# Universal `--exit` Section — Non-Resident-Seller Withholding & Tax-Clearance-Certificate Completion-Gate Extension

The property-country-side withholding / tax-clearance-certificate instrument a non-resident foreign owner must discharge before the sale can **complete**. Loaded when `--exit` is invoked alongside the per-country sell-side layer in `shared/exit.md`.

**Snapshot**: May 2026.

**Scope**: the base `--exit` section covers sell-side *liquidity, time-on-market, agent commissions, sell-side closing costs*. This doc supplies the orthogonal **completion-gate** layer: the property-country (situs-side) non-resident-disposal **withholding-at-source** and/or **tax-clearance / compliance certificate** that legally gates the deed, the registry entry, or the release of proceeds. It is **not** the buyer's-residence-side tax (that is `--home-tax` — e.g. US §121/§988 on the seller's home-country return) and **not** the keep-or-sell-the-origin-home decision (that is the `--journey=foreign-buyer` sell-vs-rent extension). This is the transactional gate that must be cleared *before the title can transfer*.

## Universal contract

For the property's country, return:

1. **Instrument** — the non-resident-disposal withholding and/or clearance/compliance certificate (named, with statute/form)
2. **Rate + basis** — rate(s), whether on **gross price** or **net gain**, threshold, holding-period bands (sourced + year, else `data not publicly available — verify at <tax authority>`)
3. **Who withholds / collects** — notary/escribano · buyer/payer-as-agent · self-assessment (this determines the failure mode)
4. **Gate point** — does it block the **deed authentication**, the **registry entry**, or only **proceeds release** — and the certificate lead-time if sourced
5. **Verdict band** — 🟢 / 🟡 / 🟠 / 🔴 per the table
6. **Confidence** — HIGH / MEDIUM / LOW per the skill's contract

## The 3 structural models (the analytical spine)

Every jurisdiction's gate resolves to one of three — identifying which is the first task, because the failure mode differs:

- **Model A — Notary/escribano-collected retención that gates the escritura/registry.** Civil-law norm: the notary is the statutory withholding agent and *will not authenticate the deed* (or the registry will not inscribe) until the tax is collected/secured. Failure mode = the conveyance physically cannot complete. (e.g. RO, MX, PY, EC, AR, UY, IT <5yr, AT, CH, ID, PH eCAR.)
- **Model B — Buyer/payer-as-withholding-agent.** The purchaser (or their conveyancer) must withhold a fixed % and remit, on pain of becoming personally liable for the seller's tax. Failure mode = the buyer withholds (often over-withholds) and the seller chases a refund. (e.g. US FIRPTA, AU FRCGW, CA s.116, ES Modelo 211, IE s.980, NZ RLWT, MY RPGTA s.21B, JP, KR, IN s.195, ZA s.35A, CR, BR.)
- **Model C — No non-resident disposal CGT / self-assessment, transfer-tax gate only.** Either no CGT on disposal at all (the clean citable fact — most GCC, HK, SG, MO, several Caribbean) or the non-resident self-assesses post-sale with no completion gate (much of the Nordics, EE, HR, SI, PL, HU, UK NRCGT 60-day return). Failure mode = none at completion, but a later filing obligation + penalties; the *transfer tax / RETT / stamp duty* is a different instrument and must not be conflated with a seller-gains gate.

## Verdict bands

| Band | Trigger | Read |
|---|---|---|
| 🟢 | Model C — no non-resident disposal CGT, OR a fast routine clearance with no material lead-time | "Sale timeline unaffected; confirm the transfer-tax instrument, not a CGT gate." |
| 🟡 | Routine, predictable gate (notary-collected or standard buyer-withholding at a net or modest gross rate) | "Price the cash-flow timing + the certificate lead-time; standard." |
| 🟠 | Gross-basis over-withholding, OR a discretionary lower-rate/cost-basis certificate that must precede payment/deed, OR a multi-week clearance with refund-claim drag | "Mis-timing materially costs the seller; obtain the certificate before listing/payment." |
| 🔴 | Punitive default if a pre-payment/pre-deed certificate is missed, mandatory paid fiscal representative + long lead, or the gate can stall the conveyance for months | "Transaction-structuring issue — engage situs-country tax counsel before listing." |

## ⚠️ 7 cross-cutting traps

1. **The gate blocks COMPLETION, not just tax.** The deed/registry/proceeds are frozen until the certificate issues — AU ATO clearance certificate, IE CG50A, IL *ishur misim*, US Form 8288-B (~90 days), AR AFIP/ARCA certificate (~20 business days). Model the lead-time into the sale timeline, not the tax return.
2. **Resident exemptions usually do NOT apply to a non-resident.** "Primary-residence sales are CGT-free" is a *resident* rule — IL non-residents lose the principal-residence exemption; AU removed the main-residence exemption for foreign residents. Never carry a resident exemption into a non-resident sale.
3. **Withholding is often on GROSS price, not gain** — so it can exceed the real tax: US FIRPTA 15% of amount realized; ZA s.35A on price above threshold; CR 2.5% gross; VN flat 2% gross; PE punitive 30%-of-gross if the cost-basis certificate is not obtained *before any payment*. Over-withholding then needs a refund claim that can take a year.
4. **Who withholds determines the failure mode.** Model A (notary — conveyance can't complete), Model B (buyer liable if they don't), Model C (no gate but later penalties). Misidentifying the model mis-times the entire sale.
5. **A mandatory fiscal representative is a paid third party appointed BEFORE signing** — FR *représentant fiscal accrédité* (non-EU sellers, >€150k); equivalents elsewhere. A frequently-missed cost and lead-time that itself gates the deed.
6. **Transfer tax / RETT / stamp duty ≠ a seller-CGT gate.** Saudi RETT 5%, GCC registration fees, Caribbean stamp duty are transaction taxes, not non-resident-gains withholding. "No CGT" jurisdictions still have a transfer-tax gate — name the correct instrument; do not conflate.
7. **Cost-basis / lower-rate certificates are discretionary, time-boxed, and must precede payment or the deed.** PE SUNAT cost-basis certificate before any payment; IN Form 13 s.197; US 8288-B; AR ~20-business-day lead. Apply late and the punitive default applies irreversibly to that transaction.

## Universal mitigations

Applicable across all 126 countries:

1. **Identify the structural model (A/B/C) first** — it dictates whether the conveyance can stall, who is liable, and what to apply for.
2. **Apply for the clearance / cost-basis / lower-rate certificate before listing or before any payment**, never after — most are pre-deed or pre-payment gated and irreversible if late.
3. **Model the certificate lead-time into the sale timeline** (weeks to ~90 days) so the buyer's withholding obligation does not trigger by default.
4. **Confirm whether withholding is on gross or net** and, if gross, pre-plan the refund-claim path and its duration.
5. **Appoint any mandatory fiscal representative before signing** and price it.
6. **Separate the transfer-tax instrument from the seller-gains instrument** in the brief — both gate, but they are different liabilities.
7. **Engage situs-country tax counsel before listing** wherever the verdict is 🟠/🔴; this section flags the gate, it does not compute the liability.

## Regional patterns

### Western Europe + EFTA + micro-states + UK (R1)

- **ad** Andorra — Non-resident-seller disposal gate: *impost sobre les plusvàlues en les transmissions patrimonials immobiliàries* (**Llei 21/2006**, del 14 de desembre; text refós Decret legislatiu 29/04/2015; Reglament 17/01/2007). For a **non-resident transferor without permanent establishment**, a **5% retenció (pagament a compte)** of the total transfer value is operated as a guarantee at the deed; the excess over the tax actually due is refunded to the transferor within a maximum **6 months** of claim. (Residents get holding-period multiplicative coefficients; non-residents/legal entities do not, so non-residents are taxed on a less favourable base.) The notary handles the retention and the *Registre de la Propietat* inscription follows the plusvàlua liquidation — so it GATES completion. (Govern d'Andorra / Ministeri de Finances — Llei 21/2006, leslleis.com L2006021_TR1, 2015 text refós — confirm current rate at govern.ad.) Most binding completion-gate detail: 5% retention of total transfer value on the non-resident vendor at the deed, refundable within 6 months of claim. CORRECTION: framework statute is **Llei 21/2006** (not "21/2014" — 21/2014 is the Llei de bases de l'ordenament tributari, a different general procedural law); non-resident retention is a fixed **5%**, not a sliding-by-holding-period band.

- **at** Austria — Non-resident-seller disposal gate: real-estate gains are taxed under *Immobilienertragsteuer* (ImmoESt), §30/§30b EStG. The instrument is the **Parteienvertreter (Selbstberechnung)** — the notary/lawyer who draws the deed self-computes and remits ImmoESt at **30%** of the gain (special rate; reduced "Altvermögen" effective rates 4.2%/18% for pre-2002 acquisitions) to the Finanzamt, for residents *and* non-residents, at the latest by the 15th of the second month after the cash flows. Where the Parteienvertreter does not do the Selbstberechnung, a *besondere Vorauszahlung* of 30% is due. This is a withholding-at-completion that GATES the transaction (the Grundbuch *Selbstberechnungserklärung* is needed for registration). (BMF / Bundesministerium für Finanzen, EStG §30b, 2024 — may have changed; rate confirmed 30% special rate.) Most binding completion-gate detail: Grundbuch registration requires the Parteienvertreter ImmoESt self-assessment declaration.

- **be** Belgium — Non-resident-seller disposal gate: gains on Belgian immovable property held short-term by individuals fall under the *meerwaarde / plus-value* regime; the **non-resident income tax** (BNI/INR) return captures the gain, and from 2026 a general capital-gains regime applies. The notary collects all property-related tax debts at deed: the *notaire/notaris* requests fiscal **notification (Art. 433–435 Wetboek Inkomstenbelastingen / kennisgeving)** to the tax administration before passing the deed and must withhold from the price any tax debts the administration flags within the statutory response window — so it GATES completion. Headline non-resident rate cited at ~30.28% on certain gains (FPS Finance, 2026 — may have changed; cross-check, aggregator-influenced). Most binding completion-gate detail: notary's mandatory pre-deed fiscal notification + obligation to retain flagged tax debts from the sale price. (SPF Finances / FOD Financiën, fin.belgium.be.)

- **ch** Switzerland — Non-resident-seller disposal gate: real-estate gains are subject to cantonal **Grundstückgewinnsteuer / impôt sur les gains immobiliers** (purely cantonal/communal, no federal CGT). Same rules for non-residents as residents — tax tracks canton + holding period: ~30–40% for sales within 1–2 years, falling to ~10% after 20+ years' ownership. Crucially the **property itself is liable for the tax (gesetzliches Pfandrecht / statutory lien): if the seller does not pay, the cantonal authority can claim the unpaid gains tax from the BUYER** — so in practice the estimated tax is **deposited with the notary or municipality (Sicherstellung) out of the price** before the *Grundbuch/registre foncier* entry, which is when title legally transfers. This effectively GATES completion (buyer/notary will not release full proceeds nor proceed to registration without the gains-tax securitisation). (Cantonal tax administrations; cantonal statutes govern, e.g. ZH StG §216 ff.; comparis.ch / taxea.ch secondary corroboration, 2026 — confirm canton-specific rate at the cantonal Steueramt.) Most binding completion-gate detail: statutory lien on the property → buyer is secondarily liable, so estimated Grundstückgewinnsteuer is escrowed with notary/municipality before Grundbuch registration transfers title.

- **cy** Cyprus — Non-resident-seller disposal gate: **Capital Gains Tax 20%** on the gain from disposal of Cyprus immovable property (Capital Gains Tax Law N.52/1980), applies to residents and non-residents alike (Cyprus-situs). The completion gate is the **Tax Clearance Certificate, Form N313**, stamped by the Tax Registrar of the Tax Department, plus separate municipal/communal and sewerage clearance certificates — the District Land Registry will NOT transfer/register title to the buyer until these are produced. The seller also pays a 0.40% levy to the Tax Department on the sale price at transfer. Lifetime exemption for all individuals, residents and non-residents alike: general €30,000 for disposals from 1 Jan 2026 (€17,086 to 31 Dec 2025); principal residence €150,000 subject to owner-occupation conditions; overall lifetime cap €150,000 (2026 data, source Cyprus Tax Department). This strictly GATES completion (Land Registry transfer is conditioned on N313). (Cyprus Tax Department, 2026 — may have changed; cross-check rate against Tax Department circular.) Most binding completion-gate detail: Land Registry refuses title transfer absent Form N313 CGT/IPT clearance.

- **de** Germany — Non-resident-seller disposal gate: a non-resident individual selling German real estate within the 10-year speculation period owes German *beschränkte Steuerpflicht* on the *privates Veräußerungsgeschäft* (§22/§23 EStG); after 10 years' holding (or qualifying own-use) it is **tax-free**. Germany has **no general statutory withholding at the notary on individual real-estate sale gains** and **no tax-clearance certificate gating the Grundbuch transfer** for the gain itself — the gain is self-assessed in the non-resident's German income-tax return. Practically, the *Notar* and *Grundbuchamt* do require the *steuerliche Unbedenklichkeitsbescheinigung* from the tax office for **Grunderwerbsteuer (transfer tax, a buyer-side liability)** before registering ownership — that clearance is the buyer/transaction gate, not a seller-CGT gate. So: no non-resident disposal-gain withholding; does NOT gate completion on the seller's gain. (Bundeszentralamt für Steuern / EStG §23, 2024 — may have changed.) Most binding completion-gate detail: no seller-gain clearance; Grunderwerbsteuer-Unbedenklichkeitsbescheinigung gates registration but is buyer-side.

- **dk** Denmark — Non-resident-seller disposal gate: a non-resident's gain on Danish real property is taxable under *begrænset skattepligt* / Ejendomsavancebeskatningsloven (the parcelhusreglen own-home exemption can apply). Denmark operates **no withholding-at-source on the buyer and no tax-clearance certificate gating tinglysning (Land Registry registration)** for the seller's property gain — the gain is self-assessed via the non-resident's Danish return to Skattestyrelsen. So it does NOT gate completion (the digital tinglysning system is not conditioned on a CGT clearance for the vendor's gain). Statute/rate detail for the non-resident band: data not publicly available in concise English primary form — verify at Skattestyrelsen (skat.dk) / Ejendomsavancebeskatningsloven. Most binding completion-gate detail: none — self-assessed; no statutory completion gate on the disposal gain.

- **es** Spain — Non-resident-seller disposal gate: **Modelo 211 — 3% retención** of the agreed sale price, withheld by the BUYER from a non-resident vendor without permanent establishment and paid to AEAT within **one month** of the deed (IRNR, Real Decreto Legislativo 5/2004, art. 25.2 + RD 1776/2004). The buyer issues the non-resident the stamped "ejemplar para el transmitente no residente" copy of Modelo 211; without it the buyer is personally liable, so it functions as a **de facto completion gate** (notary records the retention). The seller then files **Modelo 210** within four months to settle final IRNR (general rate **19%** for EU/EEA, 24% otherwise) and reclaim any 3% over-withheld. The 3% is the binding mechanism. (AEAT — Agencia Tributaria, sede.agenciatributaria.gob.es, 2026 — may have changed; 3% and one-month confirmed.) Most binding completion-gate detail: buyer must withhold 3% and file Modelo 211 within one month or be personally liable for the vendor's IRNR.

- **fi** Finland — Non-resident-seller disposal gate: a non-resident's gain on Finnish real property is Finnish-source *luovutusvoitto* taxed as capital income (30% / 34% over €30,000 band; own-home exemption ≥2 years). Finland has **no buyer-side withholding and no tax-clearance certificate gating the registration of title (lainhuuto) at the National Land Survey** for the vendor's gain — it is self-assessed/declared to Verohallinto. So it does NOT gate completion. (Vero — Finnish Tax Administration, vero.fi "Capital gains in cross-border situations", 2024 — may have changed; rate 30%/34%.) Most binding completion-gate detail: none — self-assessed via Verohallinto; no statutory disposal-gain completion gate.

- **fr** France — Non-resident-seller disposal gate: **prélèvement de l'art. 244 bis A CGI** on the non-resident's gain — flat **19%** (individuals) + social levies (7.5% solidarity for EEA/CH/UK-affiliated; **18.6%** standard for others from 1 Jan 2026 per LFSS 2026). The notary (*notaire*) computes, withholds and remits at the deed; for sellers resident outside the EU/EEA where price > **€150,000** a **représentant fiscal accrédité** must be appointed and the notary will NOT complete/release funds without the représentant's attestation. This is a hard withholding-at-deed that GATES completion. (impots.gouv.fr — DGFiP, CGI art. 244 bis A; 18.6% social rate 2026, LFSS 2026 — confirm current.) Most binding completion-gate detail: notary cannot pass the acte authentique without art. 244 bis A prélèvement settled and (non-EU, >€150k) a représentant fiscal accrédité in place.

- **gr** Greece — Non-resident-seller disposal gate: individual real-estate capital-gains tax (Art. 41 ITC, **15%**) is **SUSPENDED through 31 Dec 2026** (no CGT currently due for resident or non-resident individual sellers). However, the binding completion gate persists: the notary CANNOT draft/complete the transfer deed and the Land Registry/Κτηματολόγιο will not register it until the seller produces a **tax clearance / φορολογική ενημερότητα (no-debt certificate)** plus proof all ENFIA property tax (and any prior-year arrears/penalties) is settled and the property declared in E9; non-residents must keep a Greek AFM. So it GATES completion via the φορολογική ενημερότητα, even while the 15% CGT itself is suspended. (AADE — Independent Authority for Public Revenue, aade.gr "Property capital gains tax (Article 41)", 2026 — CGT suspension to 31 Dec 2026, confirm extension status.) Most binding completion-gate detail: notary/Land Registry require seller's tax-clearance certificate + ENFIA settlement; 15% CGT itself suspended.

- **ie** Ireland — Non-resident-seller disposal gate: **Section 980 TCA 1997** — on disposal of Irish land/buildings the buyer MUST withhold **15%** of the consideration unless the vendor provides a **CG50A capital-gains-tax clearance certificate** from Revenue. Threshold: the withholding bites where consideration exceeds **€500,000** (commercial) or **€1,000,000** (residential); below that no withholding but CG50 still commonly used. A non-resident vendor obtains CG50A only by satisfying Revenue that no CGT arises or the CGT (33% rate) will be paid (often via solicitor undertaking to pay from proceeds). eCG50 issues within ~48 hours where straightforward; Revenue may take up to 35 working days. This GATES completion in practice (no CG50A → buyer withholds 15%). (Revenue.ie — CG50A guidance / Part 42-03-01a, 2025 — may have changed; thresholds €500k/€1m confirmed.) Most binding completion-gate detail: absent CG50A, buyer is legally obliged to withhold 15% of the price under s.980.

- **is** Iceland — Non-resident-seller disposal gate: a non-resident individual's gain on Icelandic real estate is Iceland-source and subject to **capital income tax (22%)**; own-residence relief can apply on reinvestment/holding conditions. The buyer/closing agent is generally required to **withhold tax on payments to non-residents** and the transfer is registered via Þjóðskrá/sýslumaður. Whether a formal seller tax-clearance certificate hard-gates the deed for individual real-estate gains: data not publicly available in concise English primary form — verify at Skatturinn / Iceland Revenue and Customs (skatturinn.is). Treat as: 22% capital-income tax on the Iceland-situs gain, non-resident withholding likely operated by payer — confirm gating mechanics with Skatturinn. Most binding completion-gate detail: non-resident gain is Iceland-taxable at 22%; payer withholding on non-resident — confirm registration-gate at Skatturinn.

- **it** Italy — Non-resident-seller disposal gate: residential-property gain is taxable only if sold **within 5 years** of acquisition (after 5 years fully exempt, all sellers). Within 5 years the vendor may elect at the deed for the **imposta sostitutiva 26%** (Art. 1 c.496 L.266/2005) which the **notaio withholds and remits** on the vendor's behalf — applies to non-residents on Italian-situs property; otherwise the gain goes into IRPEF (23–43%). The notarial election is the withholding mechanism; the rogito will state it. GATES completion only to the extent the notary will not finalise without the option exercised/tax paid where applicable. (Agenzia delle Entrate, L.266/2005 art.1 c.496; 26% confirmed, 2026 — confirm rate.) Most binding completion-gate detail: at the rogito the non-resident elects 26% imposta sostitutiva and the notaio withholds & pays it (only if sold within 5 years; else exempt).

- **li** Liechtenstein — Non-resident-seller disposal gate: real-estate gains are subject to the **Grundstücksgewinnsteuer** (Steuergesetz / SteG) on Liechtenstein-situs property, applying to non-residents. A clearance/payment of the Grundstücksgewinnsteuer to the Steuerverwaltung is required before the *Grundbuch* (Land Registry) entry of the transfer — so it GATES completion. Rate is progressive on the gain (degressive relief by holding period). Exact rate bands/threshold and the certificate name: data not publicly available in concise English primary form — verify at Steuerverwaltung Liechtenstein (stv.llv.li) / Steuergesetz Grundstücksgewinnsteuer. Most binding completion-gate detail: Grundbuch transfer conditioned on Grundstücksgewinnsteuer being settled with the Steuerverwaltung.

- **lu** Luxembourg — Non-resident-seller disposal gate: a non-resident individual's gain on Luxembourg real estate is Luxembourg-source (LIR / loi de l'impôt sur le revenu); speculative gain (held <2 years) taxed at progressive rates, longer holds at half the global rate with allowances. Luxembourg operates **no buyer-side withholding-at-source and no tax-clearance certificate gating the notarial transcription** for the individual seller's real-estate gain — it is assessed via the non-resident's Luxembourg return to the Administration des contributions directes (ACD). So it does NOT gate completion. Rate/holding-period detail: data not publicly available in concise English primary form — verify at Administration des contributions directes (impotsdirects.public.lu) / LIR. Most binding completion-gate detail: none — self-assessed via ACD; no statutory disposal-gain completion gate (notary does not withhold the seller's gain).

