Guides · Jurisdictions
United Kingdom, Spain or the United States: where should a Latin American investor buy?
All three jurisdictions are solvent and all three have a market. The difference lies in the recurring burden and in what happens to the asset over the long run. The United Kingdom has no wealth tax, withholds nothing on dividends and has the widest double taxation treaty network in the world. Spain levies a wealth tax and withholds 3% when a non-resident sells a property. The United States withholds 30% on dividends, withholds on the gross sale price under FIRPTA, and gives a non-resident with no treaty an estate tax exemption of sixty thousand dollars.
The full picture
Every row is a verifiable fact, not an opinion. Where a jurisdiction beats the United Kingdom, the row says so just the same.
| Item | United Kingdom | Spain | United States |
|---|---|---|---|
| Wealth tax | None | Yes, regional, plus solidarity levy | None at federal level |
| Withholding on dividends | 0% | 19% | 30%, reducible by treaty |
| Withholding on a property sale | None at source | 3% of the price | FIRPTA, on the gross price |
| Non-resident capital gains | CGT on the gain | 19% (EU) / 24% (non-EU) | Federal plus state |
| Non-resident succession | £325,000 nil-rate band | Regional, highly variable | 60,000 USD exemption, up to 40% |
| Estate tax treaty with LatAm | Depends on the country | Depends on the country | None |
| Residency for buying a home | Never granted it | Abolished on 3 April 2025 | Does not grant it |
| Double taxation treaty network | The widest in the world | Broad | Broad |
| Foreign buyer's entry cost | SDLT with 5% and 2% surcharges | ITP or VAT depending on the case | Closing costs, no foreigner surcharge |
| Tenancy framework | Predictable national regulation | Rent-pressure zones, varies by region | Highly variable by state |
Checked as at September 2026 against the sources listed at the end. Rates and thresholds change.
Why the United Kingdom comes out well
Not because of any single figure, but because of the recurring burden taken as a whole. There is no wealth tax, so simply holding the asset does not erode the capital year after year — which is the difference that weighs most over a decade. There is no withholding on dividends paid to non-residents and none at source on a sale, unlike Spain's 3% or FIRPTA. And the double taxation treaty network is the widest in the world, which reduces the odds of being taxed twice on the same income and having to claim it back afterwards.
To that you can add what no tax table captures: a public land register in which the state stands behind the title, a deep and professionally run rental market, financing available to non-resident buyers, and a structural housing shortfall that holds demand up. None of that guarantees a return, but it explains why international capital has been choosing this jurisdiction for decades.
And underneath it all, the real reason: there are not enough houses
Tax explains why it is worth holding the asset in the United Kingdom. What explains why the asset works is simpler: England builds less than it needs, and has done so for years.
- Around 209,000 homes a year are completed against an estimated need of 300,000. The annual shortfall is roughly one hundred thousand homes, and it compounds.
- The rental market has about 25% less stock available than before the pandemic, because fewer landlords have come in than have left.
- The average house price is above 280,000 pounds, beyond the long-run affordability ratio in almost every English region, which keeps out of ownership people who would otherwise be first-time buyers. That demand does not disappear: it stays in rented housing.
- Average private rent reached 1,381 pounds a month in April 2026.
A market with a structural shortfall of supply and rental demand sustained by demographics is exactly what a long-horizon investor looks for and rarely finds.
It is the difference between buying into a market that is rising because it is fashionable and buying into one where the scarcity is structural and measured. And it does not depend on the foreign investor: British rental demand is local.
What has just changed in Spain
Spain abolished residency by investment on 3 April 2025, through Organic Law 1/2025. Buying a home no longer grants a residence permit.
This matters more than it looks. For a meaningful share of Latin American capital, European residency was the main reason to buy in Spain; the rental return was never the argument. Without that piece, the comparison stops being between an asset and a passport and becomes one between two real estate assets. That one can be settled with numbers.
And it is worth being precise about a persistent rumour: the surcharge of up to 100% on non-EU non-resident foreign buyers is not in force. It was announced in January 2025, has not been passed into law, and its constitutional and EU-law footing has been questioned publicly. What matters to an investor is not that tax, but the fact that the Spanish tax framework for the foreign buyer is under active political debate.
The fact almost nobody mentions about the United States
A non-resident alien who owns assets situated in the United States has a federal estate tax exemption of sixty thousand dollars. Above that figure the rate reaches 40%, and real estate is a US-situs asset.
The United States has estate tax treaties with sixteen countries, and not one of them is in Latin America.
It is worth seeing this for what it is: a treaty gap, not an isolated quirk. The same pattern shows up in dividends, where the United States withholds 30% when there is no income treaty to reduce it —Mexico and Chile have one, Colombia, Brazil, Peru and Argentina do not—. The United States is not more expensive for everyone: it is more expensive for those without a treaty, and much of the region has none. We go into this in the holding company guide.
No Latin American country has an estate tax treaty with the United States. The Chile–United States treaty that took effect in December 2023 is an income tax treaty, not an estate one. It is an exposure most Latin American buyers of Florida property do not learn about until it is late. There are legitimate ways to mitigate it, but you have to know about it before buying, not after.
Where each one wins
Spain wins on language, cultural proximity, an established community, a lower entry cost and the option of using the property yourself. Someone buying in Málaga to spend three months a year there is not making a worse decision: they are making a different one, on different criteria.
The United States wins on sheer market size, on familiarity, on the availability of financing, and it does not penalise the foreign buyer on entry. One qualification is worth making: it wins on scale. On relative liquidity the United Kingdom holds its own, with around 1,176,000 residential transactions a year in a country of sixty-eight million people, and a public price history transaction by transaction.
The United Kingdom wins on the recurring burden, on the predictability of the framework, on the treaty network and on the imbalance between housing supply and demand. If the aim is to hold a rented asset for a decade in a stable jurisdiction, that combination is what counts, and it is hard to replicate anywhere else.
Related questions
Sources
- GOV.UK and HM Revenue & Customs — SDLT, Non-Resident Landlord Scheme, Capital Gains Tax and Inheritance Tax.
- Agencia Tributaria — Non-Resident Income Tax and the 3% withholding on transfers.
- Boletín Oficial del Estado — Organic Law 1/2025, abolishing the residence permit by investment.
- Internal Revenue Service — Estate tax for nonresidents not citizens of the United States, FIRPTA withholding and Estate and gift tax treaties.
What Acacias does with this
Acacias does not advise on property in Spain or the United States: we work only with British assets. We wrote this comparison because most of our clients arrived considering another jurisdiction and deserved all three sides of the analysis before deciding. If after reading it another jurisdiction is still the right answer for your case, that is a legitimate decision.
General information drawn from the official sources listed at the end. It is not tax, legal or financial advice, nor an invitation to invest. Rates and thresholds change; check against the official source before making a decision. Acacias Capital Ltd is not authorised or regulated by the FCA.