Tax-free on a $100K share gain (held over 1 year): UAE, Singapore, Switzerland (private), New Zealand. Lowest rates: Hong Kong 0%, Belgium 0% (mostly). Highest: Denmark 42%, Ireland 33%, Germany 26.4%. The US 0/15/20% bracket structure means many earners pay 0%.
You bought $100,000 of shares, sold them for $200,000 a few years later. Same trade, eight different countries: how much of that $100,000 profit do you actually keep? The spread is enormous because every country has different rates, hold-period rules, and exemption regimes.
The headline ranking
Single private investor, $100,000 USD long-term capital gain on listed equity, no other income shifts. Approximate effective rates 2026:
Country
CGT rate
Tax on $100K
You keep
Notes
🇦🇪 UAE
0%
$0
$100,000
No personal income tax
🇸🇬 Singapore
0%
$0
$100,000
No CGT for individuals
🇳🇿 New Zealand
0%
$0
$100,000
No general CGT (some FIF / dealer rules apply)
🇭🇰 Hong Kong
0%
$0
$100,000
No CGT
🇨🇭 Switzerland
0%
$0
$100,000
0% for private investors; cantonal wealth tax separate
🇮🇳 India
12.5% LTCG
$12,500
$87,500
Above ₹1.25L exempt; 1-year hold for listed equity
🇺🇸 USA (0% bracket)
0%
$0
$100,000
If total income under ~$48K single
🇺🇸 USA (15% bracket)
15%
$15,000
$85,000
Most middle earners
🇺🇸 USA (20% bracket)
20% + 3.8% NIIT
$23,800
$76,200
Income over ~$518K single
🇨🇦 Canada
~26.7% (50% inclusion at 53.5% marginal)
~$26,700
$73,300
50% of gain taxed as income; 66.67% on gains over C$250K
🇦🇺 Australia
~22.5% (50% discount at 45% marginal)
$22,500
$77,500
50% discount if held over 12 months
🇬🇧 UK
24%
$24,000
$76,000
£3K annual exempt amount; 18%/24% rates after Oct 2024 Budget
If your total income (including the gain) puts you in the 12% federal bracket or below, your long-term capital gains rate is literally 0%. For 2026 single filers that means total taxable income up to $48,475. A retiree living off $40K of ordinary income can sell $8K of long-term gains tax-free every year. The effective vs marginal tax rate distinction matters here because the 0% applies to the gain that fits inside the bracket; spillover is taxed at 15%.
2. India just fundamentally changed
Until July 23, 2024, India's LTCG on listed equity was 10% above ₹1L. After: 12.5% above ₹1.25L. Indexation for real estate was abolished (with grandfathering for properties bought before 2024). Crypto stays at 30% flat with no setoff and 1% TDS at every transaction.
3. UK doubled CGT in October 2024
Before October 30, 2024: UK CGT was 10%/20%. After: 18%/24%. Annual exempt amount is now £3,000 (was £12,300 just two years ago). For sophisticated investors this means moving share sales below the threshold every year and timing disposals across spouses to use both allowances.
Holding-period rules that flip the answer
Country
Short-term hold
Long-term hold
Rate difference
🇮🇳 India
under 1 year listed equity: 20%
over 1 year: 12.5%
7.5 pp
🇺🇸 USA
under 1 year: ordinary 10-37%
over 1 year: 0/15/20%
up to 22 pp
🇩🇪 Germany
same rate (no holding-period for listed shares)
same
none
🇦🇺 Australia
under 12 months: 100% included
over 12 months: 50% discount
~22 pp
🇩🇪 Germany (crypto)
under 1 year: ordinary income tax
over 1 year: tax-free
up to 45 pp
Germany's rule that crypto held over 1 year is tax-free is one of the most generous in the world. UK and US tax crypto identically to other capital assets.
The principal residence exemption
Almost every country exempts the gain on your primary home (with conditions):
USA: $250K single / $500K married exclusion (lived in 2 of last 5 years)
UK: Principal Private Residence Relief (full exemption while it was your home)
Canada: Principal Residence Exemption (one home per couple per year)
Germany: tax-free if you lived there in the year of sale and the 2 preceding
India: 54/54F provisions allow rolling proceeds into another residential property
Australia: main residence exemption
Singapore: no CGT, no exemption needed
Strategies that move the needle
Tax-loss harvesting - sell losers in the same year as winners to net them off. Limited by wash-sale rules in the US, "bed and breakfasting" rules in the UK.
Year-end gain harvesting - if you have low income in a given year, realize gains into the 0% US bracket or use up annual exempt amounts (UK £3K, Germany €1K Sparer-Pauschbetrag).
Spousal asset transfers - in UK, US, Canada, Germany you can transfer assets to a spouse pre-sale to use their allowance and lower bracket.
Tax-advantaged wrappers - ISA / 401(k) / RRSP / TFSA / SRS shelter the gain entirely, often more powerful than CGT planning. The decision tree in the RRSP vs TFSA vs FHSA stack applies the same logic for Canadians.
Move country before realising - establishing tax residence in a 0%-CGT country (UAE, Singapore, NZ) before you sell is the nuclear option. Watch for "exit tax" rules in the country you're leaving.
The non-obvious winner: middle-income US investor
A single American with $80K wages, $20K of long-term capital gains in 2026: the ordinary income fills the 12% bracket up to $48,475, then the LTCG starts. Because their total income still puts the LTCG into the 0% capital gains band (up to $48,475), and the LTCG sits "on top" but the 0% / 15% threshold for capital gains is its own separate ladder, they pay $0 federal capital gains tax on the first chunk that fits. Worth running through the US capital gains calculator before selling.