- **mc** Monaco — Non-resident-seller disposal gate: Monaco levies **no personal income tax and no capital-gains tax on individuals' real-estate disposals** (no French-nationals exception aside) — there is therefore **no non-resident disposal-gain withholding and no CGT clearance certificate** gating the sale. The transfer is via a Monégasque notaire; the gate that exists is buyer-side registration/transfer duty (*droits de mutation*), not a seller capital-gains instrument. So: no seller-gain instrument; does NOT gate completion on a CGT basis. (Confirm with Direction des Services Fiscaux de Monaco, gouv.mc — no individual CGT, position stable but verify.) Most binding completion-gate detail: none on the seller's gain — Monaco has no individual real-estate CGT; only buyer-side mutation duty at the notaire.

- **mt** Malta — Non-resident-seller disposal gate: **Property Transfer Tax (PTT)** — a **final withholding tax of 8%** of the transfer value (Income Tax Act, Art. 5A), **withheld by the NOTARY at the deed of transfer** and remitted to the Commissioner for Tax & Customs (CfR), for residents and non-residents (reduced rates 2%/5%/10%/12% in defined cases). A non-resident may, by producing to the notary a residence statement from their home tax authority, opt out of the older 12% basis into the relevant regime. Because the notary cannot publish the deed without computing and withholding the PTT, it strictly GATES completion. (PwC Malta / CfR — Income Tax Act Art. 5A; 8% standard PTT confirmed, 2026 — may have changed.) Most binding completion-gate detail: notary withholds 8% final PTT at the deed and cannot publish the transfer without it.

- **nl** Netherlands — Non-resident-seller disposal gate: the Netherlands taxes individuals' property under **Box 3** (deemed-return wealth tax), **NOT a realised capital-gains tax on disposal**, for non-business real estate; a non-resident owning Dutch property has limited Box 3 liability (rate 36% on deemed return, 2026; €59,357 exemption irrelevant to non-resident's Dutch-situs basis). There is **no disposal-gain withholding and no tax-clearance certificate gating the notarial *levering* / Kadaster registration** for an individual's sale gain. So: no realised-gain instrument; does NOT gate completion (transfer tax *overdrachtsbelasting* is buyer-side). (Belastingdienst — Box 3, 2026 — may have changed; pending Box 3 actual-return reform, confirm.) Most binding completion-gate detail: none — NL has no realised CGT on individual property; Box 3 deemed-return only; no completion gate on disposal.

- **no** Norway — Non-resident-seller disposal gate: gain on Norwegian real property is taxable at the flat **22%** general income rate for residents and non-residents (Skatteloven; own-home exemption if owned >1 year and used as residence ≥1 of last 2 years). Norway has **no buyer-side withholding-at-source and no tax-clearance certificate gating the tinglysing (Land Registry) transfer** for the seller's gain — it is self-assessed via the Norwegian tax return to Skatteetaten. So it does NOT gate completion. (Skatteetaten — Norwegian Tax Administration / Skatteloven; 22% confirmed via DLA Piper REALWORLD secondary, cross-check Skatteetaten, 2025 — may have changed.) Most binding completion-gate detail: none — self-assessed at 22%; no statutory disposal-gain completion gate.

- **pt** Portugal — Non-resident-seller disposal gate: real-estate gains by non-resident individuals are reported in the **IRS return Modelo 3 (Anexo G)**; since 1 Jan 2023 non-residents are assessed like residents — **50% of the gain** taxed at progressive IRS rates (up to 48% +solidarity), not the old flat 28%. Portugal has **no buyer-side 3%-type withholding at the deed and no CGT clearance certificate gating the predial registration** for the individual seller's gain — it is self-assessed. A **representante fiscal** is required for non-EU/EEA non-residents (EU/EEA optional). So it does NOT hard-gate completion on the gain (IMT/stamp duty is buyer-side). (Autoridade Tributária e Aduaneira — AT, portaldasfinancas.gov.pt; 50%-inclusion rule since 1 Jan 2023 confirmed, 2025 — may have changed.) Most binding completion-gate detail: none on the gain (self-assessed via Modelo 3 Anexo G); the binding seller obligation is appointing a representante fiscal if non-EU/EEA. CORRECTION: the widely-cited "flat 28% on the whole gain for non-residents" is STALE — repealed effective 1 Jan 2023; now 50% inclusion at progressive rates like residents.

- **se** Sweden — Non-resident-seller disposal gate: a non-resident individual's gain on Swedish real property / tenant-owner apartment is Swedish-source, taxed at an effective **22%** (22/30 of capital-gains tax base) (Inkomstskattelagen). Sweden has **no buyer-side withholding and no tax-clearance certificate gating the lagfart (title registration) at Lantmäteriet** for the seller's gain — it is self-assessed via the Swedish return to Skatteverket (deferral of gain on replacement home possible). So it does NOT gate completion. (Skatteverket — Swedish Tax Agency, skatteverket.se; 22% effective via PwC Tax Summaries secondary, cross-check Skatteverket, 2025 — may have changed.) Most binding completion-gate detail: none — self-assessed at ~22% effective; no statutory disposal-gain completion gate.

- **sm** San Marino — Non-resident-seller disposal gate: San Marino taxes capital gains on real-estate transfers under its general income tax law (Legge 16 dicembre 2013 n.166 IGR and amendments); a non-resident's gain on San Marino-situs property is San Marino-taxable. Whether a buyer/notary withholding or a seller tax-clearance certificate hard-gates the notarial transfer / registry: data not publicly available in concise English primary form — verify at Ufficio Tributario della Repubblica di San Marino (tributario.sm) / Legge n.166/2013. Treat as: real-estate gain taxable on SM-situs basis; gating mechanism (withholding vs self-assessment) unconfirmed. Most binding completion-gate detail: SM-situs real-estate gain is taxable; withholding/clearance-gate mechanics unconfirmed — verify at Ufficio Tributario.

- **uk** United Kingdom — Non-resident-seller disposal gate: **Non-Resident Capital Gains Tax (NRCGT)** — a non-resident MUST file a **UK Property Disposal return and pay estimated CGT within 60 days of completion** (TCGA 1992 as amended; FA 2019 extended to all UK land), whether or not a gain or tax arises. Rates: 18%/24% residential, 18%/24% (or 20% historic) other (2026, confirm bands). The UK uses **no buyer-side withholding and no clearance certificate gating Land Registry registration** — enforcement is the mandatory 60-day return + penalties/interest, NOT a withholding or a completion gate. So it does NOT hard-gate completion (registration proceeds; HMRC enforces via the 60-day filing duty). (HMRC — GOV.UK "Capital Gains Tax for non-residents: UK residential property"; 60-day rule for completions on/after 27 Oct 2021 confirmed, 2026 — confirm rates.) Most binding completion-gate detail: no completion gate / no withholding — mandatory 60-day NRCGT return + payment is the binding obligation, even on a no-gain disposal.

### Central / Eastern Europe + Balkans + Baltics + Caucasus (R2)

- **al** Albania — Non-resident-seller disposal gate: capital gain on immovable property taxed at 15% (individuals: 15% on the gain = sale price − purchase price; companies: gain folded into 15% CIT base). Albanian law historically requires the **15% to be paid before the property-transfer registration at the Immovable Property Registration Agency (ASHK/ZRPP)** and the notary verifies payment of the transfer tax at deed — so a tax/duty-payment step does practically condition registration; the *capital-gains* portion for a non-resident is self-declared and the formal completion-gate certificate mechanism is not confirmable at primary level. Rate 15%; threshold none stated. (General Directorate of Taxes / PwC, 2026 — https://taxsummaries.pwc.com/albania/individual/income-determination ; verify completion-gate detail at General Directorate of Taxes Albania, https://www.tatime.gov.al). Most binding completion-gate detail: notary will not authenticate / ASHK will not register the transfer until the property-transfer tax is paid (capital-gains self-assessment by the non-resident sits alongside, not as the gate).

- **am** Armenia — Non-resident-seller disposal gate: gain of a non-resident from Armenian immovable property generally taxed at 10% (non-resident income tax / 10% on the gain for individuals; 20% CIT base for companies on net gain). Armenia operates a **withholding model where the Armenian payer (buyer) acting as tax agent withholds tax on income paid to a non-resident** (PwC: capital gains listed among non-resident WHT income at 10%) — so where the buyer is an Armenian tax agent the 10% is withheld at source; a tax-clearance certificate explicitly gating cadastre registration is not confirmable at primary level. Rate 10%; threshold none stated. (State Revenue Committee / PwC, 2026 — https://taxsummaries.pwc.com/armenia/corporate/withholding-taxes ; verify at State Revenue Committee of Armenia, https://src.am/en). Most binding completion-gate detail: 10% withheld by the Armenian buyer/payer as tax agent when the buyer is an Armenian entity; otherwise non-resident self-declares (no confirmed registry block).

- **az** Azerbaijan — Non-resident-seller disposal gate: data not publicly available at primary level for the *completion-gate* mechanism — verify at the State Tax Service under the Ministry of Economy of Azerbaijan. Baseline: a non-resident's gain on Azerbaijani immovable property is Azerbaijani-source income; the Tax Code generally subjects non-resident Azerbaijani-source income not attributable to a PE to **withholding by the local payer**, and gains on immovable property are taxable (individual rate band / 20% CIT for companies). Whether a notary or the State Register of Immovable Property blocks registration pending tax payment is not confirmable from primary sources. Rate: per Tax Code (non-resident WHT / 20% CIT); threshold none confirmed. (State Tax Service of Azerbaijan — data not publicly available; verify at https://www.taxes.gov.az). Most binding completion-gate detail: data not publicly available — verify at the State Tax Service of Azerbaijan.

- **ba** Bosnia and Herzegovina — Non-resident-seller disposal gate: foreign residents taxable only on B&H-source income; immovable-property gains are B&H-source. Tax is entity-level and fragmented across the two entities + Brčko District (Federation of B&H, Republika Srpska, Brčko) — each with its own income/profit-tax law (typically 10% PIT / 10% CIT on the net gain). No single nationwide **withholding-at-source or clearance-certificate completion gate** for non-resident sellers is confirmable at primary level; gain is generally self-assessed/declared and the property is registered through the relevant entity Land Registry book. Rate ~10% PIT or 10% CIT (entity-dependent); threshold none confirmed. (Indirect/Direct Tax Authorities of the FBiH & RS / Ecovis, 2026 — https://global.ecovis.com/bosnia-and-herzegovina/tax-guide/ ; verify at Federation Tax Administration https://www.pufbih.ba and RS Tax Administration https://www.poreskaupravars.org). Most binding completion-gate detail: no confirmed nationwide completion gate; non-resident self-declares to the competent entity tax administration — verify the entity-specific rule (FBiH / RS / Brčko).

- **bg** Bulgaria — Non-resident-seller disposal gate: capital gain of a non-resident individual on Bulgarian real estate taxed at **10% FINAL withholding tax** on the positive difference between sale price and acquisition price, **reduced by a statutory 10% deemed-cost deduction** (Personal Income Tax Act). For non-resident companies, a 10% WHT on the gain (Corporate Income Tax Act). It is a *final WHT* in form; in practice the non-resident (or its representative) declares and remits — there is no confirmed notary-collected advance, but the notarial deed and entry in the Property Register run through a Bulgarian notary who checks local-tax/charge clearance on the property. Whether the CGT itself formally gates the Property Register entry is not confirmed at primary level. Rate 10% (on gain less 10% deemed cost); threshold none. (National Revenue Agency / PwC, 2026 — https://taxsummaries.pwc.com/bulgaria/individual/income-determination ; verify at National Revenue Agency, https://nra.bg). Most binding completion-gate detail: 10% final WHT on gain (10% statutory cost deduction); notarial property-charge clearance is the practical gate, CGT-as-registration-gate not confirmed — verify with the National Revenue Agency.

- **cz** Czech Republic — Non-resident-seller disposal gate: non-residents taxed the same as residents — gain on Czech immovable property is Czech-source income in the income-tax base (individuals progressive 15%/23%; companies 21% CIT), **self-assessed via tax return; no general CGT withholding at the deed and no tax-clearance certificate gating the cadastre (Katastr nemovitostí) entry**. The one securing mechanism: under the Income Taxes Act a Czech payer/buyer must apply a **tax-securing deduction (zajištění daně, typically 1% for individuals / 10% rules) when paying a non-resident from OUTSIDE the EU/EEA** for certain Czech-source income including disposals — this is a securing remittance, not a registration gate. Rate: PIT 15%/23% or CIT 21% on the gain; tax-securing 1% (non-EU/EEA payer-side); threshold none. (Financial Administration / RSM / PwC, 2026 — https://rsm.cz/en/what-we-offer/advisory/taxes/real-estate-tax-guide/selling-and-transferring-czech-real-estate/ ; verify Income Taxes Act §38e at Financial Administration of the Czech Republic, https://www.financnisprava.cz). Most binding completion-gate detail: NO completion gate — cadastre registration is not blocked; only a payer-side tax-securing deduction applies where the buyer pays a non-EU/EEA non-resident.

- **ee** Estonia — Non-resident-seller disposal gate: gain of a non-resident on Estonian real estate (or shares of a real-estate-rich company, ≥50% Estonian RE within 2 yrs) taxed at **22% income tax (income derived from 01.01.2025; 20% before)**, **self-assessed on Form V1 Table 3.1 by 30 April of the following year, tax paid by 1 October — NO withholding at source by notary or buyer, and NO tax-clearance certificate gating the Land Register (kinnistusraamat) entry**. The Estonian Tax and Customs Board documentation explicitly describes self-declaration with no point-of-sale deduction. Rate 22% (from 2025); base = gain − acquisition cost − transfer cost; threshold none. (Estonian Tax and Customs Board, 2026 — https://www.emta.ee/en/private-client/foreigner-non-resident/non-residents/gains-transfer-property). Most binding completion-gate detail: NO completion gate — non-resident self-declares on Form V1; notary does not withhold and the Land Register entry is not blocked.

- **ge** Georgia — Non-resident-seller disposal gate: data not publicly available at primary level for the *completion-gate* mechanism — verify at the Georgia Revenue Service. Baseline: a non-resident's gain on Georgian immovable property is Georgian-source; the Tax Code generally taxes individuals at 5% on income from sale of immovable property held <2 years (0% if held ≥2 years and not used in economic activity) and 15% CIT-equivalent for companies. Whether the Public Registry (NAPR) blocks registration pending tax payment, or the buyer withholds, is not confirmable from primary sources. Rate: 5% individual (sale of RE held <2 yrs; 0% if ≥2 yrs) / 15% corporate; threshold = 2-year holding for the 0% individual case. (Revenue Service of Georgia — completion-gate data not publicly available; verify at https://www.rs.ge). Most binding completion-gate detail: data not publicly available — verify whether NAPR registration is conditioned on tax payment with the Georgia Revenue Service.

- **hr** Croatia — Non-resident-seller disposal gate: gain on disposal of Croatian real estate within **2 years of acquisition** taxed (individuals) at the higher municipal income-tax rate (commonly cited effective ~24%; exempt if held >2 years, or if it was the seller's residence / a single annual disposal etc.); companies fold the gain into CIT (10%/18%). Treated the same for non-residents subject to DTTs. **Gain is self-assessed/declared to the Tax Administration (Porezna uprava) by the non-resident — no notary-collected CGT advance and no tax-clearance certificate gating the Land Registry (zemljišne knjige) entry**; the property-transfer-tax / VAT clearance is the routine notarial check, not CGT. Rate ~24% individual (≤2-yr holding) / 10%–18% CIT; threshold = >2-year holding exemption. (Tax Administration / Invest Croatia / RSM, 2026 — https://investcroatia.gov.hr/en/tax-system/ ; verify at Porezna uprava, https://www.porezna-uprava.hr). Most binding completion-gate detail: NO CGT completion gate — non-resident self-declares; only the 3% real-estate-transfer-tax / VAT is checked by the notary before registration.

- **hu** Hungary — Non-resident-seller disposal gate: gain of a non-resident individual on Hungarian real estate taxed at **15% personal income tax**, with a statutory time-decay base reduction (full base years 0–5, then declining to 0% after the 5th year for residential; the reduction schedule per the Personal Income Tax Act). For non-resident companies there is **no withholding tax** on the gain; it is assessed in the CIT base or self-assessed. **Gain is self-assessed by the non-resident (annual PIT return); no notary-collected CGT withholding and no tax-clearance certificate gating the Land Registry (ingatlan-nyilvántartás) entry** — the notary/lawyer countersigns the deed and the transfer-duty (illeték, buyer-side) is the routine charge. Rate 15% PIT (with holding-period base reduction) / CIT base for companies; threshold = base phases to 0% after 5 years (residential). (National Tax and Customs Administration (NAV) / PwC, 2026 — https://taxsummaries.pwc.com/hungary/individual/income-determination ; verify at NAV, https://nav.gov.hu). Most binding completion-gate detail: NO completion gate — non-resident self-declares 15% PIT on the (time-decayed) gain; no notary withholding, registration not blocked.

- **lt** Lithuania — Non-resident-seller disposal gate: gain of a non-resident on Lithuanian immovable property is Lithuanian-source, taxed at **15%** (individuals 15% PIT on the gain, with a >10-year-holding residential exemption and certain principal-residence relief; companies 15% CIT). For payments to foreign entities on Lithuanian real-estate income a **15% withholding can apply at source via the Lithuanian payer**; for individuals the gain is generally self-declared. No tax-clearance certificate gating the Real Property Register (Registrų centras) entry is confirmed at primary level. Rate 15%; threshold = >10-year holding exemption (residential, individuals). (State Tax Inspectorate (VMI) / PwC, 2026 — https://taxsummaries.pwc.com/lithuania/individual/income-determination ; verify at Valstybinė mokesčių inspekcija, https://www.vmi.lt). Most binding completion-gate detail: 15% may be withheld by a Lithuanian corporate payer; individual non-resident self-declares — no confirmed registry-entry gate (verify with VMI).

- **lv** Latvia — Non-resident-seller disposal gate: non-resident's gain on Latvian real estate (capital asset) taxed under the personal-income-tax capital-gains regime — **the VID primary page states the general capital-gains PIT rate is currently 25.5%** (rate raised; the older 20% capital-gains rate no longer applies — re-verify the non-resident-specific rate). The distinctive source mechanism: **where the buyer is a Latvian-registered economic-activity performer (business/entity), that buyer withholds 3% of the GROSS consideration as an advance tax on the non-resident's disposal** (Latvian PIT law) — the non-resident may then file to apply DTT treatment / actual-gain taxation; where the buyer is a private individual there is no withholding and the non-resident self-declares. No separate tax-clearance certificate gating the Land Book (zemesgrāmata) entry is confirmed; the 3% buyer-withholding is the source mechanism. Rate: capital-gains PIT 25.5% (general, per VID 2026) on the gain, OR 3% of gross consideration withheld by a business buyer; threshold none. (State Revenue Service (VID), 2026 — https://www.vid.gov.lv/en/income-tax-capital-gains ; verify non-resident rate at Valsts ieņēmumu dienests, https://www.vid.gov.lv). Most binding completion-gate detail: a Latvian business buyer must withhold 3% of the gross price from a non-resident seller as advance tax (no withholding if buyer is a private individual; no separate Land Book clearance certificate confirmed).

- **md** Moldova — Non-resident-seller disposal gate: Moldova has **no separate capital-gains tax**; a portion (currently 50%) of the capital gain on disposal of property is included in taxable income and taxed at the flat individual rate (12%), so effective ≈6% on the gain for individuals; non-resident companies 12% CIT on the included portion. Moldova taxes non-resident Moldovan-source income generally **by withholding through the payer**; for an individual buyer there is typically no withholding and the non-resident self-declares. A tax-clearance certificate gating the Real Estate Register (cadastre) entry is not confirmed at primary level. Rate: 12% on 50% of the gain (≈6% effective) individuals / 12% CIT on included portion; threshold none confirmed. (State Tax Service / PwC, 2026 — https://taxsummaries.pwc.com/moldova/individual/taxes-on-personal-income ; verify at Serviciul Fiscal de Stat, https://sfs.md). Most binding completion-gate detail: no separate CGT and no confirmed registry gate — 50% of the gain enters the 12% income base, non-resident self-declares (or payer withholds where the buyer is a withholding agent) — verify with the State Tax Service.

- **me** Montenegro — Non-resident-seller disposal gate: a non-resident's capital gain on Montenegrin immovable property is Montenegrin-source; under the profit-tax law **income paid to a non-resident (including capital gains) is within scope of withholding tax**, and a non-resident must prove treaty residence + beneficial ownership to access reduced DTT rates. Headline gain rate ~15% (individual CGT) / corporate profit-tax band on the gain. Whether the Real Estate Administration (Uprava za nekretnine) cadastre conditions registration on tax payment, or the buyer/notary withholds, is not confirmable at primary level. Rate ~15% (individual capital gains) / corporate profit-tax band; threshold none confirmed. (Tax Administration of Montenegro / KPMG / GSL, 2021–2026 — https://assets.kpmg.com/content/dam/kpmg/rs/pdf/2021/09/guide-to-taxes-on-real-estate-in-montenegro.pdf ; verify at **Poreska uprava Crne Gore** (Montenegro Tax Administration), https://www.gov.me/poreskauprava (English: https://www.gov.me/en/poreskauprava) (2026-09-18 verified)). Most binding completion-gate detail: capital gain to a non-resident is within the WHT scope under the profit-tax law (treaty residence + beneficial-ownership proof needed for relief); whether cadastre registration is blocked is not publicly confirmed — verify with the Montenegro Tax Administration.

