Cross-border succession · Selling what you inherited · Information, not legal advice — as at 25 August 2026
Selling an inherited property abroad: the tax picture before you list
Four countries, four completely different answers. Italy: a home acquired by inheritance is generally outside capital-gains tax on resale altogether — whenever you sell (building land is the exception). Spain: the gain above the declared succession value is taxed at a flat 19% for non-resident sellers, the buyer withholds 3% of the price on account, and the town-hall land tax (plusvalía) falls due twice — once on inheriting, once on selling. France: 19% plus social charges — but a UK- or Irish-affiliated seller pays 7.5%, not 17.2% — with reliefs that grow from the date of death and, above €150,000, a mandatory tax representative. Portugal: half the gain is taxed at progressive rates set by your worldwide income, with no withholding — the bill arrives with the next year’s return. In every country the starting point is the value declared in the succession — which is why the inheritance paperwork quietly decides the tax on the later sale.
Families usually ask about the tax on inheriting. The tax that more often surprises them is the one on selling — because it lands months later, at the notary’s table or with the next tax return, out of the sale proceeds. And it turns on a number fixed long before the sale: the value declared when the inheritance was processed. In all four of our countries, that succession value is the seller’s starting value — the gain is measured from it, and the clock runs from the date of death. The inheritance paperwork, done well or badly, quietly decides the tax on the later sale.
Italy — the one where the answer is usually zero
Italy taxes an individual’s property gains only where the property was bought or built within the previous five years — and the statute expressly excludes property acquired by inheritance. The practical result: selling an inherited Italian home generally triggers no Italian capital-gains tax at all — whether you sell after eighteen months or eighteen years. The exception is building land, which is taxable however it was acquired (with an optional flat tax the notaio can settle at the deed). One elegant Italian efficiency worth knowing: the sale deed itself can operate as acceptance of the inheritance, with the notaio recording it — though how you accept is a decision to take deliberately, before touching anything.
Spain — 19%, a 3% retention, and the tax that falls twice
A non-resident seller’s gain — sale price over the declared succession value — is taxed at a flat 19%, and that rate is the same whether you live in Dublin or Doncaster: the higher “general” non-resident rate does not apply to property gains. The mechanics are the memorable part: the buyer must hold back 3% of the full price at completion and pay it to the tax office on account of your tax; you then file to settle the difference — a top-up if 19% of the gain exceeds the retention, a refund if it works the other way (refunds arrive, but unhurriedly). Separately, the town-hall land tax — the plusvalía municipal — falls due twice in an inherit-then-sell sequence: once on the inheritance, and again on the sale for the period since the death; sold soon after, the second bill is usually small. And because the gain is measured from the declared succession value, the value entered at the inheritance stage matters enormously — a point to take proper advice on at the inheritance, not at the sale, particularly where regional inheritance-tax reliefs are generous.
France — two clocks running from the date of death
France taxes the gain at 19%, plus social charges — and here the seller’s social-security affiliation matters: a seller affiliated in the UK or Ireland (or elsewhere in the EU/EEA) is exempt from the main French social contributions and pays a 7.5% solidarity levy instead of 17.2% — 26.5% in total, confirmed by the French administration for UK residents post-Brexit. Two reliefs grow with time, both counted from the date of death: the 19% falls away progressively from year six and disappears after 22 years; the social charge after 30. Two more features are pure France: gains above €50,000 per seller attract a surtax of 2–6% — assessed on each seller’s share, so a property split between two heirs at €50,000 of gain each attracts none — and a UK-resident seller above €150,000 of price must appoint an accredited représentant fiscal (a percentage-of-price fee to budget for; EU/EEA residents are exempt). The notaire computes and deducts the whole tax at the deed — nothing is left to a later return. (And note who does what: the notaire conducts the conveyance itself, and his conveyancing fee is paid by the buyer — as in Italy — so a seller-side lawyer’s fee covers what the notaire does not do for you: aligning the succession with the sale, the seller’s paperwork, and your side of the table.)
Portugal — half the gain, at a rate set by your worldwide income
Since 2023 Portugal taxes resident and non-resident sellers alike: half the gain is brought into Portuguese income tax at progressive rates — and the rate applied to that half is set by reference to your worldwide income, so two heirs selling identical shares can pay different Portuguese tax. The starting value is the one used for the inheritance stamp-duty return — in practice the property’s official tax value at the death — with an inflation adjustment once held beyond two years. There is no withholding at the sale: the full price is paid over, and the tax falls due with the following year’s Portuguese return — so the discipline is to reserve for the bill at completion, not to discover it the next spring. No town-hall gain tax exists on a Portuguese sale.
The home-country half of the picture
A UK- or Irish-resident seller usually faces home-country capital-gains tax on the same sale — measured, broadly, from the property’s value at the date of death, which tends to keep the two computations aligned — with credit for the foreign tax under the relevant treaty so the same gain is not taxed twice. That side belongs to your home tax adviser; what matters here is that the foreign tax paid is documented so the credit can actually be claimed.
Before you list: the three questions that set everything
First, is the title actually ready to sell? A property still registered in the deceased’s name cannot complete — though in all four countries the inheritance step and the sale can be sequenced tightly, sometimes on the same day (Portugal’s undivided-estate trap is the classic blocker). Second, what value did the succession declare? — it is the base for everything above. Third, who exactly is selling? — numbers of heirs change the French surtax, the Spanish filings and everyone’s home-country position. We handle all of this — the sale itself, at a fixed conveyancing fee, in Spain, Italy and France (from January 2027) too — and, where we act on the sale, the sale-year return that follows it. Your home-country tax is not ours: where those numbers need advice we say so plainly and brief a suitable adviser precisely. (Rates and mechanics above are stated as at August 2026 and change with budgets. Where we act on the sale we prepare the French return; your home-country position is for your adviser at home.)