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Guide

How capital gains tax works: the four ways countries tax a gain

Every capital gains tax is one of four designs — a discount, an inclusion rate, a separate rate schedule or a flat rate — plus a few exemptions. Knowing which one you are under explains most of the number.

Published 22 September 2026

A capital gain is the difference between what you sold an asset for and what it cost you. Almost every country taxes that difference, but they do it in strikingly different ways, and the design your country uses matters more to the final bill than the headline rate. Once you know which of the four models applies, the calculator's output stops being a black box.

The gain itself is the same everywhere

Before any rate applies, the gain is worked out the same way almost everywhere:

Losses usually offset gains in the same year, and most countries let an unused loss carry forward to later years. A few restrict which losses can offset which gains — a property loss against a property gain only, for instance — and a few allow no carry-forward at all. The calculator for your country applies its own rule; the Australia calculator nets every loss against every gain, while the India calculator keeps long-term and short-term pools apart.

Model 1: the discount

Some countries tax the gain at your ordinary income-tax rates but let you leave part of it out if you held the asset long enough. The gain is added to your salary and other income, and the marginal bands do the rest.

Australia is the clearest example. An individual who has held an asset for more than twelve months includes only half the gain in taxable income — the 50% CGT discount. A A$40,000 gain becomes A$20,000 of extra income, taxed at whatever marginal rate that income lands in. Hold for less than a year and the whole gain is taxed. Because the tax depends on your other income, the Australia calculator asks for it first.

The same design appears with different fractions elsewhere. What matters is the holding-period test: a day short and the discount is gone.

Model 2: the inclusion rate

Closely related but subtly different: a fixed fraction of every gain is included in income, regardless of how long you held the asset.

Canada includes one-half of a capital gain in taxable income, whether you held the shares for a week or a decade. The included half is then taxed at your combined federal and provincial marginal rate, which is why the Canada calculator asks for your province — the same gain costs a different amount in Alberta and Quebec. A lifetime exemption shelters gains on qualifying small-business shares and farm or fishing property.

The practical difference from a discount: there is no holding-period cliff to plan around, but there is also no way to reduce the fraction.

Model 3: a separate rate schedule

The third design keeps capital gains out of the ordinary income bands entirely and taxes them on their own, usually lower, schedule. Your other income often still matters, because it decides which band of the gains schedule you start in.

The United States taxes long-term gains — assets held more than one year — at 0%, 15% or 20% depending on total taxable income and filing status. Short-term gains are ordinary income. High earners pay an extra 3.8% net investment income tax on top. The United States calculator needs your filing status and other income to place the gain in the right band.

The United Kingdom also runs a separate schedule, with different rates for residential property and everything else, and a lower rate for basic-rate taxpayers. An annual exempt amount takes the first slice of gains out of tax each year; it has been cut sharply in recent years, which pulled many more small investors into filing. The United Kingdom calculator applies the current year's exempt amount and rates.

Spain taxes gains as savings income on its own progressive scale, separate from the general scale for salary. The Spain calculator shows the savings bands and where your gain lands in them.

Model 4: the flat rate

The simplest design: one rate on the gain, no bands, often with a modest annual exemption.

Ireland charges a single flat rate on most gains, with a small annual exemption per person and a long list of reliefs for business assets, retirement and principal private residences. The Ireland calculator applies the exemption and the rate, and separates the two payment deadlines Ireland uses within a year.

Germany taxes gains on shares and funds at a flat withholding rate plus the solidarity surcharge, with a small annual saver's allowance. Property is the exception: sell a property you have held for more than ten years and the gain is tax-free; sell sooner and it is ordinary income. The Germany calculator switches between the two regimes by asset type.

The outliers: no capital gains tax, or a tax on something else

New Zealand has no general capital gains tax. Instead it has targeted rules: the bright-line test taxes residential property sold within a set period of purchase, and anyone who bought an asset with the intention of resale is taxed on the profit as income. The New Zealand calculator is really a bright-line calculator.

The Netherlands does not tax actual gains on savings and investments at all. Box 3 taxes a deemed return on the value of your assets each year, whether or not you sold anything. Gains on a substantial shareholding (5% or more of a company) fall in Box 2 at their own rates. The Netherlands calculator models both boxes.

India sits between the models: listed equity held more than a year is taxed at a concessional long-term rate above an annual threshold, shorter holdings at a higher short-term rate, and property and other assets on their own holding periods. The India calculator sorts each sale into the right pool.

Exemptions that override all four models

Whichever model applies, three exemptions decide more bills than any rate:

  1. Main residence. Almost every country exempts the gain on the home you live in, with conditions — Australia and the UK in full, the US up to a fixed amount, Germany after a residency test. A second home never qualifies.
  2. Annual exemption. The UK, Ireland, Germany and India (for listed shares) take the first slice of each year's gains out of tax. Where the exemption exists it is per person and per year, and unused amounts do not roll over.
  3. Holding period. Australia's discount, the US long-term rate, Germany's ten-year property rule and India's long-term thresholds all turn on one date. Selling a day early is the most expensive mistake in capital gains tax.

Which year does a sale fall into?

The tax year is decided by the contract or trade date, not the settlement or payment date, in most systems. Australia's year runs 1 July to 30 June, the UK's 6 April to 5 April, India's 1 April to 31 March; the US, Canada, Ireland, Germany, the Netherlands and Spain use the calendar year. Every calculator on this site picks the year from your sale date and applies that year's rates, and shows the filing deadline for it.

Using the calculator

Pick your country from the full list, enter each sale with its buy and sell dates and prices, and the calculator applies the model above: it nets losses, tests holding periods, applies exemptions and works out the tax on the year's net gain. Where the tax depends on your other income, it asks for that too and shows the income-tax scale it used. Every rate it applies is read from a dated record of the official source, and the page lists those sources below the calculator.