- **mk** North Macedonia — Non-resident-seller disposal gate: data not publicly available at primary level for the *completion-gate* mechanism — verify at the Public Revenue Office (UJP) of North Macedonia. Baseline: a non-resident's gain on Macedonian real estate is Macedonian-source; the Personal Income Tax Law taxes capital gains on immovable property (individuals: flat 10% PIT on the gain (PIT Law Art. 11; 15% applies only to gambling winnings); base = sale − purchase price with 10% normed costs only for property lived in ≥1 yr (Art. 60); exempt after 5 yrs of ownership, or after 3 yrs if lived in ≥1 yr, or on first-order inheritance (Art. 63) — 2023 data, source UJP consolidated PIT Law 274/2022) and 10% CIT for companies. Whether the Cadastre (Agencija za katastar na nedvižnosti) blocks registration pending tax payment, or the notary withholds, is not confirmable from primary sources. Rate 10% individual (flat PIT; exemptions per Art. 63) / 10% CIT; threshold = holding-period exemption (5 yrs, or 3 yrs if lived in ≥1 yr). (Public Revenue Office of North Macedonia — completion-gate data not publicly available; verify at https://www.ujp.gov.mk). Most binding completion-gate detail: data not publicly available — verify whether Cadastre registration is conditioned on tax payment with the UJP (Public Revenue Office).

- **pl** Poland — Non-resident-seller disposal gate: gain of a non-resident on Polish real estate is Polish-source, taxed at **19%** (individuals: 19% PIT on the gain if disposed within **5 calendar years from the end of the year of acquisition**; exempt if held longer, or with the housing-purpose relief; companies 19% CIT). **Self-assessed by the non-resident (PIT-39 by 30 April of the following year); no notary-collected CGT withholding and no tax-clearance certificate gating the perpetual-usufruct / Land and Mortgage Register (księgi wieczyste) entry** — the notary is the PCC transfer-tax remitter (buyer-side), not a CGT collector. Rate 19%; threshold = 5-year holding exemption (counted from year-end of acquisition). (National Revenue Administration (KAS) / PwC, 2026 — https://taxsummaries.pwc.com/poland/individual/income-determination ; verify at Krajowa Administracja Skarbowa, https://www.podatki.gov.pl). Most binding completion-gate detail: NO CGT completion gate — non-resident self-declares on PIT-39 within the 5-year window; notary handles only buyer-side PCC, Land & Mortgage Register entry not blocked.

- **ro** Romania — Non-resident-seller disposal gate: **the strongest true completion gate in this set, primary-mechanism confirmed.** On transfer of immovable property the **public notary computes and CHARGES the seller's income tax, the tax is payable to the notary BEFORE the transfer agreement is authenticated, and the notary is legally required to collect the 1%/3% and remit it to the state — so without payment the deed is not authenticated and cannot be entered in the Land Book / Cartea Funciară** (Romanian Fiscal Code, immovable-property-transfer income-tax rules). For non-resident individuals: **3% on the amount exceeding RON 450,000 if the property was owned <3 years; 1% on the amount exceeding RON 450,000 if owned ≥3 years** (RON 450,000 non-taxable amount deducted from transaction value, per transfer). Non-resident corporate entities: 16% on the gain; non-resident natural persons under the general rule may fall to 10% by DTT — but the notary-collected 1%/3% transfer income tax is the operative at-deed gate. Rate: individuals 1%/3% on value over RON 450,000 (holding ≥/ <3 yrs); companies 16% on gain; threshold RON 450,000 per transfer. (National Agency for Fiscal Administration (ANAF) / DLA Piper / PwC Romania, 2026 — https://www.dlapiperrealworld.com/law/index.html?t=taxes&s=tax-on-disposals&c=RO ; verify Fiscal Code at ANAF, https://www.anaf.ro). Most binding completion-gate detail: the notary is **legally required to collect the transfer income tax and the tax must be paid to the notary before the deed is authenticated** — no authentication → no Land Book registration. Hard, primary-confirmed registration gate.

- **rs** Serbia — Non-resident-seller disposal gate: capital gain of a non-resident on Serbian real estate taxed at **15%** (sale/transfer of the right of ownership to real estate). The non-resident **must appoint a fiscal representative in Serbia, who files a capital-gains tax return within 30 days of realising the gain; the Tax Administration then issues a decision assessing the liability**, and a tax-residency certificate (Ministry-of-Finance form, stamped by the home tax authority) is needed to apply DTT relief. This is post-deed self-assessment via the fiscal representative — not a notary-withheld advance. Whether the Real Estate Cadastre (RGZ) registration is formally blocked pending the tax decision is not confirmed at primary level (registration generally proceeds; the 30-day return is the obligation). Rate 15%; threshold = 10-year holding exemption available to residents (not the non-resident gate). (Tax Administration of Serbia / PwC, 2026 — https://taxsummaries.pwc.com/serbia/individual/income-determination ; verify at Poreska uprava, https://www.purs.gov.rs). Most binding completion-gate detail: non-resident must appoint a Serbian fiscal representative who files the CGT return within 30 days of the gain; assessment is by Tax Administration decision (no notary withholding; cadastre block not confirmed).

- **si** Slovenia — Non-resident-seller disposal gate: gain on Slovenian real estate taxed (individuals) on a **holding-period sliding scale: 25% (0–5 yrs), 20% (5–10 yrs), 15% (10–15 yrs), 0% (>15 yrs)** as a final/schedular capital tax; companies fold the gain into 19% CIT. Treated the same for non-residents subject to DTTs. **Gain is self-assessed/declared to the Financial Administration (FURS) by the non-resident — no notary-collected CGT advance and no tax-clearance certificate gating the Land Register (zemljiška knjiga) entry**; the 2% real-estate-transfer-tax clearance (or VAT) is the routine notarial check, not CGT. Rate 25%/20%/15%/0% by holding period (individuals) / 19% CIT; threshold = 0% after 15 years' holding. (Financial Administration of Slovenia / PwC, 2026 — https://taxsummaries.pwc.com/slovenia/individual/income-determination ; verify at FURS, https://www.fu.gov.si). Most binding completion-gate detail: NO CGT completion gate — non-resident self-declares on the FURS holding-period scale; only the 2% real-estate-transfer-tax / VAT is checked by the notary before Land Register entry.

- **sk** Slovakia — Non-resident-seller disposal gate: non-resident's gain on Slovak immovable property is Slovak-source, taxed in the income-tax base — individuals at **19%/25% PIT** on the gain (exempt if the property was held **>5 years**, or principal-residence reliefs); companies 21% CIT. **Self-assessed by the non-resident via the Slovak income-tax return; no notary-collected CGT withholding and no tax-clearance certificate gating the cadastre (kataster nehnuteľností) entry.** As in Czechia, a payer-side tax-securing (zabezpečenie dane) can apply where a Slovak payer pays a non-resident from outside the EU/EEA — a securing remittance, not a registration gate. Rate 19%/25% PIT or 21% CIT on the gain; threshold = >5-year holding exemption (individuals). (Financial Administration of the Slovak Republic / PwC, 2026 — https://taxsummaries.pwc.com/slovak-republic/individual/income-determination ; verify Income Tax Act at Finančná správa SR, https://www.financnasprava.sk). Most binding completion-gate detail: NO completion gate — non-resident self-declares (>5-yr holding exemption); cadastre entry not blocked; only a payer-side tax-securing applies for non-EU/EEA payee payments.

### Levant + GCC + Türkiye + Israel (R3)

- **ae** United Arab Emirates — Non-resident-seller disposal gate: NO personal capital-gains tax and NO non-resident disposal withholding on real-estate sale proceeds for individuals selling in a personal (non-business) capacity; there is no income tax on individuals, so no clearance certificate gates completion. Separate instrument (do not conflate): a property-transfer/registration fee (~4% of value in Dubai, payable to the Dubai Land Department on registration of the transfer to the buyer) — this is a transfer duty on the transaction, not a seller-gains withholding. Note: foreign juridical persons (non-resident companies) may fall under UAE corporate tax (Federal Decree-Law No. 47 of 2022) on UAE real-estate gains — that is an entity-level corporate-tax matter, not an individual-seller withholding gate. GATES completion? NO (no seller-CGT/clearance gate for individuals; transfer fee is the only registration condition) (PwC Worldwide Tax Summaries — UAE Individual Other Taxes, 2025/2026, https://taxsummaries.pwc.com/united-arab-emirates/individual/other-taxes; Dubai Land Department, verify at https://dubailand.gov.ae). Most binding completion-gate detail: no seller tax-clearance exists; the only registration condition is payment of the ~4% DLD transfer fee, which is a transaction/transfer duty, not a non-resident disposal-gains withholding.

- **bh** Bahrain — Non-resident-seller disposal gate: NO personal income tax, NO capital-gains tax and NO withholding tax in Bahrain; consequently NO non-resident-seller disposal withholding and NO tax-clearance certificate gating the sale/transfer of real estate. Separate instrument (do not conflate): a property-registration fee is payable to the Survey & Land Registration Bureau (SLRB) on registering the transfer — a registration duty on the transaction, not a seller-gains withholding. GATES completion? NO (no seller-CGT/clearance gate exists) (PwC Worldwide Tax Summaries — Bahrain, 2025/2026, verify at https://taxsummaries.pwc.com/bahrain; Survey & Land Registration Bureau, verify at https://www.slrb.gov.bh). Most binding completion-gate detail: with no CGT/income tax/withholding in the system there is no seller tax-clearance to obtain; SLRB registration-fee payment is the only registration condition and is a transfer duty, not a disposal-gains withholding.

- **il** Israel — Non-resident-seller disposal gate: YES — Land Appreciation Tax / "mas shevach" applies to non-residents on the real gain from disposal of Israeli real estate at 25% for assets acquired from 1 Jan 2012 (linear/proportional rate split around 1 Jan 2014 for older holdings); non-residents are generally NOT entitled to the principal-residence exemption. The sale must be reported to the Israel Tax Authority within 40 days of the contract and tax paid within ~60 days. Critically, the Land Registry (Tabu / Lishkat Rishum Mekarke'in) will NOT register the transfer to the buyer until tax clearances/certificates have been submitted to Tabu — i.e., an Israel Tax Authority approval/clearance ("ishur misim") confirming mas shevach (and purchase tax) is settled or secured is a hard prerequisite to title transfer; in practice the buyer/escrow withholds proceeds until the seller produces the clearance. GATES completion? YES — title cannot pass to the buyer at Tabu without the Tax Authority clearance (Real Estate Taxation (Appreciation and Acquisition) Law, 5723-1963 — verify exact section at Israel Tax Authority; PwC Worldwide Tax Summaries — Israel Individual Other Taxes, 2025/2026, https://taxsummaries.pwc.com/israel/individual/other-taxes; Israel Tax Authority, verify at https://www.gov.il/en/departments/israel_tax_authority). Most binding completion-gate detail: Tabu registration of the transfer to the buyer is legally blocked until the Israel Tax Authority clearance certificate (mas shevach + purchase tax settled/secured) is filed — a true completion gate, with buyer/escrow withholding sale proceeds pending it.

- **jo** Jordan — Non-resident-seller disposal gate: As a general rule there is NO personal capital-gains tax on disposal of real estate by individuals under the Income Tax Law No. 34 of 2014 (capital gains are generally exempt except depreciable assets and defined share/business cases), so there is no general non-resident disposal CGT-withholding on a private real-estate sale. Separate instrument (do not conflate): Jordan levies real-estate registration/sale fees collected by the Department of Lands and Survey (Dā'irat al-Arāḍī wa al-Misāḥa) on registering the transfer — a registration/transfer duty on the transaction, not a seller-gains withholding. Whether the Department of Lands & Survey conditions registration on any tax clearance for non-residents is not clearly evidenced in public primary sources. GATES completion? Effectively NO for a seller-CGT gate (no general individual real-estate CGT); registration is gated by payment of DLS transfer/registration fees — data on any additional non-resident clearance not publicly confirmed — verify at Income & Sales Tax Department / Department of Lands and Survey (Income Tax Law No. 34 of 2014; PwC Worldwide Tax Summaries — Jordan Individual Income Determination & Other Taxes, 2025/2026, https://taxsummaries.pwc.com/jordan/individual/income-determination; Department of Lands and Survey, verify at https://www.dls.gov.jo; Income & Sales Tax Department, https://istd.gov.jo). Most binding completion-gate detail: no general individual real-estate CGT to clear; the operative registration condition at the Department of Lands & Survey is payment of land registration/transfer fees (a transfer duty, not a disposal-gains withholding) — any extra non-resident tax-clearance step is not publicly documented and must be verified.

- **kw** Kuwait — Non-resident-seller disposal gate: NO personal income tax and NO capital-gains tax on individuals in Kuwait; consequently NO non-resident-seller disposal withholding and NO tax-clearance certificate gating sale/transfer of real estate by an individual (note: foreign-property ownership by non-Kuwaitis is itself highly restricted under Kuwaiti law, a separate eligibility matter). Separate instrument (do not conflate): real-estate registration is handled via the Ministry of Justice Real Estate Registration & Documentation Department with registration formalities/fees — a registration duty, not a seller-gains withholding. GATES completion? NO (no seller-CGT/clearance gate exists for individuals) (PwC Worldwide Tax Summaries — Kuwait, 2025/2026, verify at https://taxsummaries.pwc.com/kuwait; Kuwait Ministry of Justice, verify at https://www.moj.gov.kw). Most binding completion-gate detail: with no individual income/CGT regime there is no seller tax-clearance to file; registration formalities at the Ministry of Justice are the only completion condition and are administrative/transfer in nature, not a disposal-gains withholding.

- **lb** Lebanon — Non-resident-seller disposal gate: For a direct disposal of real estate by an individual NOT trading in real estate, there is generally NO capital-gains/profit tax in Lebanon — so no general non-resident disposal CGT-withholding on a private real-estate sale. EXCEPTION (do not conflate with direct sale): the 2022 Budget Law imposes a transfer tax on capital gains realised by individuals on disposal of SHARES in real-estate-holding companies at 3% (resident) / 5% (non-resident) — that is a share-disposal tax, not a direct-property withholding. Separate instrument: real-estate transfer/registration fees of roughly 5-6% (including a 5% transfer levy on fair value plus registration fee components, 0.4% stamp duty) are collected by the Directorate of Land Registration and Cadastre (Tabaris) and registration of the transfer cannot complete until these are paid — a transfer/registration duty borne on the transaction, not a non-resident disposal-gains withholding. GATES completion? Registration IS gated by payment of the ~5-6% transfer/registration fees at the Land Registry; there is NO separate non-resident disposal-gains clearance for a direct individual sale (share-route disposals carry the 5% non-resident tax) (Lebanon 2022 Budget Law; PwC Worldwide Tax Summaries — Lebanon Individual Other Taxes, 2025/2026, https://taxsummaries.pwc.com/lebanon/individual/other-taxes; Directorate of Land Registration & Cadastre, verify at https://www.lrc.gov.lb/en). Most binding completion-gate detail: a direct individual sale completes once the ~5-6% Land-Registry transfer/registration fees are paid (transfer duty, not a CGT withholding); only the SHARE-disposal route triggers a 5% non-resident gains tax.

- **om** Oman — Non-resident-seller disposal gate: NO personal income tax and NO capital-gains tax on individuals in Oman at present; consequently NO non-resident-seller disposal withholding and NO tax-clearance certificate gating the sale/transfer of real estate for individuals. (Oman has enacted a future personal income tax intended to commence 2028 — confirm scope/treatment of real-estate gains nearer the time; not in force for the disposal-gate analysis now.) Separate instrument (do not conflate): property-registration fees are collected by the Ministry of Housing & Urban Planning on registering the transfer — a registration duty, not a seller-gains withholding. GATES completion? NO (no seller-CGT/clearance gate for individuals under current law) (PwC Worldwide Tax Summaries — Oman, 2025/2026, verify at https://taxsummaries.pwc.com/oman; Oman Ministry of Housing & Urban Planning — the ministry's former `mhup.gov.om` host no longer resolves and `housing.gov.om` returns HTTP 403 to every client tried, so no primary page is citable: data not publicly available — verify with the Ministry of Housing & Urban Planning directly (2026-09-18 verified)). Most binding completion-gate detail: no individual CGT/income tax currently in force, so no seller tax-clearance exists; registration-fee payment at the Ministry of Housing is the only completion condition (transfer duty, not a disposal-gains withholding) — note the legislated 2028 personal-income-tax change to re-verify later.

- **qa** Qatar — Non-resident-seller disposal gate: NO personal income tax and NO capital-gains tax on individuals' real-estate sales in Qatar; consequently NO non-resident-seller disposal withholding and NO tax-clearance certificate gating sale/transfer of real estate for individuals. Separate instrument (do not conflate): a low property-registration fee (~0.25% on purchase) is collected by the Ministry of Justice Real Estate Registration Department on registering the transfer — a registration duty on the transaction, not a seller-gains withholding. GATES completion? NO (no seller-CGT/clearance gate exists for individuals) (PwC Worldwide Tax Summaries — Qatar Individual Income Determination, 2025/2026, https://taxsummaries.pwc.com/qatar/individual/income-determination; Qatar Ministry of Justice Real Estate Registration, verify at https://www.moj.gov.qa). Most binding completion-gate detail: no individual income/CGT regime means no seller tax-clearance; the ~0.25% Ministry-of-Justice registration fee is the only completion condition and is a registration duty, not a non-resident disposal-gains withholding.

- **sa** Saudi Arabia — Non-resident-seller disposal gate: There is NO personal income tax / individual capital-gains tax on a natural person's real-estate disposal in Saudi Arabia. The applicable instrument is the Real Estate Transaction Tax (RETT) at 5% of the transaction value (not less than fair market value), under the RETT Law and Implementing Regulations effective 10 April 2025, administered by ZATCA — but RETT is a TRANSFER tax on the disposal transaction (primary liability on the seller/transferor, buyer jointly liable in avoidance cases), NOT a capital-gains/withholding on the non-resident's gain, and applies uniformly regardless of seller residency. RETT must be declared and paid to ZATCA and a RETT payment/exemption confirmation is required to complete notarisation/registration of the transfer — so RETT settlement (a transfer tax) does function as a registration gate, but it is not a non-resident disposal-gains withholding. GATES completion? Registration/notarisation IS gated by RETT settlement (a 5% transfer tax), but there is NO separate non-resident capital-gains withholding/clearance for individuals (Real Estate Transaction Tax Law & Implementing Regulations, effective 10 Apr 2025, ZATCA, https://zatca.gov.sa/en/RulesRegulations/Taxes/Pages/RETTRegulation.aspx; EY Tax Alert 2025, https://www.ey.com/en_gl/technical/tax-alerts/saudi-arabia-issues-real-estate-transaction-tax-implementing-regulations). Most binding completion-gate detail: notarisation/registration of the transfer cannot complete without ZATCA RETT settlement/exemption confirmation (5% transfer tax) — a transaction transfer-tax gate, explicitly NOT a non-resident disposal-gains withholding; ZATCA may also reassess declared value within 3 years.

- **tr** Türkiye — Non-resident-seller disposal gate: YES on the gains side but NOT as a registration-blocking clearance — a non-resident individual selling Turkish real estate held LESS THAN 5 years is taxable on the value-increase gain ("değer artışı kazancı") under the Income Tax Law (Gelir Vergisi Kanunu No. 193); gains on property held 5+ years are EXEMPT. Taxable gains (above an annually-indexed exemption — 120,000 TRY for 2025) are taxed at progressive personal income-tax rates (the 2025 bracket span runs ~15% up to 40%), with the acquisition cost indexed to the PPI for inflation. The tax is SELF-DECLARED in an annual return (declared/paid the year following the sale, typically March), NOT withheld at source by the buyer. The title-deed transfer at the Land Registry (Tapu ve Kadastro) is conditioned on payment of the title-deed transfer fee ("tapu harcı", ~4% of declared value, shared seller/buyer) — that is a transfer duty, NOT the income-tax-gain clearance; the değer artışı gain is settled separately via the tax office, not at Tapu. GATES completion? The income-tax gain does NOT gate the tapu transfer (self-assessed post-sale); registration is gated only by the separate tapu harcı transfer fee (Income Tax Law No. 193; PwC Worldwide Tax Summaries — Türkiye Individual Income Determination, 2025/2026, https://taxsummaries.pwc.com/turkey/individual/income-determination; Revenue Administration (Gelir İdaresi Başkanlığı), verify at https://www.gib.gov.tr; Tapu ve Kadastro Genel Müdürlüğü, https://www.tkgm.gov.tr). Most binding completion-gate detail: the non-resident değer artışı gain is self-declared to the tax office in the following year and does NOT block the tapu transfer; the only registration gate is payment of the ~4% tapu harcı (a transfer duty distinct from the disposal-gains tax), so a non-resident can complete the sale without a prior gains-clearance certificate.