Key takeaways
Long-term vs short-term gains: holding period determines the rate, often by 10-30 percentage points.
Tax-loss harvesting can offset realised gains and (in the US) up to $3,000 of ordinary income per year.
Wash-sale rule (US): no buying substantially identical security within 30 days of the loss sale.
Inherited assets get a step-up in basis (US) - pay capital gains only on appreciation after inheritance.
Spouse splitting doubles the UK GBP 3,000 CGT annual allowance.
1031 exchanges defer US real estate capital gains indefinitely; heirs then get a basis step-up.
By audience: what to focus on
Different reader types need different angles on this topic. Pick the one closest to your situation.
Salaried employees
Maximise tax-advantaged retirement contributions (EPF/401(k)/SIPP/RRSP). Check whether your country prefers the old vs new regime, employer-match thresholds, and salary-sacrifice options. Use the calculators below with your CTC / gross income.
Freelancers / self-employed
You bear higher self-employment tax + lose the employer match, but get access to higher contribution limits (Solo 401k, SEP-IRA, NPS Tier-I). Track business expenses meticulously. Quarterly estimated tax payments avoid underpayment penalty.
NRIs / expats
Tax residency rules (183-day, tie-breaker), double-taxation treaties, foreign tax credits all come into play. NRI restrictions on PPF (no new accounts) but expanded options on NPS. Cross-border income often needs specialist advice.
Retirees / pre-retirees
Sequence-of-returns risk in early retirement is the largest threat. Glide-path asset allocation, Roth-conversion analysis in low-income years, Required Minimum Distribution planning, and Medicare/healthcare gap funding (US) are the big items.
Quick reference: 12 specific scenarios
Scan the question list, expand only the rows that match your situation.
What's the difference between short-term and long-term capital gains?
Most countries tax long-term gains (assets held over a threshold) at lower rates than short-term gains. US thresholds: 12 months. UK: no holding period for general CGT. India: 12 months for listed equity, 24 months for property. The holding period change can swing the tax bill by 10-30 percentage points.
Indexation adjusts the purchase price upward by inflation, reducing the taxable gain. Available in India (12.5% LTCG with indexation choice on real estate as of Budget 2024), UK (limited circumstances). The CII (Cost Inflation Index) determines the adjustment factor in India.
What is wash-sale rule and how do I avoid it?
US: selling a security at a loss and buying a 'substantially identical' security within 30 days before or after disallows the tax loss. The loss is added to the cost basis of the replacement security instead. To avoid: wait 31 days OR buy a similar-but-not-identical alternative (e.g., S&P 500 ETF instead of S&P 500 index fund).
How are capital gains on inherited property taxed?
US: stepped-up basis at date of death - heirs pay capital gains only on appreciation after the inheritance date. India: stepped-up basis at date of death with FMV. UK: spouse exemption + step-up. Canada: deemed disposition at fair market value on death (treated as a sale).
Can I offset capital gains with capital losses?
Yes in most countries. Losses can offset gains in the same year. Unused losses typically carry forward indefinitely (US: $3,000/year against ordinary income; UK: only against future gains; India: STCL can offset both STCG and LTCG, LTCL only against LTCG).
What is 1031 exchange (US) and how does it defer capital gains?
Sell an investment property and buy a like-kind replacement within 180 days (with 45-day identification window). The gain is deferred - the basis carries over to the new property. Stack 1031s indefinitely and heirs get a step-up at inheritance, eliminating the deferred tax entirely.
How are crypto capital gains taxed?
In most countries (US, UK, Canada, Australia), crypto is treated as property - every sale, swap, or spending is a taxable event with normal short/long-term rules. India taxes crypto gains at flat 30% with no loss offset against other income, plus 1% TDS on transfers.
What is the annual CGT allowance in the UK?
GBP 3,000 of capital gains per tax year is tax-free (down from GBP 12,300 a few years ago). Spouse splitting doubles the allowance. Above the allowance, basic-rate taxpayers pay 10%, higher-rate 20% on most assets; residential property attracts higher 18%/24% rates.
How do I report capital gains on my tax return?
US: Schedule D + Form 8949. UK: capital gains report or Real-Time CGT online service for property. India: Schedule CG in ITR-2/3 with separate STCG and LTCG sections. Keep cost basis records for at least 7 years after the asset is sold.
Are gains from primary residence sale tax-free?
US: up to $250,000 single / $500,000 MFJ exclusion if owned and lived in the home 2+ of the last 5 years. UK: Private Residence Relief fully exempts the primary home. India: Section 54 lets you reinvest the LTCG into another residential property to defer tax.
How does opportunity zone investment defer capital gains?
US: invest realised capital gains into Qualified Opportunity Funds within 180 days. Original gain deferred until 2026 tax year (or earlier sale). Hold the QOF investment 10+ years and ALL appreciation in the QOF is permanently tax-free.
Should I harvest gains in a low-income year?
Yes. The US 0% long-term capital gains bracket extends to about $47,000 single income. If you have a sabbatical / career break / gap year, you can sell appreciated long-term positions and reset your cost basis to current price for free. Same applies to Roth conversions in low-income years.
Related topics readers also search for
Common adjacent queries on this topic. Each calculator and explainer linked below covers one or more of these specifically.
long term capital gains tax 2026indexation benefit real estate Indiawash sale rule explained1031 exchange like kind propertycapital gains tax UK allowancetax loss harvesting strategystep up basis inherited propertyISO vs NSO tax treatmentcapital gains on inherited homeopportunity zone investment deferral
