents on worldwide gains with credit relief for Portuguese tax paid. Worth noting too: if citizenship rather than permanent residency is your goal, the 2026 nationality law changes may affect when you are actually free to sell without disturbing your wider immigration strategy.

Spain: the flat rate and the withholding trap

What tax do you pay selling Spanish property as a non-resident? A flat 19% on the gain. What catches people out is not usually the rate itself, but the mechanics. When a non-resident sells Spanish property, the buyer must withhold 3% of the total sale price at completion and pay it to the Spanish tax authority, even if the seller has made little profit or no profit at all.

That 3% is an advance payment, not the final bill. You then file Modelo 210 for the disposal, calculate the actual gain and either pay the difference or reclaim the excess. The filing window is commonly described as four months from completion, because the formal deadline is three months after the buyer’s one-month withholding period. In practice, refunds can take several months, so factor that gap into cash flow planning if you are relying on the full sale proceeds shortly after completion.

Spain’s own golden visa route for new applicants closed in April 2025, so many Spanish property sellers are now legacy investors exiting a programme that no longer exists for newcomers. Our piece on the best Golden Visa options for UK residents covers the wider market shift.

Cyprus: the same rate for everyone, but check the indexation

Does Cyprus tax non-residents differently on property sales? No. Cyprus applies a flat 20% capital gains tax on gains from Cyprus-situated immovable property, and residency or nationality does not change the rate. What can reduce the bill significantly is indexation, an inflation adjustment applied to the original purchase price using the Cyprus Retail Price Index.

That matters if you bought during the period when Cyprus’s former citizenship-by-investment programme was active, since that scheme closed in November 2020 and many investors are now approaching a natural exit point.

Cyprus also increased key lifetime exemptions in 2026. The main residence exemption rose from €85,430 to €150,000, and the general lifetime exemption rose from €17,086 to €30,000. The main residence relief rarely helps Golden Visa-style investors because it requires the property to have been your primary home for at least five years, but the general allowance and indexation mechanism may still matter. If you are unsure which Cyprus route your existing status falls under, what people actually mean by Cyprus Golden Visa is worth a read, since the terminology is often used loosely and Cyprus’s current investment route is permanent residency rather than citizenship.

St Kitts and Nevis: the outlier where holding period matters most

Do you pay tax when selling St Kitts and Nevis property? In a normal citizenship-by-investment exit after the required CBI holding period, capital gains tax is usually not the issue. The more important question is whether the qualifying real estate has been held for long enough under the citizenship programme.

Citizenship-linked real estate is generally subject to a seven-year holding period before it can be resold under the programme. Selling early is not simply a tax question; it can become a citizenship compliance question. You should also allow for transaction costs, legal fees and any applicable stamp duty or transfer costs. The sequencing that matters most is confirming that the required hold period has run its course before committing to a sale.

Our coverage of the 2026 genuine-link reforms is worth reading alongside this if your citizenship was granted more recently, since the wider compliance landscape around the programme has tightened even where the tax position has not changed.

The one thing all four European sales have in common: your UK return

Selling Greek, Portuguese, Spanish or Cypriot property does not end your tax obligations once the local return is filed. If you are UK tax resident, you generally need to report the disposal to HMRC through Self Assessment, using the capital gains and foreign pages where relevant, by 31 January after the end of the UK tax year in which the sale completed. Current UK capital gains tax rates on residential property are 18% for basic rate taxpayers and 24% for higher and additional rate taxpayers, with a £3,000 annual exempt amount.

Where you have already paid tax locally, whether in Greece, Portugal, Spain or Cyprus, that tax is normally creditable against your UK liability under the relevant double taxation treaty. You should not usually pay twice in full on the same gain, but you can still owe a UK top-up if the UK tax due exceeds the foreign tax paid. This is one area where getting what a Golden Visa solicitor actually does right, and coordinating between your local lawyer and a UK tax adviser, can avoid an unpleasant surprise the following January.

Timing: why “when” matters as much as “where”

Across all five countries, the tax question and the immigration question do not always move on the same clock. Greece’s capital gains suspension has an expiry date that has nothing to do with your Golden Visa renewal cycle. Portugal’s extended citizenship timeline under the 2026 nationality law may affect longer-term planning for investors seeking citizenship, which our guide to the Portugal Golden Visa to citizenship timeline sets out in full. St Kitts ties resale directly to a seven-year hold on the qualifying property, regardless of the capital gains position.

Selling a European Golden Visa property is rarely just a tax decision. It needs checking against your residence renewal schedule, and our renewals guide is a useful starting point if Portugal is your programme.

If you are comparing routes rather than exiting one, it is worth understanding residency by investment versus citizenship by investment before assuming the tax treatment on exit will look similar across programmes. The cost breakdown of a Golden Visa application is also worth reviewing if you are weighing entry costs against what you may eventually pay, or avoid paying, on exit.

If you are planning an exit and comparing what comes next

Investors who have sold a European property sometimes reinvest into a different route entirely rather than buying again in the same country. The Greece Financially Independent Person visa avoids Golden Visa property exposure, as does Italy’s investor visa. For those who would rather diversify outside the EU, Dominica and St Lucia’s citizenship by investment programme offer Caribbean alternatives with their own, generally lighter, tax profiles.

Choosing between them is less about the exit tax alone and more about what you want the next ten years of your residency or citizenship strategy to look like. A Golden Visa lawyer rather than a consultant is worth involving early if you are planning a sale and a new investment at the same time.

Frequently asked questions

Is Greek capital gains tax really zero right now?

Yes, for most private individual sellers. The 15% tax exists in law but is suspended until 31 December 2026. It is a suspension rather than a permanent exemption, so check the position again if you are planning to sell after that date.

Do UK residents pay tax twice when selling European Golden Visa property?

Not normally in full. You will typically pay tax in the country where the property is located first, and that tax is usually creditable against your UK capital gains tax liability. Higher-rate taxpayers can still owe a UK top-up if the UK tax exceeds what was paid abroad.

Can I sell my St Kitts and Nevis property before the seven-year hold ends?

Not without taking advice first. The seven-year holding period applies to qualifying CBI real estate, and selling early can create a citizenship compliance issue even where capital gains tax is not the main concern.

Why is Spain’s 3% withholding different from the actual tax I owe?

The 3% is an upfront collection mechanism applied to the full sale price at completion. Your real liability is 19% of the gain, calculated separately through Modelo 210, with any overpayment reclaimed after review.

If you are weighing up when and where to sell a residency or citizenship property, Coates Global’s immigration lawyers can help you sequence the sale against your visa renewal or citizenship timeline, not just the tax bill. Get in touch before you commit to a completion date.