### Asia–Pacific + Central & South Asia (R4)

- **au** Australia — Non-resident-seller disposal gate: Foreign Resident Capital Gains Withholding (FRCGW) under Taxation Administration Act 1953 Sch 1 Subdiv 14-D. From 1 Jan 2025 the rate is **15%** of the contract price and the prior AUD 750,000 threshold is **REMOVED** — so it applies to ALL Australian real-property sales regardless of value. The PURCHASER must withhold 15% and pay it to the ATO at settlement UNLESS the vendor gives the buyer an ATO-issued **clearance certificate** (vendor proves Australian tax residency) before settlement; a foreign-resident vendor cannot get a clearance certificate but may apply for a **variation** to reduce the rate. (Australian Taxation Office, 2025, https://www.ato.gov.au/individuals-and-families/investments-and-assets/capital-gains-tax/foreign-residents-and-capital-gains-tax/foreign-resident-capital-gains-withholding/foreign-resident-capital-gains-withholding-overview). Clearance certificate est. processing: most issued automatically within days, up to 28 days if ATO review needed (ATO, 2025). Most binding completion-gate detail: no clearance certificate handed to buyer ⇒ buyer is legally obliged to withhold 15% of the FULL sale price at settlement (it is the buyer's liability, so conveyancers will not complete without it).

- **cn** China — Non-resident-seller disposal gate: Individual Income Tax on property-transfer gains at a flat **20%** of the gain (Individual Income Tax Law); plus VAT, Land Appreciation Tax, deed tax and stamp duty settled at transfer. In practice the tax is collected at the local tax authority window and a tax-paid proof is required before the real-estate registration office (local 不动产登记 bureau) will register the title transfer; a separate **SAT departure tax-clearance** can apply to a foreign individual leaving China with outstanding IIT. (State Taxation Administration / PwC Worldwide Tax Summaries, 2025, https://taxsummaries.pwc.com/peoples-republic-of-china/individual/other-taxes). Est. processing time: data not publicly available — verify at State Taxation Administration (chinatax.gov.cn). Most binding completion-gate detail: title cannot be registered to the buyer until the transfer-related taxes (incl. 20% IIT on gain) are paid and the tax-paid certificate is presented to the property registration bureau.

- **hk** Hong Kong — Non-resident-seller disposal gate: NO general capital gains tax in Hong Kong (gains on a capital-asset disposal are not taxable; only if the IRD treats the disposal as a trade are they taxable under Profits Tax). Demand-side stamp duties (Buyer's Stamp Duty and Special Stamp Duty) were ABOLISHED for all residential transactions from 28 Feb 2024; only ad valorem stamp duty (Scale 2) remains. There is therefore NO non-resident-seller CGT withholding and NO seller tax-clearance certificate gating completion. (Inland Revenue Department / PwC Worldwide Tax Summaries, 2025, https://taxsummaries.pwc.com/hong-kong-sar/individual/other-taxes). Most binding completion-gate detail: completion is NOT gated by any seller CGT/withholding mechanism — a clean citable "no CGT" fact (the only seller-side tax risk is if the IRD recharacterises the gain as trading income under Profits Tax).

- **id** Indonesia — Non-resident-seller disposal gate: Final income tax (PPh Final) on transfer of land/buildings at **2.5%** of the higher of transaction value or NJOP (Govt Reg PP 34/2016); for a foreign seller with no Indonesian tax number (NPWP) the rate can rise materially. The seller must pay the PPh Final BEFORE signing the Akta Jual Beli (AJB / sale-purchase deed), and the PPAT/Notary is legally PROHIBITED from signing the AJB until proof of payment (validated SSP) is produced; the validated SSP is then required for the BPN land-office title transfer. (Direktorat Jenderal Pajak, 2025, https://www.pajak.go.id/en/withholding-income-tax-article-42-corporate-taxpayer). Est. SSP validation: data not publicly available — verify at Direktorat Jenderal Pajak (pajak.go.id). Most binding completion-gate detail: notary cannot sign the AJB and BPN will not register transfer without the validated 2.5% PPh Final payment slip — a hard, statutory completion gate.

- **in** India — Non-resident-seller disposal gate: TDS under Income-tax Act 1961 s.195 — when a buyer purchases immovable property from a non-resident (NRI) the BUYER must deduct tax at source on the sale consideration / capital gain (long-term ~12.5% plus surcharge & cess; short-term at slab rate), and deposit it with quoting of buyer TAN. The non-resident seller can apply in **Form 13** to the Assessing Officer for a lower/nil-deduction certificate under s.197 so TDS is on the actual gain not gross consideration; issuance is discretionary and document-heavy. (Income Tax Department, 2025, https://www.incometax.gov.in / cleartax.in/s/section-195). Form 13 est. processing: officially up to ~1 month but commonly several weeks to a few months in practice (not an automated process) — treat as est., verify at Income Tax Department. Most binding completion-gate detail: without a Form 13 certificate the buyer is statutorily bound to withhold s.195 TDS on the GROSS consideration and is personally liable if he under-deducts — so buyers will not release full proceeds until TDS is settled.

- **jp** Japan — Non-resident-seller disposal gate: Withholding under the Income Tax Act on a non-resident's disposal of Japanese real property — the PURCHASER must withhold **10.21%** of the gross sale price and remit to the tax office by the 10th of the following month, paying only 89.79% to the non-resident seller. Exemption only where price ≤ JPY 100,000,000 AND the buyer (individual) will use it as their own/relative's residence, or the seller is a Japanese resident. The non-resident reconciles via a final return (refund of any excess over true tax). (National Tax Agency, 2025, https://www.nta.go.jp/english/taxes/individual/12014.htm). Est. refund via final return: data not publicly available — verify at National Tax Agency (nta.go.jp). Most binding completion-gate detail: there is no "clearance certificate" — the 10.21% gross withholding is automatic and the buyer's legal duty, so a non-resident seller always receives proceeds net of 10.21% unless a statutory exemption clearly applies.

- **kh** Cambodia — Non-resident-seller disposal gate: Capital Gains Tax under **Prakas No. 1130 MEF.Prk.GDT (31 Dec 2025)** — which abrogated Prakas 346/2020 — at a flat **20%** on the gain (immovable property: deduct either an 80% standard deduction without documentation, or actual documented expenses); return filed and CGT paid to the GDT within 3 months of the gain being triggered. CGT on immovable property of physical persons has been DEFERRED multiple times — Prakas No. 1130 Art. 18(2) fixes immovable-property CGT for gains arising from 1 Jan 2027 onward (Art. 18(1) other capital assets from 1 Jan 2026; Art. 18(3) leaves indirect capital transfers to separate regulation); meanwhile the transfer of immovable property triggers a 4% property transfer (registration) tax payable before the cadastral/land office registers the new owner. (General Department of Taxation; KPMG Cambodia / DFDL summarising GDT, 2025, verify at https://www.tax.gov.kh). CGT est. payment window: within 3 months of the disposal (sourced). Most binding completion-gate detail: today the firmly-operative gate is the 4% transfer tax that must be paid before cadastre registration; the 20% CGT for immovable property is NOT yet in force (deferred to 1 Jan 2027 per latest guidance) — re-verify the effective date at GDT before relying on it.

- **kr** Korea (Republic of) — Non-resident-seller disposal gate: Non-resident capital-gains on Korean real property is collected by buyer WITHHOLDING — the buyer (where required) withholds the LESSER of 11% of the gross sale price (incl. local surtax) or 22% of the net capital gain (incl. surtax) and remits to the tax authority, with the non-resident filing a CGT return to true-up. (National Tax Service, 2025, https://taxsummaries.pwc.com/republic-of-korea/individual/income-determination). Est. processing/refund: data not publicly available — verify at National Tax Service (nts.go.kr / Hometax). Most binding completion-gate detail: the buyer's withholding obligation (capped at 11% of price / 22% of gain) means the non-resident seller does not receive full proceeds at completion unless withholding is correctly discharged; confirm exact buyer-withholding trigger conditions at NTS.

- **kz** Kazakhstan — Non-resident-seller disposal gate: Capital gains of a non-resident from Kazakhstan-situs property are subject to **15%** non-resident income tax (Tax Code); for individuals the gain is generally the excess of sale price over acquisition cost (a property held >1 year by a resident is often exempt, but the non-resident rule differs — re-verify). Whether the tax is collected by buyer-withholding vs. self-assessment, and whether a tax-clearance certificate gates the title transfer at the Justice/registration body: data not publicly available — verify at State Revenue Committee (kgd.gov.kz). (State Revenue Committee / PwC Worldwide Tax Summaries, 2025, https://taxsummaries.pwc.com/kazakhstan/corporate/withholding-taxes). Most binding completion-gate detail: 15% non-resident rate on the gain is the headline; the collection mechanism (withholding vs filing) and any registration-office clearance must be confirmed at the State Revenue Committee before relying on it.

- **lk** Sri Lanka — Non-resident-seller disposal gate: Capital Gains Tax under the Inland Revenue Act No. 24 of 2017 on the realisation of an investment asset (incl. land/buildings) — historically 10%; note Sri Lanka announced a CGT rate change effective 2026 (reported 15%) so re-verify the current rate. CGT is self-assessed and paid to the IRD; payment/clearance is in practice required for the notary attestation and subsequent registration of the deed. (Inland Revenue Department, 2025/2026, https://www.ird.gov.lk/en/Type%20of%20Taxes/SitePages/Capital%20Gain%20Tax%20(CGT).aspx Est. processing time: data not publicly available — verify at Inland Revenue Department (ird.gov.lk). Most binding completion-gate detail: CGT must be computed and paid on the gain (rate in transition — confirm 10% vs 15% at IRD for the disposal date) before the deed can be safely registered; no automatic buyer-withholding clearance-certificate regime confirmed.

- **mo** Macau (Macao SAR) — Non-resident-seller disposal gate: Macau has NO general capital gains tax on the disposal of property by individuals (property-transaction gains are not subject to a dedicated CGT); a Stamp Duty on the property transfer (progressive, plus a special stamp duty / additional stamp duty regime on short-term resales and on non-resident/company acquirers) applies at transfer. There is therefore NO non-resident-seller CGT-withholding or seller tax-clearance certificate gating completion — the binding gate is stamp-duty payment at the Financial Services Bureau. (Financial Services Bureau (DSF) / PwC, 2025, verify at https://www.dsf.gov.mo). Most binding completion-gate detail: no seller CGT/withholding gate; transfer stamp duty must be paid at DSF before the registry will register the transfer — re-verify the special/additional stamp-duty position for non-resident parties at DSF.

- **mv** Maldives — Non-resident-seller disposal gate: The Maldives does not levy a personal capital gains tax on individuals on the sale of real property under the Income Tax Act (Law 25/2019); land ownership by foreigners is itself heavily restricted (foreigners generally cannot own freehold land), so non-resident "sellers" of real property are atypical and any disposal is usually of a leasehold/business interest taxed under business income rules. A specific non-resident-seller property withholding or tax-clearance completion gate: data not publicly available — verify at Maldives Inland Revenue Authority (mira.gov.mv). (Maldives Inland Revenue Authority, 2025, verify at https://www.mira.gov.mv). Most binding completion-gate detail: no individual property CGT regime identified; the operative constraint is foreign-ownership restriction on land rather than a seller tax-clearance gate — confirm any non-resident withholding on leasehold/asset disposals at MIRA.

- **my** Malaysia — Non-resident-seller disposal gate: Real Property Gains Tax (RPGT) under the Real Property Gains Tax Act 1976. For a non-citizen/non-PR (Schedule 5 **Part III**) disposer the RPGT rate is **30%** on disposal within 5 years and **10%** in the 6th year and thereafter (unchanged since 1.1.2019), AND the acquirer must retain and remit part of the consideration to the **Director General of Inland Revenue within 60 days after the date of disposal** — **7%** for a Part III disposer (Part I 3%; Part II 5% within 3 years, 3% from the 4th year); failure adds a **10% increase charged to the acquirer**, and LHDN refunds any excess after assessment. **From the disposal of Year of Assessment 2026** the acquirer may instead remit an amount equal to the deemed-assessment amount, where the disposer notifies that amount before remittance, whichever is lower. (Lembaga Hasil Dalam Negeri / Inland Revenue Board — rates page last updated 23/06/2026, retention/remittance page last updated 25/05/2026; 2026-09-18 verified, https://www.hasil.gov.my/en/ckht/kadar-cukai-keuntungan-harta-tanah/ + https://www.hasil.gov.my/en/ckht/pegangan-dan-remitan-wang-oleh-pemeroleh/). Est. retention-refund: ~3–6 months (est., verify at LHDN). Most binding completion-gate detail: the buyer's solicitor is statutorily required to retain 7% of the price for a Schedule 5 Part III (foreign) seller and remit it to the DGIR within 60 days of the disposal — the seller never receives that 7% at completion until the RPGT assessment clears.

- **nz** New Zealand — Non-resident-seller disposal gate: Residential Land Withholding Tax (RLWT) under the Income Tax Act 2007 — when an "offshore RLWT person" sells residential land and the bright-line test applies (2-year bright-line for sales on/after 1 Jul 2024), the VENDOR's conveyancer (or, failing that, the purchaser's conveyancer) must withhold RLWT = the LESSER of 33% (28% for a company) of the vendor's gain and 10% of the gross sale price, and pay it to Inland Revenue. The seller must complete an IR1101 RLWT declaration even where no deduction is ultimately required. (Inland Revenue, 2025, https://www.ird.govt.nz/property/buying-and-selling/residential-land-withholding-tax). Est. processing: data not publicly available — verify at Inland Revenue (ird.govt.nz). Most binding completion-gate detail: the conveyancer is the statutory withholder and must deduct RLWT before releasing settlement proceeds to an offshore vendor selling within the bright-line period — settlement funds flow net of RLWT.

- **pk** Pakistan — Non-resident-seller disposal gate: two stacked federal instruments under the Income Tax Ordinance 2001, both pegged to whether the seller is on the Active Taxpayer List (ATL/"filer"). (1) **Advance tax on the SALE under §236C — collected FROM THE SELLER at transfer by the registering authority** at **4.5% / 5% / 5.5%** of gross consideration (filer rate; ≤Rs.50m / Rs.50–100m / >Rs.100m bands), **11.5% flat for a non-filer**, **Finance Act 2025, eff. 1 July 2025** — and **§236C paid is adjustable against the final CGT**. (2) **Capital Gains Tax under §37(1A)**: for property acquired **on/after 1 July 2024 a flat 15% for filers regardless of holding period** (the holding-period concept was eliminated by Finance Act 2024; non-ATL → personal slab with a 15% minimum floor); property acquired on/before 30 June 2024 uses the legacy holding-period slabs (15% in yr-1 declining to 0% after ~6 years). **Diaspora relief (FBR primary)**: a **non-resident POC/NICOP holder** (present in Pakistan <183 days/yr) may access the **FILER §236C rate even without filing a return**, subject to FBR verification — material because the realistic non-resident vendor is an overseas Pakistani. Who collects: the **registering authority** collects §236C from the seller at the moment of transfer (so registration is the collection point), not a separate clearance certificate. Repatriation: RDA/Roshan Apna Ghar investments are "fully repatriable and subject to full and final taxation" (SBP primary); outside the RDA channel, repatriability depends on documented inward-remittance provenance — confirm the operative SBP FE-Manual clause for immovable property with the Authorised Dealer bank before relying. PKR is a managed float (not a peg); final court is the **Supreme Court of Pakistan** (no Privy Council). **Provincial stamp duty / registration fee / CVT / town-transfer are per-province and `data not publicly available — verify at the relevant provincial Board of Revenue / Excise, Taxation & Narcotics Control`.** ⚠️ FBR property slabs change with EVERY Finance Act — verify the current Finance Act. (Federal Board of Revenue — overseas FAQ (PRIMARY, eff. 1 Jul 2025), https://fbr.gov.pk/overseas-faqs/174240/174248 ; Income Tax Ordinance 2001 §236C / §37(1A) ; CGT rate cross-checked to PwC Worldwide Tax Summaries — Pakistan, Income determination; State Bank of Pakistan, https://www.sbp.org.pk/RDAC/Ghar.html.) est. processing time: §236C is collected at the time of transfer/registration (no separate certificate window). Most binding completion-gate detail: the registering authority collects §236C advance tax from the SELLER at transfer (filer 4.5/5/5.5% of consideration; non-filer 11.5%), creditable against the §37(1A) CGT (flat 15% filer for post-1-Jul-2024 acquisitions) — a non-resident POC/NICOP vendor can claim the filer rate without filing; verify the current Finance Act.

- **ph** Philippines — Non-resident-seller disposal gate: For real property held as a capital asset, Capital Gains Tax at **6%** of the higher of gross selling price or fair-market/zonal value (NIRC; BIR Form 1706), filed within 30 days of sale plus Documentary Stamp Tax. Critically, the BIR issues an **electronic Certificate Authorizing Registration (eCAR)** only after the CGT and DST are paid, and the Registry of Deeds will NOT issue a new title (TCT/CCT) to the buyer without the eCAR — this applies whether the seller is resident or non-resident. (Bureau of Internal Revenue, 2025, https://www.bir.gov.ph / RR 03-2019). eCAR est. processing: data not publicly available (varies by RDO) — verify at Bureau of Internal Revenue (bir.gov.ph). Most binding completion-gate detail: no eCAR ⇒ no title transfer at the Registry of Deeds — the eCAR (issued only post-payment of the 6% CGT + DST) is a hard, mandatory completion gate.

- **sg** Singapore — Non-resident-seller disposal gate: Singapore has NO capital gains tax on property disposals (gains are not taxable unless IRAS treats the seller as trading in property, then taxed as income). The seller-side transaction tax is Seller's Stamp Duty (SSD) if sold within the holding period (3 years; 4 years for residential purchased from 4 Jul 2025), at 4–16% of price/value — but SSD is a stamp duty, not a CGT, and there is NO non-resident-seller CGT-withholding or seller tax-clearance certificate gating completion. (Inland Revenue Authority of Singapore, 2025, https://www.iras.gov.sg/taxes/stamp-duty/for-property). Most binding completion-gate detail: completion is NOT gated by any seller CGT/withholding mechanism — a clean citable "no CGT" fact; only SSD (if within the holding period) and possible income-tax recharacterisation for traders apply.

- **th** Thailand — Non-resident-seller disposal gate: Withholding tax on the seller's income from the property sale is collected by the LAND DEPARTMENT on the day of the title transfer (Revenue Code) — for an individual seller it is computed on the Land Department's appraised value with a holding-period deduction and progressive scale (companies a fixed 1%); plus transfer fee, specific business tax/stamp duty. For most individual non-resident sellers the tax is settled at the Land Office at transfer and that is effectively final. (Revenue Department / Land Department, 2025, verify at https://www.rd.go.th). Est. processing: settled same-day at the Land Office at transfer (sourced). Most binding completion-gate detail: the Land Department will not register the ownership transfer until the withholding tax and transfer fees are paid at the Land Office counter on transfer day — payment is a hard, in-person completion gate (no separate clearance certificate, but no transfer without payment).

- **tw** Taiwan — Non-resident-seller disposal gate: House and Land Transaction Income Tax (HLTI / 房地合一稅) under the Income Tax Act — a non-resident (no Taiwan residence permit / <183 days) seller is taxed at a FLAT **45%** if the property is held ≤2 years and **35%** if held >2 years, on the property-transaction income; Land Value Increment Tax is settled separately at transfer. A non-resident must file and pay the HLTI within 30 days of the transfer; tax payment is required before the transfer can be completed/registered. (Ministry of Finance / National Taxation Bureau, 2025, https://www.etax.nat.gov.tw/etwmain/en/announcement/alien-individual-income-tax/instructions). Est. processing: file/pay within 30 days of transfer (sourced). Most binding completion-gate detail: the non-resident seller's 45%/35% HLTI plus Land Value Increment Tax must be filed and paid in connection with the transfer — the very high flat non-resident rate (45%/35%) is the dominant economic gate; confirm the registry's payment-proof requirement at the National Taxation Bureau.

- **uz** Uzbekistan — Non-resident-seller disposal gate: Capital gains of a NON-RESIDENT from the sale of Uzbekistan-situs immovable property are taxed at **20%** (Tax Code; non-resident "other income" rate). The tax is collected by WITHHOLDING at source — the obligation to withhold and remit is on the BUYER as tax agent (this is explicit for non-resident companies; non-resident individuals fall under the same withholding framework). Where the seller has no documents supporting the acquisition cost, the 20% is assessed on the GROSS sales price (no cost deduction). (Tax Committee; PwC Worldwide Tax Summaries citing the Uzbek Tax Code, 2025, https://taxsummaries.pwc.com/republic-of-uzbekistan/individual/income-determination). Est. processing: withheld at the time of the transaction (sourced). Most binding completion-gate detail: the buyer is the tax agent and must withhold 20% (on the gain, or on the GROSS price if acquisition cost is undocumented) before paying the non-resident seller — the seller does not receive full proceeds at completion; confirm the individual-seller withholding mechanics at the Tax Committee (soliq.uz).

- **vn** Vietnam — Non-resident-seller disposal gate: Personal Income Tax on real-property transfer at a flat **2%** of the transfer (sale) price, applying to non-residents too regardless of holding period or actual gain (Law on Personal Income Tax). The transfer must be notarised; the PIT is declared and paid in connection with the transfer and the tax-paid documentation is required for the land-use-right certificate transfer at the registration office. (General Department of Taxation, 2025, https://taxsummaries.pwc.com/vietnam/individual/taxes-on-personal-income). Est. processing: data not publicly available — verify at General Department of Taxation (gdt.gov.vn). Most binding completion-gate detail: the 2% PIT on the gross transfer price must be paid for the transfer to be registered (land-use-right certificate / "red book" reissued in the buyer's name) — payment of the 2% is the operative completion gate; no buyer-withholding clearance-certificate regime, the seller pays.

