Compare countries
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.
| Country | Gain | Estimated tax | Effective rate on the gain | How it is taxed |
|---|---|---|---|---|
| United Kingdom CGT Calculator | £100,000 | £23,280 | 23.3% | 18% within the basic-rate band, 24% above, after the £3,000 allowance |
| United States (federal) CGT Calculator | $100,000 | $15,000 | 15.0% | Long-term rate stacked on income; state tax extra |
| Ireland CGT Calculator | €100,000 | €32,581 | 32.6% | 33% after the €1,270 exemption |
| Australia CGT Calculator | $100,000 | $16,000 | 16.0% | 50% discount, then marginal rates plus 2% Medicare levy |
| Canada (Ontario) CGT Calculator | $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 Calculation Methodology. For the same figures at four income levels, and what changes when the property is your main home, see our analysis on which country charges the lowest capital gains tax on property.
How do the rules differ by country?
| Country | Headline residential rate | Annual exemption | Main-home relief | Reporting deadline |
|---|---|---|---|---|
| UK Capital Gains Tax Calculator | 18% or 24% by band | £3,000 | Private Residence Relief | 60 days |
| US Real Estate Capital Gains Tax Calculator | 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 Capital Gains Tax Calculator | 33% flat | €1,270 per person | Principal Private Residence relief | 15 December or 31 January, by sale date |
| Australia Capital Gains Tax Calculator | 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 Capital Gains Tax Calculator | 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.