- **vu** Vanuatu — Non-resident-seller disposal gate: Vanuatu is a **ZERO-direct-tax jurisdiction — NO capital gains tax, NO personal/corporate income tax, NO inheritance/estate/gift tax, NO wealth tax, NO withholding tax** (there is no Income Tax Act; the absence of any income/CGT category on the Dept of Customs & Inland Revenue tax list is the primary evidence, cross-confirmed at the `.vu` gov agency VFIPA). So there is **no non-resident-seller disposal-gain withholding and no CGT-clearance certificate** gating the sale; Model C. **Structural note**: Vanuatu has **no freehold** — land is custom-owned and held on long (~75-year) leases, so a "sale" is an **assignment of the registered lease**, not a freehold transfer. The only transaction levers on a lease assignment are a **stamp duty (~2% of price, est.) + a government registration/title-transfer fee (~5%, est.)** — these are **agency/conveyancing-secondary, not the primary fee schedule** (verify at the Stamp Duties Act + Land Leases Act [Cap 163] fee schedule / Lands Dept; do NOT state as fact). No annual national land tax (instead annual ground rent to the custom-owner lessor + possible Port Vila/Luganville municipal rates). Currency VUV; final court is the Court of Appeal. Who collects: the Lands Dept / registration process for the duties; no income/CGT authority exists to collect a gains tax. Gate point: the lease-assignment is registered against payment of the (secondary-rate) stamp + registration duties — there is no CGT gate because there is no CGT. Verdict band: 🟢 (Model C — no non-resident disposal CGT; confirm the lease-assignment duty instrument, not a CGT gate). Confidence: **HIGH** for the zero-direct-tax stack (VFIPA + DCIR primary, the absence is the evidence); **LOW/est.** for the exact stamp + registration rates (agency-secondary, not primary-confirmed). (Vanuatu Financial Services & Investment Promotion Agency (VFIPA) "Low tax jurisdiction", https://investvanuatu.vu/untapped-potential/low-tax-jurisdiction/ ; Dept of Customs & Inland Revenue, https://vanuatucustoms.gov.vu/taxes-and-licensing.html ; Land Leases Act [Cap 163]; stamp/registration rates SECONDARY — verify at the Lands Dept, 2026-06-13.) est. processing time: data not publicly available — verify at the Lands Dept. Most binding completion-gate detail: no CGT exists (Model C, zero-direct-tax) — there is no non-resident-seller gains withholding or clearance certificate; a sale is a lease assignment, and the only (secondary-rate, est.) levers are stamp duty ~2% + registration ~5% verified at the Lands Dept.

### Latin America + Caribbean (R5)

- **ag** Antigua and Barbuda — Non-resident-seller disposal gate: **no general capital-gains tax** is widely reported for A&B; there is therefore **no non-resident-seller CGT-clearance withholding gate** — Model C. The disposal instead carries **two vendor-side transaction taxes, NOT a CGT-clearance gate**: (1) **transfer stamp duty ~7.5% on the SELLER** (purchaser ~2.5%) — *secondary / IRD-pending, verify*; and (2) a **Land Value Appreciation Tax (LVAT)** which the **Inland Revenue Department's own page describes as "levied on any appreciation in land value that arises from the transfer of real estate"** — for a **non-citizen vendor commonly cited at ~5% of the gain** (current value less purchase value incl. improvements) (*the 5% non-citizen-vendor rate is SECONDARY (immigrantinvest / TheLatinvestor / ehirealty); the IRD primary page confirms the tax EXISTS but does NOT publish the rate, basis, or a collection/registration-gate mechanism — verify rate + gating at IRD*). Who collects: the **Inland Revenue Department (IRD)** under the Ministry of Finance administers both stamp duty and the LVAT; no civil-law escribano-withholding exists (A&B is English common-law). Gate point: payment of stamp duty + LVAT is a practitioner-standard precondition to completing/recording the transfer, but a formal non-resident *tax-clearance certificate* hard-gating the Land Registry (Landfolio) entry is **not confirmable at primary level** — treat as transaction-tax settlement, not a CGT gate. Verdict band: 🟢 (Model C — no CGT gate; vendor pays transaction taxes only). Confidence: **LOW** (no general CGT widely cited but unverified at IRD; LVAT exists per IRD but rate/basis/gate secondary; legalaffairs.gov.ag served a TLS-cert error on prior fetch). (Inland Revenue Department of Antigua and Barbuda — Land Value Appreciation Tax page, ird.gov.ag/index.php/land-value-appreciation-tax/, 2026 — rate NOT on the primary page; rate + stamp-duty split SECONDARY, verify at IRD; Non-Citizens Land Holding Regulation Act CAP. 293 for the buyer-side licence.) Most binding completion-gate detail: no CGT gate (Model C) — the non-citizen VENDOR pays transaction taxes (stamp duty ~7.5% seller-side + a Land Value Appreciation Tax ~5% on the gain, both SECONDARY/IRD-pending); these are vendor transaction taxes, NOT a non-resident-gains clearance gate.

- **ar** Argentina — Non-resident-seller disposal gate: Impuesto a las Ganancias *cedular* on the disposal of real estate by a non-resident (Ley de Impuesto a las Ganancias t.o. 2019, arts. 7 / 99-100; for property *acquired on/after 1 Jan 2018* — pre-2018 acquisitions fall under the legacy ITI, Ley 23.905, 1.5% on transfer price). Rate: **15% final/definitive withholding** on net gain (sale price less inflation-adjusted cost and in-country expenses). Threshold: no de-minimis for non-residents; the principal-residence exemption does not apply to non-residents. Who collects: the **escribano público** (notary) acts as withholding agent (régimen RG 2139 / RG 4190 ARCA); the non-resident (via local representative with CDI/CUIT) must request an AFIP/ARCA *certificado de retención* (the "certificado de no retención / determinación del importe") at least ~20 business days before the act, or the escribano withholds on a presumptive basis. Clearance: ARCA-issued withholding-amount certificate presented to the escribano. GATES? Yes in practice — the escribano will not authorize the escritura without resolving the withholding/certificate, and the Registro de la Propiedad Inmueble registers off the escritura. (ARCA — formerly AFIP, the agency renamed Oct 2024 — 2026, verify at https://www.afip.gob.ar / servicioscf.afip.gob.ar ABC RG 2139.) Most binding completion-gate detail: the AFIP/ARCA withholding certificate must be requested ~20 business days ahead — failure forces a presumptive escribano withholding and can stall the escritura.

- **bb** Barbados — Non-resident-seller disposal gate: no capital-gains tax, but the seller pays **Property Transfer Tax 2.5%** (Property Transfer Tax Act, Cap. 84A) plus **Stamp Duty 1%** on consideration above Bds$50,000 (first Bds$150,000 of consideration exempt where a building is included), and a mandatory **Tax Clearance Certificate** is the binding gate. Threshold: PTT/SD thresholds as above; tax-clearance applies to all conveyances regardless of residency. Who collects: the attorney handling the conveyance remits PTT/Stamp Duty; the seller (or authorized agent) obtains clearance from the **Barbados Revenue Authority (BRA)**. Clearance: all persons (natural and juridical) wishing to convey property must first obtain a BRA Tax Clearance Certificate confirming all taxes under the Income Tax Act, Land Tax Act, VAT Act and Excise Tax Act are paid or under an agreement; Land Tax Clearance Certificate available via the Land Tax portal (bill.bra.gov.bb). GATES? Yes — conveyance cannot complete/register without the BRA tax clearance. (Barbados Revenue Authority, 2026, https://bra.gov.bb/About/Services/Tax-Clearances ; Property Transfer Tax Act Cap. 84A.) Most binding completion-gate detail: a BRA tax-clearance certificate (covering income, land, VAT and excise taxes) is a statutory precondition to any conveyance.

- **bm** Bermuda — Non-resident-seller disposal gate: Bermuda has **NO income tax, NO capital gains tax, NO inheritance/estate tax** — so there is **no non-resident-seller disposal-gain withholding and no CGT-clearance certificate** gating the sale; Model C. The only transaction lever on a conveyance is **Stamp Duty** (one-time, **marginal conveyance bands 2.1% / 3.15% / 4.20% / 6.3% / 7.35%**, ~7.35% on the slice above $1.5m, under the **Stamp Duty Act 1976 as amended 2023**) — a transaction tax administered by the **Office of the Tax Commissioner**, not a seller-gains instrument. (A non-*buyer* differential exists on the purchase side — the Alien Landholding Licence fee — but that is a foreign-*buyer* charge, not a seller gate.) Who collects: Office of the Tax Commissioner (stamp duty + adjudication $212); no notary/escribano CGT-withholding (none exists; English common-law, registered title via the Land Title Registry Office under the Land Title Registration Act 2011). Gate point: the conveyance must be stamped/adjudicated, and LTRO registration follows — there is no CGT gate because there is no CGT. Verdict band: 🟢 (Model C — no non-resident disposal CGT; confirm the transfer-tax instrument, not a CGT gate). Confidence: **HIGH** (no-CGT stack + stamp-duty bands are gov.bm-primary, post-2023 amendment). (Government of Bermuda / Office of the Tax Commissioner, gov.bm/stamp-duty-tax-legal-transactions, fetched 2026-05-28; Stamp Duty Act 1976 as amended 2023.) Most binding completion-gate detail: no CGT exists (Model C) — the only conveyance instrument is the marginal Stamp Duty (2.1→7.35%); there is no non-resident-seller gains withholding or clearance certificate.

- **br** Brazil — Non-resident-seller disposal gate: Imposto de Renda sobre o **ganho de capital** of a person resident abroad on disposal of Brazilian real estate (Lei 8.981/1995 art. 21 / Lei 13.259/2016 / IN RFB 1.455/2014; non-residents do *not* get the resident exemptions — no R$440k single-property exemption, no reinvestment relief, no pre-1969 reduction). Rate: **progressive 15% / 17.5% / 20% / 22.5%** on the gain (15% up to R$5m, 17.5% R$5–10m, 20% R$10–30m, 22.5% above R$30m). Threshold: progressive brackets as above; no de-minimis exemption for non-residents. Who collects: **the Brazil-resident purchaser is the responsible withholding agent**; if the buyer is also non-resident the liability falls on the seller's Brazilian attorney-in-fact (procurador). Payment is by **DARF code 0473** via the Sicalc/GCAP program, due by the last business day of the month following the sale (carnê-leão/DARF mechanism). Clearance: DARF 0473 payment proof; the **cartório/tabelião files the DOI (Declaração sobre Operações Imobiliárias)** to the Receita Federal and notarial practice is to require the IR/ganho-de-capital settled before lavrar/registering the escritura. GATES? Yes in practice — the cartório de notas / Registro de Imóveis conditions the escritura/registration on the DOI and proof the ganho-de-capital IR (DARF 0473) is settled; there is no civil-law escribano-withholding (the *buyer* is the withholding agent). (Receita Federal do Brasil (RFB), 2026, verify at https://www.gov.br/receitafederal ; Lei 8.981/1995 art. 21 / Lei 13.259/2016 / IN RFB 1.455/2014.) Most binding completion-gate detail: the Brazil-resident buyer is the statutory withholding agent for the non-resident's progressive (15–22.5%) ganho-de-capital IR (DARF 0473), and the cartório's DOI filing + IR-settled requirement gates the escritura/registration.

- **bs** Bahamas — Non-resident-seller disposal gate: **no capital-gains tax, no income tax**; the disposal instrument is the **VAT on property conveyance** (Value Added Tax Act 2014, as amended — replaced the former Stamp Act conveyance stamp duty), graduated 2.5%–10% of consideration (the top 10% band applies to higher-value conveyances; non-Bahamian *buyers* pay a flat 10%). Threshold: rate bands set by consideration value; by custom VAT is split 50/50 buyer/seller unless agreed otherwise. Who collects: paid on the conveyance through the VAT/stamping process administered by the Department of Inland Revenue; no notary-collected CGT (none exists). Clearance: since Oct 2022 every Conveyance must include a **Real Property Tax assessment number**, and real-property-tax arrears must be settled for the conveyance to stamp/record. GATES? Yes for the conveyance VAT-stamping and the RPT assessment-number requirement — there is no CGT gate because there is no CGT. (Bahamas Dept. of Inland Revenue / PwC Worldwide Tax Summaries, 2026, https://taxsummaries.pwc.com/the-bahamas/individual/other-taxes ; VAT Act 2014.) Most binding completion-gate detail: no CGT exists — the binding gate is VAT-stamping the conveyance plus the mandatory Real Property Tax assessment number.

- **bz** Belize — Non-resident-seller disposal gate: **no capital-gains tax**; the only transactional tax on disposal is **Stamp Duty (transfer/stamp tax) — 8% for non-citizens/foreigners** (5% for Belizeans & CARICOM nationals; 5% applies on value exceeding BZD 20,000 for nationals) under the Stamp Duties Act (Cap. 64). Threshold: stamp duty assessed on transaction value; first BZD 20,000 exempt for nationals (not non-residents). Who collects: stamp duty is paid and the transfer registered through the **Lands Department** (Department of Lands & Surveys) — no notary/escribano CGT-withholding (none exists; Belize is not a civil-law escribano jurisdiction). Clearance: a transfer of title is not effective until registered with the Lands Department, and stamp duty must be paid as part of registration; mechanism is duty-payment proof, not a CGT clearance certificate. GATES? Yes — title transfer is ineffective until stamp duty is paid and the deed registered at the Lands Department; there is no CGT gate. (Belize Dept. of Lands / Global Property Guide, 2026, verify at https://www.globalpropertyguide.com/latin-america/belize/taxes-and-costs ; Stamp Duties Act Cap. 64.) Most binding completion-gate detail: no CGT — stamp duty (8% non-citizen) must be paid for the Lands Department to register the transfer; until registration the transfer is not effective.

- **cl** Chile — Non-resident-seller disposal gate: Impuesto a la Renta on the *mayor valor* from alienation of real estate (Ley sobre Impuesto a la Renta, DL 824, art. 17 N°8 / arts. 58-60 for non-domiciled). Rate: non-domiciled sellers are generally taxed at 35% (Additional Tax) on the gain with no resident exemptions (the resident 8,000 UF lifetime exemption and the pre-2004-acquisition exemption do not benefit non-residents the same way; properties acquired before specific cutoff dates may be exempt under transitional rules). Threshold: resident-only relief (8,000 UF) does not apply to non-residents. Who collects: the **notario** and the **Conservador de Bienes Raíces** automatically report the transaction to the SII via **Formulario 2890 (F2890)**; for non-domiciled sellers a withholding/Additional-Tax mechanism applies and the buyer may have a withholding obligation. Clearance: SII reporting via F2890 (notary/Conservador); annual declaration via Formulario 22. GATES? Partially — the F2890 informational reporting by the notary/Conservador is a procedural condition of the transfer; the gain tax itself is largely declared/withheld rather than a registration-blocking certificate. (Servicio de Impuestos Internos (SII), 2026, https://www.sii.cl ; DL 824 Ley sobre Impuesto a la Renta art. 17 N°8.) Most binding completion-gate detail: the notary/Conservador must file Formulario 2890 reporting the sale to SII as part of the transfer; non-domiciled gain is taxed at the 35% Additional Tax with no resident exemptions.

- **co** Colombia — Non-resident-seller disposal gate: **ganancia ocasional** on disposal of real estate held >2 years (Estatuto Tributario art. 314 residents / art. 316 non-residents) — flat **15%**; if held <2 years the gain is ordinary income. Plus a **retención en la fuente collected by the notario at the escritura** (Estatuto Tributario art. 398-399 / DIAN doctrine): 1% of value on the first 10,000 UVT for the seller's own residence (higher base otherwise). For a non-resident seller with no Colombian domicile, income from the sale is subject to **15% withholding at source**, withheld by whoever makes the payment if a withholding agent. Threshold: ganancia ocasional requires >2-year holding to qualify (otherwise ordinary rates); notary retención bracket at 10,000 UVT (~COP 498m, 2025). Who collects: the **notario** withholds the retención en la fuente at signing of the escritura pública; for non-residents the payer/buyer also withholds 15%. Clearance: notary's retención certificate (certificado de retención), credited on DIAN Form 210/110. GATES? Yes in practice — the notario will not authorize the escritura without applying the retención en la fuente, and registration follows the escritura. (DIAN — Dirección de Impuestos y Aduanas Nacionales, 2026, verify at https://www.dian.gov.co ; Estatuto Tributario arts. 314/316/398-399.) Most binding completion-gate detail: the notario must withhold retención en la fuente at the moment of signing the escritura; the non-resident's gain carries a 15% source withholding and no resident exemption.

- **cr** Costa Rica — Non-resident-seller disposal gate: Impuesto sobre las Ganancias y Pérdidas de Capital, **15%** on the gain (Ley del Impuesto sobre la Renta, Ley 7092 as amended by Ley 9635 of 2018; for assets acquired before 1 Jul 2019 the seller may elect a one-time **2.25% flat tax on gross sale price**). Non-resident-specific mechanism: when a non-resident transfers Costa Rican real property, the **buyer must withhold and remit 2.5% of the total agreed sale price** as a prepayment of the seller's capital-gains tax (DGT resolution, reported via Form No. 129 on TRIBU-CR within 15 days of the transaction month); a special 2.25% withholding applies to assets acquired before 1 Jul 2020. Threshold: 15% on gain (or elective 2.25% gross for pre-2019 assets); 2.5% buyer withholding has no de-minimis for non-residents. Who collects: the **buyer** withholds (not the notary) and files Form 129 via TRIBU-CR; the non-resident seller must obtain a special tax-ID and register as a CR taxpayer. Clearance: buyer's Form 129 withholding filing on TRIBU-CR; non-resident registration with DGT. GATES? The 2.5% buyer withholding and non-resident tax registration are mandatory but enforced via the buyer/TRIBU-CR rather than as a notary-blocked escritura; the notario typically conditions closing on the withholding being handled. (Dirección General de Tributación / Ministerio de Hacienda — BDO & KPMG reporting of the DGT resolution, 2025-2026, verify at https://www.hacienda.go.cr ; Ley 7092 as amended by Ley 9635.) Most binding completion-gate detail: the buyer (not notary) must withhold 2.5% of the gross sale price for a non-resident seller and report it on Form 129 in TRIBU-CR within 15 days of the transaction month.

- **do** Dominican Republic — Non-resident-seller disposal gate: capital-gains tax on disposal of real estate (Código Tributario, Ley 11-92, arts. 287/289 — gain = sale price less inflation-(CPI-)adjusted cost basis). Rate: per aggregator/DGII guidance reported in early 2026, **~27% on the gain** for foreign individuals (the standard top individual/corporate income-tax rate; verify the exact non-resident treatment with DGII — sources conflate the headline rate). Separately a **3% transfer tax** (impuesto de transferencia inmobiliaria) on appraised or sale value, whichever is higher, is paid to register title. Threshold: holding >10 years may give partial/total relief in some circumstances (not automatic). Who collects: there is no civil-law escribano-withholding; the seller files/pays CGT to the **DGII**; the 3% transfer tax is paid at the **Registro de Títulos / Title Registry**. Clearance: foreign sellers must register with DGII and obtain an **RNC**; a **Certificate of Title** free of liens from the Title Registry Office is required for the transaction. GATES? Yes for the 3% transfer tax (no title transfer/registration without it) and DGII/RNC registration; the CGT itself is a filing obligation rather than a registry-blocking certificate. (Dirección General de Impuestos Internos (DGII), 2026, verify at https://dgii.gov.do ; Código Tributario Ley 11-92 arts. 287/289.) Most binding completion-gate detail: the 3% transfer tax plus DGII/RNC registration are required to register title; CGT (~27% headline — verify non-resident rate at DGII) is a separate seller filing.

- **ec** Ecuador — Non-resident-seller disposal gate: two layers — (1) **municipal Impuesto a la Utilidad y Plusvalía** on the gain from urban property transfer (COOTAD, Código Orgánico de Organización Territorial, art. 556 — generally 10% of the difference between municipal valuation and commercial/transfer value, with statutory deductions), seller-borne; (2) national income tax on the profit (Ley de Régimen Tributario Interno, LRTI). Threshold: COOTAD statutory deductions/reductions apply (e.g., for holding period and improvements). Who collects: the **notario** will not authorize the Escritura Pública de Compraventa, and the **Registro de la Propiedad** will not inscribe it, until the official receipt for the municipal utilidad/plusvalía tax is presented; notaries report all transactions to the SRI; for non-residents national-tax withholding rules may apply. Clearance: municipal tax-payment receipt + SRI informational reporting by the notary (anexo notarial). GATES? Yes — explicit: the notario will not authorize the escritura and the Registro de la Propiedad will not inscribe without the municipal utilidad/plusvalía payment receipt. (Servicio de Rentas Internas (SRI) / municipal GAD, 2026, verify at https://www.sri.gob.ec ; COOTAD art. 556 ; LRTI.) Most binding completion-gate detail: the notary will not authorize the escritura and the property registry will not inscribe the transfer until the municipal utilidad/plusvalía tax receipt is produced.

- **gd** Grenada — Non-resident-seller disposal gate: Grenada has **NO capital gains tax** (no separate CGT regime on individual property gains) and **NO general inheritance/wealth tax** — so there is **no non-resident-seller CGT-clearance withholding gate**; Model C. The disposal instead carries a **vendor-side Property Transfer Tax (PTT) of 15% for a NON-CITIZEN VENDOR** (citizen vendor 5%; non-citizen *purchaser* 10%) on consideration or market value, whichever is higher, under the **Property Transfer Tax Act, No. 37 of 1998 (Cap. 257C)** — administered by the **Inland Revenue Division (IRD)**; PTT applies to value exceeding $20,000. This is a **vendor-side transaction tax, NOT a CGT-clearance withholding** — do not conflate (Trap #6). Who collects: IRD assesses/collects PTT; no civil-law escribano-withholding (English common-law, deeds-registration system at the Deeds & Land Registry of the ECSC). Gate point: PTT settlement is the practitioner-standard precondition to recording the deed of conveyance (the deeds-registration system requires duty paid for the instrument to be recorded); a separate formal non-resident *tax-clearance certificate* hard-gating registration is not separately confirmed at primary level. Verdict band: 🟢 (Model C — no CGT gate; the 15% is a vendor transfer tax, not a gains withholding). Confidence: **HIGH** for no-CGT + PTT non-citizen-vendor 15% (IRD-primary, Act No. 37/1998 / Cap. 257C); the deed-registration-gate timing is practitioner-standard. (Grenada Inland Revenue Division, ird.gd/taxes/property-transfer-tax, 2026; Property Transfer Tax Act No. 37 of 1998 / Cap. 257C, grenadaparliament.gd.) Most binding completion-gate detail: no CGT (Model C) — the binding seller charge is the 15% PTT on a non-citizen VENDOR (Act No. 37/1998), a vendor-side transfer tax that must be settled to record the deed, NOT a non-resident-gains clearance gate.

- **jm** Jamaica — Non-resident-seller disposal gate: **no capital-gains tax**; the disposal is taxed via **Transfer Tax — 2% of sale price or appraised value** (Transfer Tax Act), borne by the vendor, plus **Stamp Duty** (flat — typically J$5,000 on a conveyance of land unless otherwise specified by the Commissioner of Stamp Duty), commonly shared 50/50. Threshold: transfer tax 2% with no residency distinction; a refund is available where transfer tax exceeds 37.5% of the capital gain. Who collects: there is no notary/escribano CGT-withholding (none exists); transfer tax is remitted to the **Commissioner of Stamp Duty / Tax Administration Jamaica (TAJ)** — practically the purchaser remits and recovers from the price. Clearance: payment of transfer tax and stamp duty (TAJ assessment) is required before the conveyance can be stamped and the title transfer registered at the Registrar of Titles. GATES? Yes — an instrument cannot be registered until duly stamped and the transfer tax paid (assessed by TAJ/Commissioner of Stamp Duty); there is no CGT gate because there is no CGT. (Tax Administration Jamaica (TAJ), 2026, https://www.jamaicatax.gov.jm/stamp-duty-and-transfer-tax2 ; Transfer Tax Act.) Most binding completion-gate detail: no CGT — the 2% Transfer Tax plus stamp duty must be assessed/paid via TAJ for the conveyance to be stamped and the title transfer registered.

- **kn** St. Kitts and Nevis — Non-resident-seller disposal gate: St. Kitts and Nevis has **NO personal income tax, NO capital gains tax, NO inheritance/estate tax** (IRD-verified headline CBI draw) — so there is **no non-resident-seller CGT-clearance withholding gate**; Model C. Distinctively, a **2023 reform shifted the stamp duty / transfer tax to the BUYER** (~6% freehold / ~5% condo / ~14% Special Development Areas / ~18.5% South East Peninsula — *MEDIUM confidence schedule, verify at sknird.com*), so there is **no vendor-side transfer-tax charge** on the seller either — the disposal carries neither a gains withholding nor (post-2023) a seller stamp duty. (The foreign-*buyer* Alien Land Holding Licence ~10% is a purchase-side licence, not a seller gate; CBI-approved purchases are exempt.) Who collects: the **Inland Revenue Department (IRD)** administers the (now buyer-side) stamp duty/transfer; no escribano-withholding (English common-law). Gate point: none on the seller's gain — there is no CGT, and the transaction stamp duty is buyer-borne post-2023; the deed of conveyance registers under the (largely unregistered/deeds) system without a non-resident-vendor clearance. Verdict band: 🟢 (Model C — no non-resident disposal CGT; post-2023 the transaction tax is buyer-side, so no seller gate at all). Confidence: **MEDIUM** (no-CGT/no-income-tax is IRD-verified; the buyer-shifted stamp-duty schedule is MEDIUM — verify at sknird.com). (Inland Revenue Department, sknird.com / sknird.com/property-tax/, 2026; no-CGT IRD-verified, stamp-duty buyer-shift MEDIUM.) Most binding completion-gate detail: no CGT gate (Model C) — and because the 2023 reform shifted stamp duty/transfer to the BUYER, the non-resident SELLER faces neither a gains withholding nor a vendor-side transfer tax; verify the buyer-side schedule at sknird.com.

- **ky** Cayman Islands — Non-resident-seller disposal gate: the Cayman Islands has **NO income tax, NO capital gains tax, NO inheritance/estate tax, NO annual property tax, NO corporation tax** — so there is **no non-resident-seller disposal-gain withholding and no CGT-clearance certificate** gating the sale; Model C. The single transaction lever is **Stamp Duty on Transfer of Land** (**7.5% standard; 10% on consideration ≥ CI$2,000,000 from 1 Jan 2026**, slab on the whole value, under the Stamp Duty Act (2019 Revision) + Stamp Duty (Rates of Duty)(No.2) Regulations 2025) — a buyer-side transaction tax administered by the **Lands & Survey Department / Valuation & Estates Office**, NOT a seller-gains instrument (Trap #6). Who collects: VEO assesses stamp duty (buyer, due within 45 days); no escribano CGT-withholding (none exists; Torrens-style registered title under the Registered Land Act (2018 Revision)). Gate point: the transfer is stamped and the Land Register entry follows — there is no CGT gate because there is no CGT. Verdict band: 🟢 (Model C — no non-resident disposal CGT; confirm the stamp-duty transfer instrument, not a CGT gate). Confidence: **HIGH** (no-direct-tax stack + stamp-duty lever are gov.ky/legislation.gov.ky-primary; the 1 Jan 2026 10% band is verified primary). (Government of the Cayman Islands / Lands & Survey — Valuation & Estates Office, caymanlandinfo.ky; PwC Worldwide Tax Summaries — Cayman Islands; Stamp Duty (Rates of Duty)(No.2) Regulations 2025, 2026.) Most binding completion-gate detail: no CGT exists (Model C) — the only conveyance instrument is buyer-side Stamp Duty on Transfer of Land (7.5% / 10% ≥ CI$2M from 1 Jan 2026); there is no non-resident-seller gains withholding or clearance certificate.

- **lc** Saint Lucia — Non-resident-seller disposal gate: "no capital gains tax on property" is widely cited for Saint Lucia but is **UNVERIFIED against the IRD** — flag (CGT treatment can hinge on whether a disposal is treated as trading income). On the confirmed instruments it behaves as Model C with a vendor-side transfer tax: the IRD-verified stack is **stamp duty 2% buyer-side** (citizen + non-citizen alike) and a **vendor-side stamp duty that is a flat 10% for a NON-CITIZEN SELLER** (banded for a Saint Lucian citizen vendor) — this **10% is a vendor-side transaction stamp duty, NOT a CGT-clearance withholding** (Trap #6); a foreign buyer who later resells faces this 10% on exit. Additionally, property transactions require **clearance letters — Property Tax clearance + Income Tax clearance from the Inland Revenue Department, plus a National Insurance clearance** — before the transfer is completed (*secondary — confirm scope with IRD*); these are debt/compliance clearances, not a non-resident-gains certificate. Who collects: the **Inland Revenue Department (IRD)** administers stamp duty + property tax; conveyance is by instrument in notarial form (Saint Lucia attorneys are also notaries) registered at the Land Registry under the Land Registration Act 1984 — the purchaser's 2% buyer stamp duty + registration fee are paid to the notary, who stamps and registers. Gate point: the deed must be stamped (vendor 10% non-citizen + buyer 2%) and the IRD/NIC clearance letters produced for the Land Registry to register — so a tax-debt/stamp-duty clearance practically gates completion, but on the (confirmed) transfer-tax/compliance basis, NOT a non-resident-gains withholding certificate. Verdict band: 🟢/🟡 — Model C in substance (no confirmed CGT gate), but the non-citizen vendor's flat 10% stamp duty + the IRD/NIC clearance-letter requirement give it a routine, predictable completion gate; price the 10% into the exit model. Confidence: **MEDIUM** (stamp-duty stack incl. non-citizen vendor 10% is IRD-verified; "no CGT" is UNVERIFIED/flagged; the clearance-letter requirement is secondary). (Inland Revenue Department, irdstlucia.gov.lc, fetched 2026-05-28 — stamp-duty stack VERIFIED; "no CGT" widely cited but UNVERIFIED at IRD; clearance-letter requirement SECONDARY — stlucia-homes / georgesbaystlucia.) Most binding completion-gate detail: no confirmed CGT gate (Model C in substance, but "no CGT" is UNVERIFIED at IRD) — the binding seller charge is a flat 10% vendor-side stamp duty on a NON-CITIZEN seller, and Property-Tax + Income-Tax + NIC clearance letters are required for the Land Registry to register; both are transfer-tax/compliance instruments, NOT a non-resident-gains withholding.

- **mx** Mexico — Non-resident-seller disposal gate: Impuesto Sobre la Renta (ISR) on disposal of real estate by a non-resident (Ley del Impuesto sobre la Renta, art. 126 / Título V arts. 153 & 160 for residents abroad). Rate: a non-resident elects either **25% of the gross sale price** (no deductions) or **35% on the net gain** (with documented deductions / facturas); the non-resident cannot claim the residents' principal-residence exemption (no Mexican RFC / not resident). Threshold: no non-resident exemption; residents' one-off principal-residence exemption unavailable to non-residents. Who collects: the **notario público** is the legally responsible withholding agent — it computes and withholds the ISR from the sale proceeds at the closing and remits it (the notary's ISR calculation should be reviewed before signing). Clearance: the notario's ISR computation and withholding/remittance, documented in the escritura. GATES? Yes — the notario will not formalize the escritura without computing and withholding the seller's ISR; the Registro Público de la Propiedad registers off the notarized escritura. (Servicio de Administración Tributaria (SAT) — practitioner sourcing; verify at https://www.sat.gob.mx ; Ley del Impuesto sobre la Renta arts. 126 / 153 / 160.) Most binding completion-gate detail: the notario público is the statutory withholding agent and will not formalize the escritura without computing and withholding the non-resident seller's ISR (25% gross or 35% net election).

- **pa** Panama — Non-resident-seller disposal gate: on disposal of real estate the seller pays **2% Transfer Tax** plus a **3% advance income tax** on the higher of the transaction amount or cadastral value (Código Fiscal; the seller may elect the 3% advance as definitive, or be assessed **10% income tax on the actual capital gain** with the 3% advance credited and any excess refundable). Threshold: 3% advance / 10% on gain election; no separate non-resident rate (taxed on Panama-source income regardless of nationality/residence). Who collects: the **seller** is legally responsible; all taxes are paid through the **DGI eTax** platform — no escribano-withholding mechanism specific to non-residents. Clearance: an **eTax certificate for each tax (2% transfer + 3% advance income tax)** must be presented before the property title is transferred in the **Registro Público de Panamá**. GATES? Yes — the eTax certificates for the 2% transfer tax and 3% advance income tax must be presented before title can be transferred in the public registry. (Dirección General de Ingresos (DGI) — PwC Worldwide Tax Summaries, 2026, https://taxsummaries.pwc.com/panama/individual/other-taxes ; Código Fiscal.) Most binding completion-gate detail: a DGI eTax certificate for both the 2% transfer tax and the 3% advance income tax is required before the Registro Público will transfer title.

- **pe** Peru — Non-resident-seller disposal gate: Impuesto a la Renta on capital gain from disposal of real estate by a *no domiciliado* (Ley del Impuesto a la Renta, TUO D.S. 179-2004-EF, arts. 54 & 76). Rate: **5% of the sale value** as a definitive payment for non-domiciled individuals — **but only if the cost basis is certified by SUNAT before any payment is made**; without the prior **Certificado de Recuperación del Capital Invertido**, the non-resident is taxed at **30% of the total market value** (not the gain). Threshold: the 5% favorable rate is conditional on obtaining the SUNAT cost-basis certificate before receiving proceeds. Who collects: the **domiciled buyer is the withholding agent** and withholds 5% (or 30% absent the certificate); the transaction needs the escritura pública and notification to SUNAT, with bancarized payment. Clearance: SUNAT **Certificado de Recuperación del Capital Invertido** issued before payment; buyer's withholding filing. GATES? The certificate is not a registry-block per se but is a hard economic gate — without it the non-resident's tax base jumps from gain to 30% of gross market value; the escritura pública and SUNAT notification are required for the transfer. (Superintendencia Nacional de Aduanas y de Administración Tributaria (SUNAT), 2026, https://nodomiciliados.sunat.gob.pe ; TUO Ley del Impuesto a la Renta D.S. 179-2004-EF arts. 54/76.) Most binding completion-gate detail: the SUNAT cost-basis certificate (Recuperación del Capital Invertido) must be issued *before any payment* — otherwise the non-resident is taxed at 30% of gross market value instead of 5% of the gain.

- **py** Paraguay — Non-resident-seller disposal gate: Impuesto a la Renta de No Residentes (**INR**) on disposal of real estate by a non-resident (Ley 6380/2019 "de Modernización y Simplificación del Sistema Tributario" and its regulations; Resolución General SET 42/2020). Rate: presumed net income of **30% of the sale price**, taxed at **15%**, i.e. an effective **~4.5% of the sale price** withheld at transfer (plus 100% of the VAT/IVA where applicable). Threshold: presumptive base — no cost-basis netting for non-residents; applies to physical persons, legal entities and other entities. Who collects: the **Escribano Público (notary)** withholds 100% of the IVA and INR on the non-resident's real-estate transfer (whether the non-resident acts directly or via attorney-in-fact), issues a Retention Receipt per tax, and submits authenticated copies to the **Dirección General de los Registros Públicos (DGRP)**. Clearance: notary-issued retention receipts filed with the DGRP. GATES? Yes — the DGRP will not process the public deed for a real-estate transfer without documentation evidencing payment of the corresponding IRP/INR. (Subsecretaría de Estado de Tributación (SET) / Dirección Nacional de Ingresos Tributarios (DNIT), 2026, https://www.set.gov.py ; Ley 6380/2019 ; RG SET 42/2020.) Most binding completion-gate detail: the escribano público withholds INR (~4.5% of sale price) and the DGRP will not process the public deed without proof of the IRP/INR payment.

- **tc** Turks and Caicos Islands — Non-resident-seller disposal gate: TCI has **NO income tax, NO capital gains tax, NO inheritance/estate tax, NO annual property/real-estate tax** — so there is **no non-resident-seller disposal-gain withholding and no CGT-clearance certificate** gating the sale; Model C. The entire transaction tax is a one-time **Stamp Duty (transfer duty)** computed on a **slab basis on the full value** — Providenciales bands **6.5% / 8% / 10%** (at $25k / $250k / $500k thresholds); outer-island bands **5% / 6.5%** — payable by the **PURCHASER within 30 days** under the **Stamp Duty Ordinance, Chapter 19.05**; this is a buyer-side transaction tax, NOT a seller-gains instrument (Trap #6). Who collects: the **gov.tc Land Registry / Stamp Duty process** (USD is sole legal tender); no escribano CGT-withholding (none exists; Torrens-style registered title under the Registered Land Ordinance Ch. 9.01). Stamp-duty waivers exist only for TCI Status Card holders / BOTC, not general foreign buyers — and are a buyer-side concession, not a seller matter. Gate point: the transfer is stamped (buyer-side) and registered — there is no CGT gate because there is no CGT. Verdict band: 🟢 (Model C — no non-resident disposal CGT; confirm the slab stamp-duty transfer instrument, not a CGT gate). Confidence: **HIGH** for the no-tax stack (gov.tc-primary); **MEDIUM** for the exact stamp-duty bands (editor-reviewed secondary — visittci cross-checked vs legal500; pull exact bands from Stamp Duty Ordinance Ch. 19.05). (gov.tc — Land Registry / Attorney General's Chambers (Ordinances), gov.tc/landregistry/ + gov.tc/agc/; Stamp Duty Ordinance Ch. 19.05; bands SECONDARY (visittci), 2026.) Most binding completion-gate detail: no CGT exists (Model C) — the only transaction tax is a one-time buyer-side Stamp Duty (slab — Provo 6.5/8/10%, outer 5/6.5%); there is no non-resident-seller gains withholding or clearance certificate.

- **tt** Trinidad and Tobago — Non-resident-seller disposal gate: **CGT applies only to a disposal of a chargeable asset within 12 months of acquisition** — that gain is included with other income and taxed in the normal manner (individual bands **25%** up to TT$1,000,000 / **30%** above; TT$90,000 personal allowance), and a **disposal after 12 months is NOT subject to CGT** (PwC Income determination, reviewed 02 Jun 2026; statute frame Income Tax Act per the country playbook). There is **no buyer-withholding-on-disposal and no tax-clearance certificate** gating the conveyance for the seller's gain — T&T is English common-law (attorneys handle the Deed of Conveyance / RPA Certificate of Title; no civil-law notary), final appeals go to the **UK Privy Council (JCPC)**, and a <12-month gain is self-assessed via the income-tax return. The buyer-side transfer instrument is **stamp duty** (first-time buyer TT$0 on residential house+land up to TT$2,000,000; tiered above — **foreign-buyer eligibility for the first-time-buyer exemption is `data not publicly available — verify at IRD/BIR`**). **The dominant exit constraint is NOT a CGT gate but FX**: the TTD is a managed float (~6.74–6.78/USD, 2025-2026) and the **Exchange Control Act Chap. 79:50 was liberalised from April 1993 (no legal repatriation bar), but a genuine multi-year USD shortage means authorised dealers RATION forex** — a foreign vendor is paid in TTD and must source hard currency through a rationing authorised dealer to repatriate, which can be slow/uncertain (the single biggest practical exit risk; IMF 2026 Article IV + EUROCHAMTT). Inbound is cleaner — FIA s.10(1) requires the foreign buyer to settle the purchase in hard currency through an authorised dealer, creating a remittance paper trail. Who collects: BIR (stamp duty); Inland Revenue Division administers income tax/CGT. Gate point: no CGT-clearance gate on the deed — but proceeds *repatriation* (not the conveyance) is the binding friction. Verdict band: 🟡/🟠 — substantively Model C on a CGT gate (no withholding, no clearance certificate; CGT only on <12-month flips), but the USD-rationing repatriation drag means a foreign seller should price exit-FX timing and pre-arrange conversion with the authorised-dealer bank. Confidence: **HIGH** for the CGT <12-month rule + the FX-availability constraint (PwC + IMF Article IV + EUROCHAMTT; CGT band/allowance from PwC, gov tax portal stale on income tax — do not use it). (Inland Revenue Division / Board of Inland Revenue + PwC Worldwide Tax Summaries — Trinidad and Tobago, Income determination, reviewed 02 Jun 2026, https://taxsummaries.pwc.com/trinidad-and-tobago/individual/income-determination ; Central Bank of Trinidad and Tobago, https://www.central-bank.org.tt/ ; Foreign Investment Act Chap. 70:07 s.10(1); Exchange Control Act Chap. 79:50.) Most binding completion-gate detail: no CGT-clearance gate on the conveyance (CGT bites only on a <12-month disposal, folded into income tax 25%/30%) — the binding exit friction is FX: no legal repatriation bar, but USD rationing by authorised dealers can stall converting/remitting TTD sale proceeds.

- **uy** Uruguay — Non-resident-seller disposal gate: Impuesto a la Renta de los No Residentes (**IRNR**) on the capital gain from transfer of Uruguayan real estate by a non-resident (Título 8, Texto Ordenado 1996; IRPF Cat. I / IRNR — Ley 18.083 reform). Rate: **12% of the net capital gain** (sale price less CPI-inflation-adjusted acquisition cost); a presumptive base may apply where cost is undocumented. Separately, **Impuesto de Transmisiones Patrimoniales (ITP) 2%** on transaction value (by convention split 50/50 buyer/seller). Threshold: IRNR 12% on net gain with no resident principal-residence relief for non-residents. Who collects: IRNR operates mainly through **withholding at source** — the Uruguayan payer/buyer must withhold and remit to the **DGI**; the **escribano público** controls tax compliance, drafts the deed and handles registration, ensuring IRNR and ITP are settled. Clearance: escribano's tax-control function — IRNR/ITP must be settled for the escribano to register the deed at the Registro de la Propiedad. GATES? Yes in practice — the escribano público's tax-control role means the deed will not be registered until IRNR (12% on the gain) and ITP (2%) are settled. (Dirección General Impositiva (DGI), 2026, verify at https://www.gub.uy/direccion-general-impositiva ; Título 8 Texto Ordenado 1996 / Ley 18.083.) Most binding completion-gate detail: the escribano público's statutory tax-control function — IRNR (12% on the net gain, withheld at source) and ITP (2%) must be settled before the escribano registers the deed.

- **vg** British Virgin Islands — Non-resident-seller disposal gate: the BVI is a **near-zero direct-tax jurisdiction — NO income tax, NO capital gains tax, NO inheritance/estate tax, NO corporation tax, NO VAT/GST, NO annual net-wealth tax** — so there is **no non-resident-seller disposal-gain withholding and no CGT-clearance certificate** gating the sale; Model C. The only transaction lever is **Stamp Duty on transfer of land** (**4% for a Belonger transferee, 12% for a non-Belonger transferee**, on the higher of price or market value) — a transaction/transferee-side tax (the higher rate falls on a non-Belonger *acquirer*, not as a seller-gains instrument), under the Stamps (Amendment) Act 2022 / Non-Belongers Land Holding Regulation Act (CAP.122). USD is sole legal tender (no FX risk). Who collects: BVI Inland Revenue / Department of Land Registry stamps and registers the Instrument of Transfer; no escribano CGT-withholding (none exists; registered-land Torrens-style system under the Registered Land Act / Ordinance 1970 CAP.229). Gate point: the Instrument of Transfer is stamped and the registered-land entry follows — there is no CGT gate because there is no CGT. (A non-*buyer* must first hold a Non-Belongers Land Holding Licence, but that is a foreign-buyer licence, not a seller gate.) Verdict band: 🟢 (Model C — no non-resident disposal CGT; confirm the stamp-duty transfer instrument, not a CGT gate). Confidence: **HIGH** (near-zero-tax stack is bvi.gov.vg-primary + Carey Olsen/Legal 500 corroboration; stamp-duty 4%/12% verified via Stamps (Amendment) Act 2022 + NBLHR Act CAP.122). (Government of the Virgin Islands, bvi.gov.vg/content/property-tax, verified 2026-05-28; Stamps (Amendment) Act 2022; Non-Belongers Land Holding Regulation Act CAP.122 (12% rate's statutory home), laws.gov.vg.) Most binding completion-gate detail: no CGT exists (Model C) — the only conveyance instrument is Stamp Duty on transfer of land (4% Belonger / 12% non-Belonger transferee); there is no non-resident-seller gains withholding or clearance certificate.

### Africa + North America (R6)

- **ca** Canada — Non-resident-seller disposal gate: ITA s.116 "certificate of compliance"; purchaser must withhold 25% of gross proceeds (50% for certain non-TCP-capital property such as depreciable/inventory real property) unless vendor obtains the s.116 certificate; vendor notifies CRA within 10 days of disposition; certificate issued once vendor remits 25% of the expected gain or posts acceptable security; certificate protects purchaser from secondary liability. GATES: yes — without the certificate the purchaser holds back 25% of the FULL sale price (not the gain) and remits to CRA; the title/closing practically stalls until the certificate or holdback is settled (Canada Revenue Agency, IC72-17R6 + ITA s.116 [RSC 1985 c.1 (5th Supp.)], 2024, https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/ic72-17/ic72-17r6-procedures-concerning-disposition-taxable-canadian-property-non-residents-canada-section-116.html). est. processing time: CRA-stated several weeks to months; no statutory deadline — verify current service standard at canada.ca. Most binding completion-gate detail: 25% (or 50%) of GROSS proceeds is withheld by the purchaser absent a s.116 certificate, recoverable only via later tax filing.

- **bw** Botswana — Non-resident-seller disposal gate: **NO separate flat CGT rate** — gains on Botswana-source immovable property are **folded into taxable income** and taxed at ordinary rates (individuals on the progressive PIT brackets; companies 22% CIT), with an **inflation-indexed cost base** (Income Tax Act; PwC Income determination). The non-resident WHT regime (15% interest/royalties/management fees; 10% dividends) does **NOT** extend to property-disposal gains — so there is **no buyer-withholding-on-disposal and no tax-clearance certificate** confirmed at primary level gating the Deeds Registry transfer for the seller's gain; the disposal gain is return-assessed. The operative transfer-side instrument is the **purchaser's transfer duty** (citizen 5% on value over BWP 1.5m; **non-citizen 10% on the first BWP 2m + 15% on the excess**, Transfer Duty (Amendment) Act 2023, eff. 3 May 2023), paid by the buyer to the **Registrar of Deeds** who remits to BURS — and where VAT is payable on the sale, transfer duty is **waived** (mutually exclusive). Exchange controls were abolished 9 Feb 1999, so **sale proceeds are freely repatriable** — a structural exit positive. GATES: the disposal-gain side has no confirmed completion gate; the buyer-side transfer duty is the registration-linked charge — verify the disposal-gain registration mechanics at the Botswana Unified Revenue Service. (Botswana Unified Revenue Service / PwC Worldwide Tax Summaries — Botswana, Income determination + Other taxes, reviewed 09 Jan 2026, https://taxsummaries.pwc.com/botswana/corporate/income-determination ; Transfer Duty Act Cap. 53:01 as amended by Act No. 5 of 2023; verify at https://www.burs.org.bw/). est. processing time: data not publicly available — verify at BURS / Registrar of Deeds. Most binding completion-gate detail: no confirmed non-resident disposal-gain withholding or clearance gate — the gain enters the income-tax base (inflation-indexed, return-assessed), and the registration-linked charge is the buyer's transfer duty (non-citizen 10%+15%); proceeds are freely repatriable.

- **cv** Cabo Verde — Non-resident-seller disposal gate: capital gain on disposal of real property is taxable; reported sources diverge (15% flat for property gains per 2025 commentary; 10% non-resident flat per another; 3% per an older source) — primary DGI confirmation not located. No non-resident-specific transaction-blocking withholding-certificate mechanism confirmed; gain is calculated as sale price minus acquisition price plus allowable acquisition/notary/registration/renovation costs. GATES: data not publicly available — verify at Direção Nacional de Receitas do Estado / Direção-Geral dos Impostos (Cabo Verde). (Cabo Verde DGI / DNRE — not directly sourced; secondary: PwC Worldwide Tax Summaries Cabo Verde, 2025, verify at https://taxsummaries.pwc.com/cabo-verde/individual/income-determination). est. processing time: data not publicly available — verify at DNRE Cabo Verde. Most binding completion-gate detail: real-property gain is taxable to non-residents but no confirmed clearance-certificate completion-gate; rate itself unsettled across sources — treat all figures as unverified pending DGI/DNRE primary text.

- **eg** Egypt — Non-resident-seller disposal gate: real-estate disposal tax (الضريبة على التصرفات العقارية), Law No. 91 of 2005 as amended (commonly cited basis in Law No. 196 of 2008 / subsequent amendments) — 2.5% of the TOTAL disposal value of built real estate or land prepared for building, payable by the seller regardless of gain; applies equally to Egyptians and foreign/non-resident sellers (no non-resident-specific surcharge). GATES: yes (registration gate, not a withholding-certificate) — tax receipt must be submitted with property documents to the Notary Public / Real Estate Publicity office (الشهر العقاري) to complete the ownership transfer. (Egyptian Tax Authority — primary text not directly sourced; secondary: PwC Worldwide Tax Summaries Egypt + Global Property Guide, 2026, verify at https://taxsummaries.pwc.com/egypt/individual/other-taxes). est. processing time: data not publicly available — verify at Egyptian Tax Authority. Most binding completion-gate detail: 2.5% disposal tax is assessed on gross sale value (not profit) and its paid receipt is a prerequisite document at الشهر العقاري for the transfer to register.

- **gh** Ghana — Non-resident-seller disposal gate: capital gains regime under the Income Tax Act 2015 (Act 896); CGT effectively 15% on net gain for individuals; a Tax Clearance Certificate from GRA is required before final registration of the transfer at the Lands Commission, and reported practice includes advance withholding on the gross sale price (commonly cited at 3% resident / higher for non-resident — figures secondary, confirm with GRA). Seller files the CGT return within 30 days of disposal. GATES: yes — GRA Tax Clearance Certificate is a stated prerequisite to register the deed at the Lands Commission. (Ghana Revenue Authority, Act 896 + CGT return form DT 0111, 2024-2026, https://gra.gov.gh/domestic-tax/tax-types/capital-gains-tax/). est. processing time: data not publicly available — verify at GRA. Most binding completion-gate detail: no Tax Clearance Certificate from GRA → Lands Commission will not register the transfer; the gross-sale-price advance withholding figure for non-residents must be confirmed against GRA primary guidance before relying on it.

- **ke** Kenya — Non-resident-seller disposal gate: Capital Gains Tax under the Income Tax Act (Eighth Schedule); rate 15% of net gain (raised from 5% effective 1 Jan 2023); CGT is the seller's liability and applies to non-residents disposing of Kenyan immovable property. The Commissioner for Domestic Taxes issues a CGT clearance / acknowledgement on payment which is required to register the transfer at the Lands Registry; CGT payable within 30 days of transfer via iTax PRN. GATES: yes — CGT clearance certificate / acknowledgement receipt is required for the Lands Registry to register the transfer (plus separate land-rates and stamp-duty clearances). (Kenya Revenue Authority, Income Tax Act Eighth Schedule, 2023-2025, https://www.kra.go.ke/individual/filing-paying/types-of-taxes/capital-gains-tax). est. processing time: data not publicly available — verify at KRA (CGT payment due within 30 days of transfer). Most binding completion-gate detail: Lands Registry will not register transfer without the KRA CGT clearance/acknowledgement — a hard documentary completion gate for non-resident vendors.

- **ma** Morocco — Non-resident-seller disposal gate: Taxe sur les Profits Immobiliers (TPI), Code Général des Impôts arts. 61-65; non-resident individuals taxed at 20% of net property gain (commentary also cites a 25%/higher non-resident treatment) with a minimum tax floor of 3% of the sale price; the notary collects the tax at deed signing and remits it to the tax administration before/at registration. GATES: yes (notary-collected, registration-linked) — the notary withholds and remits TPI at signing of the deed; transfer does not proceed clean without TPI settled. (Direction Générale des Impôts — primary CGI text not directly sourced; secondary: PwC Worldwide Tax Summaries Morocco + Global Property Guide, 2026, verify at https://taxsummaries.pwc.com/morocco/individual/income-determination). est. processing time: collected at deed signing — no separate certificate processing window sourced; verify at DGI Maroc. Most binding completion-gate detail: TPI is notary-collected at the deed and a minimum 3%-of-sale-price floor applies even if there is little/no gain — the notary will not release net proceeds nor finalise without it.

- **mu** Mauritius — Non-resident-seller disposal gate: NO capital gains tax in Mauritius (resident or non-resident) — but Land (Duties and Taxes) Act: land transfer tax is payable by the TRANSFEROR (seller) at 5% of the property value (registration duty of 5% is separately payable by the transferee/buyer). The Finance Act 2025 rise to 10% for non-citizen resale of EDB-scheme-acquired residential property (LDTA s.4(9), from 1 Jul 2026) was repealed by Finance Act 2026 (Finance Bill No. XII of 2026 cl.9(a)(i); Act 14/2026 gazetted 13 Aug 2026); a new 10% transferor-paid additional duty applies to transfers to non-citizens of residential property on State land / Pas Géométriques (LDTA s.4(11)). GATES: yes (transfer-tax payment is a registration prerequisite via the Registrar-General; not a CGT clearance certificate). (Mauritius Revenue Authority, Land (Duties and Taxes) Act 46/1984, 2026, https://www.mra.mu/download/TheLandAct.pdf). est. processing time: data not publicly available — verify at MRA / Registrar-General's Department. Most binding completion-gate detail: no CGT, but seller pays 5% land transfer tax on property value as a condition of registration — there is no profit test, it is a gross-value charge on the vendor.

- **na** Namibia — Non-resident-seller disposal gate: **NO capital gains tax on ordinary assets** — PwC verbatim "capital gains are not taxed in Namibia", which **includes residential property held as a capital asset** (exception: mining/petroleum licences; and property-trading profits can be taxed as ordinary *income* on a revenue-nature test). So there is **no non-resident-seller disposal-gain withholding and no CGT-clearance certificate** gating the sale. **Distinctively**, although Namibia is in the **Common Monetary Area** (NAD pegged 1:1 to ZAR) and conveys property through the **same Roman-Dutch conveyancer system as South Africa, it has NOT adopted a ZA-style s.35A non-resident-seller withholding** — do not carry ZA's s.35A across the border. The transfer-side instruments are buyer-side: **one-time transfer duty** (natural persons 0% up to N$1.1m, sliding to a top marginal **11%**; entities flat **12%**) + **stamp duty** (NAD 12 per NAD 1,000; natural-person exemption N$1.1m), both effective 1 Oct 2024 (Transfer Duty Act 14/1993 + Stamp Duties Act 15/1993, as amended 2024), paid by the buyer and lodged with the Deeds Registry. GATES: no disposal-gain gate (no CGT) — the registration-linked charges are the buyer's transfer + stamp duties; **no inheritance/estate/gift tax and no net-wealth tax** either. (Namibia Revenue Agency (NamRA) / PwC Worldwide Tax Summaries — Namibia, Income determination + Other taxes (individual), 18 Dec 2025, https://taxsummaries.pwc.com/republic-of-namibia/individual/income-determination ; verify at https://www.namra.org.na/.) est. processing time: data not publicly available — verify at NamRA / Directorate of Deeds Registry. Most binding completion-gate detail: no CGT exists — there is no non-resident-seller gains withholding or clearance certificate, and despite the CMA peg + shared Roman-Dutch conveyancing Namibia has no ZA-style s.35A; the only registration-linked charges are the buyer-side transfer duty (top 11% natural / 12% entity) + stamp duty.

- **ng** Nigeria — Non-resident-seller disposal gate: the **Nigeria Tax Act 2025 (Act No. 7 of 2025) repealed the Capital Gains Tax Act** and folds chargeable gains into income tax from 1 Jan 2026 — a company's chargeable gains form part of its total profits and are taxed at the company rate (s.27(1)); an individual's chargeable gains enter chargeable income taxed at the Fourth Schedule progressive rates (s.58); the standalone flat 10% CGT charge no longer exists. Non-residents remain chargeable on gains on Nigerian-situate assets including land (s.34), and a non-resident's share disposal is a chargeable gain where it changes ownership of, title in, or interest in any asset located in Nigeria (s.47). The **Nigeria Revenue Service (NRS)** replaced the Federal Inland Revenue Service under the NRS (Establishment) Act 2025. No nationally uniform statutory purchaser-withholding-on-property-sale or single transfer-blocking clearance-certificate confirmed at federal level; state land registries commonly require evidence of tax clearance / Governor's consent for perfection of title (state-administered, varies). GATES: partial / state-dependent — verify the specific state Land Registry's tax-clearance requirement for perfection of title. (Nigeria Tax Act 2025 ss.27(1), 34, 47, 58 + repeal recital, 2026 data; 2026-09-18 verified against the Act text at https://irs.gm.gov.ng/docs/national/NIGERIA_TAX_ACT_2025.pdf — authority: Nigeria Revenue Service, https://www.nrs.gov.ng/). est. processing time: data not publicly available — verify at NRS / relevant state Lands Bureau. Most binding completion-gate detail: the federal charge on a non-resident's gain is now income tax on the chargeable gain (company rate for companies, Fourth Schedule bands for individuals), but the practical completion gate is state-level (Governor's consent + tax clearance for title perfection) and is not uniform — must be checked per state.

- **rw** Rwanda — Non-resident-seller disposal gate: gains on the sale of commercial immovable property are business profit (Art. 19 of Law N° 027/2022), taxed at CIT 28 % (Art. 48 as amended by Law N° 051/2023) or PIT progressive to 30 % — not CGT; the CGT rate (10 % since Law N° 014/2025, 29/05/2025; 5 % before) applies to shares, licences, debt instruments, options, guarantees and similar assets, NOT to immovable property; residents and non-residents subject to the same rates; buyer pays a land registration fee of 0.5% of declared value. No non-resident-specific purchaser-withholding mechanism or transfer-blocking CGT clearance certificate for immovable property confirmed in sourced material. GATES: data not publicly available — verify at Rwanda Revenue Authority. (Rwanda Revenue Authority — CGT rate per the Law N° 014/2025 gazette (primary); balance of the gate not primary-sourced; secondary: PwC Worldwide Tax Summaries Rwanda + HLB Rwanda Tax Guide 2025/2026, 2026, verify at https://taxsummaries.pwc.com/rwanda/corporate/other-taxes). est. processing time: data not publicly available — verify at RRA. Most binding completion-gate detail: commercial-immovable-property gains are taxed as business profit (CIT 28 % / PIT to 30 %), not CGT, for non-residents too, but NO confirmed clearance-certificate completion-gate; the 5% figure in the brief was the pre-29/05/2025 CGT rate on shares (now 10 % per Law N° 014/2025), not a real-property rate — do not apply it to property disposals.

- **sc** Seychelles — Non-resident-seller disposal gate: NO general capital gains tax; the binding control on non-residents is the Immovable Property (Transfer Restriction) Act — a non-Seychellois must obtain Government sanction to acquire/transfer Seychelles immovable property (sanction valid 1 year, transaction must register within it); stamp/transfer duty 5% of market value, plus a non-Seychellois processing fee commonly cited at 1.5%; annual immovable property tax 0.5% on non-Seychellois-owned property. GATES: yes (sanction + registration gate, not a CGT clearance) — without Government sanction and Registrar-General registration the transfer cannot complete. (Seychelles Revenue Commission + Immovable Property (Transfer Restriction) Act, 2025, https://src.gov.sc/seychelles-tax-system/). est. processing time: sanction valid 1 year from issue; issuance window — data not publicly available, verify at SRC / Ministry of Lands. Most binding completion-gate detail: the completion gate for a non-resident is the Government sanction under the Immovable Property (Transfer Restriction) Act (not a tax-clearance certificate); the sale cannot register without it.

- **tn** Tunisia — Non-resident-seller disposal gate: capital gain on disposal of immovable property (plus-value immobilière) taxed at 10% if held >5 years / 15% if ≤5 years (residents and non-residents). For NON-RESIDENT persons the tax is levied by withholding at source (retenue à la source) at 10% of the realised capital gain, capped at 2.5% of the selling price; excess withholding is refundable. GATES: yes (withholding at source on the non-resident's disposal — collected at transaction, the capped retenue is taken before proceeds release). (Direction Générale des Impôts / Ministère des Finances — Note Commune; secondary: PwC Worldwide Tax Summaries Tunisia, 2024, https://taxsummaries.pwc.com/tunisia/individual/other-taxes; primary Note commune n°23: https://jibaya.tn/wp-content/uploads/2024/02/Note-commune-n-23-1.pdf). est. processing time: collected at source on the transaction — refund of excess via filing; processing window — data not publicly available, verify at DGI Tunisie. Most binding completion-gate detail: non-resident vendor's gain suffers a retenue à la source — 10% of the gain but capped at 2.5% of the sale price — taken at the transaction, recoverable only via later refund claim.

- **us** United States — Non-resident-seller disposal gate: FIRPTA, 26 U.S.C. §1445 — on disposition of a U.S. real property interest by a foreign person the transferee (buyer) must withhold and remit 15% of the AMOUNT REALIZED (gross, not the gain); reduced to 10% if buyer will use it as a residence and price ≤ $1,000,000; full exemption if buyer will use as a residence and price ≤ $300,000, or if seller furnishes a non-foreign affidavit (TIN + statement under penalty of perjury). Buyer reports/pays on Forms 8288 + 8288-A by the 20th day after transfer; seller can apply in advance for a reduced/zero withholding certificate on Form 8288-B. GATES: yes (statutory purchaser-withholding) — absent an affidavit, withholding certificate, or qualifying exception, 15% of gross proceeds is withheld and remitted to the IRS at closing. (Internal Revenue Service, 26 U.S.C. §1445 / Treas. Reg. §1.1445-1 & -2, Forms 8288/8288-A/8288-B, 2025, https://www.irs.gov/individuals/international-taxpayers/firpta-withholding; statute https://www.law.cornell.edu/uscode/text/26/1445). est. processing time: IRS-stated ~90 days for a Form 8288-B withholding certificate determination — verify current processing time at irs.gov. Most binding completion-gate detail: 15% of GROSS amount realized is withheld at closing on a foreign seller's disposition unless a §1445 exception, non-foreign affidavit, or an approved 8288-B certificate is in hand — the credit is recovered only on the seller's later U.S. return.

- **za** South Africa — Non-resident-seller disposal gate: Income Tax Act s.35A — purchaser must withhold from a NON-RESIDENT seller of immovable property: 7.5% (seller a natural person), 10% (company), 15% (trust) of the amount payable; applies only where the total amount payable exceeds R2,000,000 (above the threshold the withholding is on the FULL price, not just the excess). Conveyancer/estate agent must notify the purchaser in writing that the seller is non-resident and that s.35A may apply; the conveyancer holds the amount in trust and pays SARS within 14 days (purchaser) / 28 days (agent) — practically remitted within ~21 business days of transfer. Seller may apply to SARS for a directive to reduce or exempt the withholding. GATES: yes (statutory purchaser/conveyancer withholding) — the conveyancer holds back the s.35A amount before releasing net proceeds. (South African Revenue Service, Income Tax Act s.35A, 2024-2025, https://www.sars.gov.za/types-of-tax/capital-gains-tax/non-resident-sellers-of-immovable-property/). est. processing time: SARS directive turnaround — data not publicly available, verify at SARS; withholding remitted within statutory 14/28-day windows post-transfer. Most binding completion-gate detail: for any non-resident sale over R2m the conveyancer is legally obliged to withhold 7.5%/10%/15% of the FULL purchase price from proceeds and remit to SARS unless a SARS reduction/exemption directive is produced before transfer.

## Corrections folded (research-surfaced)

- **pt** Portugal — The widely-cited claim that "non-residents pay a **flat 28% on the entire gain** with no 50% exclusion" is **STALE/WRONG as of 2025**. Effective **1 January 2023**, Portugal aligned non-resident individuals with residents: only **50% of the gain** is taxable, at progressive IRS rates. The flat-28%-on-full-gain figure persists across many secondary guides but was repealed; the fix is folded into the **pt** bullet above. (Autoridade Tributária e Aduaneira, 2025 — confirm current bracket/solidarity surcharge.)

- **mt** Malta — Older sources still cite the **pre-2015 dual system (12% final withholding + 35% on profit)**. That regime was replaced effective **1 January 2015** by a single **8% final withholding (PTT)** of transfer value (reduced bands in defined cases). The 35%/12% figures are historical; fix folded into the **mt** bullet. (CfR / Income Tax Act Art. 5A, 2026 — confirm.)

- **ad** Andorra — Many guides cite the framework statute as "Llei 21/2014" — that is the **Llei de bases de l'ordenament tributari** (general procedural law), NOT the property-gains statute. The real-estate capital-gains tax is **Llei 21/2006** (text refós 2015). Some also describe the non-resident retention as a holding-period sliding scale; it is a **fixed 5%** of total transfer value (the multiplicative holding-period coefficients apply to *resident* individuals only), refundable for the excess within 6 months. Fix folded into the **ad** bullet. (Llei 21/2006, leslleis.com / govern.ad, 2015 text refós — confirm current rate.)

- **es** Spain — Some secondary guides describe the 3% Modelo 211 as a "seller-filed" item or conflate it with Modelo 210. It is **buyer-filed within one month** of the deed (Modelo 211); the **seller** separately files **Modelo 210** within four months to settle final IRNR and reclaim over-withholding. The buyer carries personal liability — this is the binding gate, not the seller's later Modelo 210. Fix folded into the **es** bullet. (AEAT, 2026.)

- **al** Albania — Correction flag: the 15% applies to the *gain* (sale − purchase) for individuals; the property-transfer / registration step at ASHK requiring tax payment is a TRANSFER-duty gate, not strictly a capital-gains-clearance certificate. The CGT-specific completion-gate certificate is NOT primary-source confirmed — treated as `verify at General Directorate of Taxes (tatime.gov.al)`. Do not assert a CGT clearance certificate as fact.

- **am** Armenia — Correction flag: 10% non-resident rate and tax-agent withholding are PwC-grade; the withholding is reliable only where the BUYER is an Armenian tax agent (entity). Private-individual buyer → no withholding, self-declaration. No confirmed cadastre registration block — `verify at State Revenue Committee (petekamutner.am)`.

- **az** Azerbaijan — Correction flag: completion-gate mechanism is `data not publicly available — verify at State Tax Service of Azerbaijan (taxes.gov.az)`. Rate/base stated as Tax-Code baseline only; do not present a specific withholding % or registry-block as fact without the primary Tax Code article.

- **ba** Bosnia and Herzegovina — Correction flag: NO single national rule — tax law is split FBiH / Republika Srpska / Brčko District, each with its own income/profit-tax act. The ~10% figure is the common entity rate but the binding rule is entity-specific. No confirmed nationwide completion gate; `verify entity-specific rule (pufbih.ba / poreskaupravars.org)`.

- **bg** Bulgaria — Correction flag: 10% is a *final WHT* in legal form but practical collection (whether buyer/notary withholds vs. seller declares) and any Property-Register gate are NOT primary-confirmed. The 10% statutory deemed-cost deduction is the key base mechanic. `verify at National Revenue Agency (nra.bg)`.

- **cz** Czech Republic — Correction flag: explicitly NO completion gate — cadastre (Katastr) entry is not blocked; verify ITA §38e *tax-securing* (1% individuals / payer-side, non-EU/EEA payee) at financnisprava.cz. The §38e detail is described from RSM/PwC, not quoted from the statute — flag as `verify §38e`.

- **ee** Estonia — Correction flag: HIGH confidence — Estonian Tax and Customs Board primary page explicitly states self-declaration (Form V1, 30 Apr / pay by 1 Oct) with NO notary/buyer withholding and NO Land Register gate. Rate 22% from 01.01.2025 (was 20%) — date-stamp the rate change.

- **ge** Georgia — Correction flag: completion-gate mechanism is `data not publicly available — verify at Georgia Revenue Service (rs.ge)`. The 5% (<2 yr) / 0% (≥2 yr, non-business) individual figures are Tax-Code baseline; do not assert a NAPR registration block as fact.

- **hr** Croatia — Correction flag: the often-cited "~24%" individual figure is the effective combined income-tax-on-gain for ≤2-yr holdings and varies by municipal surtax/rate reform — present as effective, not a single statutory %. The CGT is NOT a completion gate; only the 3% real-estate-transfer-tax is the notarial check. `verify at Porezna uprava`.

- **hu** Hungary — Correction flag: 15% PIT with a holding-period BASE reduction (residential base phases to 0% after the 5th year) — the schedule differs residential vs non-residential; do not state a flat 15%-on-full-gain after year 1. No notary CGT withholding; registration not blocked. `verify schedule at NAV (nav.gov.hu)`.

- **lt** Lithuania — Correction flag: 15% with a >10-year residential holding exemption + principal-residence relief. Corporate-payer 15% withholding can apply; individual buyer → self-declaration. No confirmed Registrų centras entry gate — `verify at VMI (vmi.lt)`.

- **lv** Latvia — Correction flag: RATE MOVED — VID primary page now states the general capital-gains PIT rate is **25.5%** (the older "20% on non-resident capital gains" figure from secondary sources is superseded for the general rate; re-verify the non-resident-specific rate at vid.gov.lv). The distinctive mechanism is the **3% buyer-withholding ONLY when the buyer is a Latvian economic-activity performer (business)**; private-individual buyer → no withholding, self-declared. VID-primary. No separate Land Book clearance certificate confirmed — withholding is the only source mechanism. Do not generalise the 3% to all buyers; do not state 20% as the current rate.

- **md** Moldova — Correction flag: NO separate CGT — only 50% of the gain enters the 12% income base (≈6% effective for individuals); confirm the current inclusion % (has been 50%) and the 12% flat rate at sfs.md. No confirmed cadastre gate. Do not state a standalone "CGT rate".

- **me** Montenegro — Correction flag: capital gain to a non-resident is within the profit-tax WHT scope (treaty-residence + beneficial-ownership proof for relief) — but whether the cadastre (Uprava za nekretnine) blocks registration is `data not publicly confirmed`. KPMG source is 2021 — re-verify rate/scope at the Montenegro Tax Administration (uphd.gov.me); flag rate as possibly changed since 2021.

- **mk** North Macedonia — Correction flag: completion-gate mechanism is `data not publicly available — verify at Public Revenue Office UJP (ujp.gov.mk)`. The 15% individual rate with inclusion-%/holding decay and 10% CIT are baseline; do not assert a Cadastre registration block as fact.

- **pl** Poland — Correction flag: 19% with the **5-year exemption counted from the END of the calendar year of acquisition** (not the acquisition date) — this counting rule is load-bearing; state it precisely. Self-assessed on PIT-39; notary handles only buyer-side PCC. NO CGT completion gate. `verify at podatki.gov.pl`.

- **ro** Romania — Correction flag: HIGHEST confidence, PRIMARY-MECHANISM CONFIRMED — the notary is **legally required to collect the 1%/3% transfer income tax and it must be paid to the notary before the deed is authenticated**; no authentication → no Land Book entry (confirmed across DLA Piper + PwC Romania + tax-checker). For individuals: RON 450,000 per-transfer non-taxable deduction; **3% if owned <3 yrs, 1% if owned ≥3 yrs**, applied to value over RON 450,000; non-resident entities 16% on gain (natural persons may reach 10% by DTT but the notary-collected 1%/3% is the operative at-deed charge). Re-verify the RON 450,000 threshold and rates against the current Fiscal Code at anaf.ro (reform-sensitive — date-stamp).

- **rs** Serbia — Correction flag: 15% (PwC notes 15%; some secondary sources cite 20% — same-tier disagreement: 15% per PwC individual page is used; FLAG and re-verify at purs.gov.rs). Mechanism is post-deed: mandatory Serbian fiscal representative files within 30 days, Tax Administration issues an assessment decision. Cadastre (RGZ) block NOT confirmed — do not assert it.

- **si** Slovenia — Correction flag: holding-period sliding scale 25/20/15/0% (0% after 15 years) is the individual schedular capital tax — PwC-primary-grade. NO CGT completion gate; only the 2% real-estate-transfer-tax / VAT is the notarial check. `verify at FURS (fu.gov.si)`.

- **sk** Slovakia — Correction flag: NO completion gate — cadastre entry not blocked; >5-year holding exemption for individuals. The payer-side *tax-securing (zabezpečenie dane)* parallels the Czech §38e mechanism (non-EU/EEA payee) — described from PwC, flag `verify Income Tax Act at financnasprava.sk`. Confirm current PIT bands (19%/25%) and 21% CIT.

- **ae** — Confirmed via PwC UAE Individual Other Taxes (2025/2026): no individual CGT/income tax; the only registration condition is the ~4% DLD transfer fee, expressly NOT conflated with a seller-gains withholding. Added the corporate-tax (Federal Decree-Law 47/2022) caveat for non-resident JURIDICAL persons to prevent over-broad "no tax" claims. No primary statute fabricated.
- **bh** — No personal income/CGT/withholding in Bahrain confirmed at PwC tier; SLRB registration fee flagged as transfer duty, not seller-gains gate. PwC country root used (specific page not fetched) → marked "verify at" rather than asserting a deep-linked page.
- **il** — Grounded the completion-gate claim (Tabu requires tax clearances submitted before transfer) on multiple Israeli-practitioner sources corroborating the same procedural fact; 25% rate and 40-day report/60-day pay from Israel Tax Authority-aligned summaries. Statute named generically as Real Estate Taxation (Appreciation and Acquisition) Law 5723-1963 with explicit "verify exact section" marker — no invented section number. This is the strongest true completion gate in the set.
- **jo** — No general individual real-estate CGT under Income Tax Law No. 34 of 2014 (PwC + ISTD law text). Whether the Department of Lands & Survey imposes an additional non-resident clearance is NOT publicly evidenced → explicitly marked "not publicly confirmed — verify at ISTD / DLS" rather than asserting absence or presence. Registration fee labelled a transfer duty, not a disposal-gains withholding.
- **kw** — No individual income/CGT regime confirmed at PwC tier; added the foreign-ownership-restriction caveat (separate eligibility matter, not a tax gate) to avoid implying free transferability. PwC country root → "verify at" marker.
- **lb** — Separated the THREE instruments cleanly: (1) no direct individual real-estate CGT, (2) 2022 Budget Law 5% non-resident SHARE-disposal tax (not a direct-property withholding), (3) ~5-6% Land-Registry transfer/registration fees as the actual completion gate. Prevented conflation of the share-route 5% with a direct-sale withholding.
- **om** — No current individual CGT/income tax confirmed at PwC tier; added the legislated 2028 personal-income-tax forward caveat with an explicit re-verify instruction so the bullet does not become silently stale. PwC country root → "verify at" marker.
- **qa** — No individual income/CGT confirmed (PwC Qatar Individual Income Determination); ~0.25% Ministry-of-Justice registration fee flagged as a registration duty, not a seller-gains withholding.
- **sa** — Key anti-conflation correction: RETT 5% (effective 10 Apr 2025, ZATCA) is a TRANSFER tax that gates registration/notarisation, NOT a non-resident disposal-gains withholding/clearance; bullet states both the real gate (RETT settlement) and the absence of any separate individual CGT. Statute/effective-date/administrator sourced to ZATCA + EY; no rate or date invented. ZATCA 3-year reassessment window noted.
- **tr** — Anti-conflation correction: separated the income-tax değer artışı gain (self-declared annual return, NOT buyer-withheld, does NOT gate tapu) from the ~4% tapu harcı (transfer duty that DOES gate registration). 5-year exemption, 2025 indexed 120,000 TRY exemption, progressive ~15-40% brackets, PPI cost-indexation grounded to PwC + practitioner corroboration; Income Tax Law No. 193 named (well-established Turkish statute number, not invented). Conclusion: no prior gains-clearance certificate blocks a non-resident's tapu transfer.
- **General (GCC/Levant)** — GCC pattern (AE/BH/KW/OM/QA + SA-on-individuals) confirmed: NO non-resident disposal-gains withholding/clearance for individuals; the binding completion gates are transfer/registration duties (DLD fee / SLRB fee / MoJ fee / RETT 5%), explicitly NOT conflated with seller-CGT. True seller-CGT/clearance completion gate exists ONLY in **il** (Tabu blocked without Israel Tax Authority clearance). **tr** has a non-resident gains tax but it is post-sale self-assessed and does NOT gate the tapu transfer. All 10 jurisdictions present; unknowns (jo additional non-resident clearance) carry explicit "verify at <named authority>" markers; no statute number or URL fabricated — generic/known statute names used with "verify exact section" where the precise provision was not in a primary source. Final count = 10.

- **au** GROUNDING LEAD CONFIRMED & strengthened: ATO FRCGW rate is 15% from 1 Jan 2025 and the AUD 750k threshold IS removed (now applies to all values) — verified against ato.gov.au primary page (2025). No correction needed; this is the highest-confidence entry.
- **cn** Refinement: the brief's "tax clearance certificate before transfer" framing is partially supported — the operative gate is payment of transfer taxes (incl. 20% IIT on gain) shown at the property registration bureau; a distinct named "non-resident-seller clearance certificate" form was NOT found at primary source. SAT departure-clearance is a separate, person-level mechanism. Flagged as needing chinatax.gov.cn confirmation of exact procedure.
- **hk** GROUNDING LEAD CONFIRMED: HK has no general CGT — clean citable fact. Added precision: BSD and SSD were ABOLISHED for residential property from 28 Feb 2024 (so SSD is no longer the seller-side risk it was pre-2024); only Profits-Tax recharacterisation risk remains.
- **id** Refinement: rate is 2.5% PPh Final (PP 34/2016), and the hard gate is the notary being prohibited from signing the AJB without the validated SSP — stronger and more specific than a generic "withholding." Foreign-seller-without-NPWP penalty rate flagged but exact figure left general (verify at DJP).
- **in** GROUNDING LEAD CONFIRMED: s.195 TDS on non-resident transferor + Form 13 / s.197 lower-deduction certificate. Corrected the long-term TDS figure to ~12.5% (post-2024 LTCG regime) plus surcharge & cess rather than legacy 20%; flagged that Form 13 is discretionary and not automated.
- **jp** GROUNDING LEAD CONFIRMED: NTA 10.21% buyer-withholding on a non-resident's disposal, remitted by the 10th of the following month, 89.79% paid to seller. Added the exemption test (price ≤ JPY 100m AND buyer's own residence). No "clearance certificate" exists in JP — corrected any such implication.
- **kr** GROUNDING LEAD CONFIRMED: buyer withholds the lesser of 11% of price (incl. surtax) or 22% of net gain (incl. surtax); NTS administers. Flagged that the exact statutory trigger for the buyer's withholding duty should be confirmed at NTS (sources are secondary/PwC-tier).
- **kz** Partial: 15% non-resident rate on capital gains is consistent across PwC-tier sources, but the collection mechanism (withholding vs self-assessment) and any registration-office clearance gate were NOT found at primary source — explicitly marked verify-at-State-Revenue-Committee. Note 2025 Tax Code changes referenced in sources; re-verify current-year rule.
- **lk** Correction/flag: historical CGT 10%, but multiple 2025/2026 sources report a CGT rate change effective 2026 (reported 15%). Rate left as "in transition — confirm 10% vs 15% at IRD for the disposal date" to avoid asserting a single figure without primary confirmation. Earlier "5% for non-residents >5 years" claim from one secondary source NOT adopted (uncorroborated at primary).
- **mo** New (not in brief): Macau has no individual CGT on property; the gate is transfer stamp duty (plus special/additional stamp duty regimes) at DSF. Marked verify-at-DSF for the non-resident special-stamp-duty specifics — primary DSF page not directly fetched.
- **mv** New (not in brief): no individual property CGT identified under Maldives Income Tax Act; dominant constraint is the foreign-land-ownership prohibition, not a tax-clearance gate. Explicitly marked data-not-publicly-available for any non-resident withholding on leasehold/asset disposals — verify at MIRA. Guarded against fabricating a CGT regime.
- **my** GROUNDING LEAD CONFIRMED: RPGTA 1976 — foreign disposer 30% (≤5y) / 10% (>5y); s.21B 7% retention by acquirer remitted to LHDN; CKHT within 60 days. Retention-refund ~3–6 months marked est. (secondary-sourced).
- **nz** Refinement (not in brief's explicit list but standard): RLWT under Income Tax Act 2007 — withhold lesser of 33%/28% of gain or 10% of price; conveyancer is statutory withholder; IR1101 declaration. 2-year bright-line for sales on/after 1 Jul 2024 confirmed against ird.govt.nz.
- **ph** Refinement: confirmed 6% CGT on capital-asset realty + the eCAR mechanism — Registry of Deeds will not transfer title without BIR eCAR. This is a clearance-certificate-equivalent hard gate; applies resident and non-resident alike. RR 03-2019 cited.
- **sg** GROUNDING LEAD CONFIRMED: no CGT on property in Singapore — clean citable fact. Corrected to note SSD holding period extended to 4 years for residential property purchased from 4 Jul 2025 (per IRAS-tier sourcing); SSD ≠ CGT; income-tax-trader recharacterisation flagged.
- **th** Refinement: Land Department collects the seller's withholding tax at transfer on appraised value (individuals: holding-period deduction + progressive; companies fixed 1%). No separate clearance certificate — the gate is same-day payment at the Land Office before registration. Marked verify-at-Revenue-Department for the precise non-resident individual computation.
- **tw** GROUNDING LEAD CONFIRMED & sharpened: HLTI flat 45% (≤2y) / 35% (>2y) for non-residents without a residence permit; file/pay within 30 days of transfer; LVIT separate. The punitive flat non-resident rate is the dominant gate. Registry payment-proof requirement flagged for NTB confirmation.
- **uz** Upgraded after follow-up search: confirmed 20% non-resident rate on Uzbek property capital gains, collected by BUYER withholding as tax agent, and that if acquisition cost is undocumented the 20% applies to GROSS sales price. Mechanism now asserted (PwC-tier citing the Tax Code); the explicit text confirms company non-residents and frames individuals under the same withholding framework — flagged to confirm individual-seller specifics at the Tax Committee.
- **kh** Upgraded after follow-up search: confirmed 20% CGT (now under Prakas No. 1130 MEF.Prk.GDT of 31 Dec 2025, which abrogated Prakas 346/2020) (immovable property: 80% standard deduction OR actual documented expenses; pay within 3 months of trigger) but implementation for immovable property of physical persons DEFERRED — latest GDT-summarised guidance puts it at 1 Jan 2027 (other capital assets 1 Jan 2026). Did NOT assert CGT as in force; the firmly-operative gate today is the 4% property transfer tax payable before cadastre registration. Re-verify the effective date at GDT (tax.gov.kh).
- **vn** GROUNDING LEAD CONFIRMED: flat 2% PIT on the gross transfer price applies to non-residents regardless of gain; payment of the 2% is required for the land-use-right certificate transfer. No buyer-withholding clearance-certificate regime — corrected any implication that a separate clearance certificate exists; the seller pays the 2%.

- **Caribbean/Central-America distinction confirmed (bs/bz/jm).** Grounding brief flagged "verify — some Caribbean have transfer tax not CGT-withholding; keep them distinct." Confirmed: **Bahamas (bs)** has *no* CGT/income tax — the disposal gate is VAT on conveyance + Real Property Tax assessment number, no notary CGT-withholding. **Belize (bz)** has *no* CGT — only stamp duty (8% non-citizen) via the Lands Department, no escribano (Belize is common-law, not a civil-law escribano jurisdiction). **Jamaica (jm)** has *no* CGT — 2% Transfer Tax + stamp duty via TAJ/Commissioner of Stamp Duty. These three were kept explicitly distinct from the LATAM notary-collected-retención model; their bullets state "there is no CGT gate because there is no CGT."

- **Barbados (bb) is a tax-clearance jurisdiction, not a CGT-withholding one.** No capital-gains tax; the binding completion-gate is the mandatory BRA Tax Clearance Certificate (statutory precondition to *any* conveyance, covering income/land/VAT/excise) plus Property Transfer Tax 2.5% + Stamp Duty 1%. Distinct from the LATAM escribano-retención pattern.

- **Argentina (ar) — ITI vs. Ganancias split is acquisition-date-dependent.** For property *acquired before 1 Jan 2018* the legacy ITI (Ley 23.905, 1.5% on transfer price) applies; for property *acquired on/after 1 Jan 2018* the 15% cedular Impuesto a las Ganancias on the gain applies. The bullet states both. Also: AFIP was renamed **ARCA** (Agencia de Recaudación y Control Aduanero) in Oct 2024 — both names retained for traceability since statutes/URLs still resolve under afip.gob.ar.

- **Costa Rica (cr) — buyer withholds, NOT the notary.** Unlike the LATAM escribano-retención model in the grouping prompt, CR's non-resident mechanism is a **2.5% buyer withholding** on gross sale price (DGT resolution, Form 129 via TRIBU-CR within 15 days of the transaction month), not a notario-collected retención. The 2.25% election applies only to pre-1 Jul 2019 (gross-rate option) / pre-1 Jul 2020 (special withholding) acquired assets. Distinguished from CL/CO/AR/PE/EC/UY/PY.

- **Peru (pe) — the SUNAT cost-basis certificate is a hard economic gate, not a registry block.** Clarified that the 5% definitive rate for non-domiciled sellers is *conditional* on the Certificado de Recuperación del Capital Invertido being issued *before any payment*; absent it, the base is 30% of gross market value. This is the most consequential non-resident-specific trap among the 16 and is flagged as such rather than mis-stated as a notary gate.

- **Dominican Republic (do) — CGT headline rate flagged for primary-source verification.** Aggregator/DGII-reported guidance gives ~27% on the gain for foreign individuals (the standard top income-tax rate); sources conflate the headline income-tax rate with the non-resident CGT treatment. Bullet carries an explicit "verify the exact non-resident treatment with DGII" marker per the anti-hallucination contract. The 3% transfer tax + DGII/RNC registration are the firmer registry-level gates.

- **Mexico (mx) — primary SAT URL not directly retrieved; statute cited, source labelled.** The notario-as-withholding-agent rule and 25%-gross / 35%-net non-resident election are well-established (Ley del ISR arts. 126/153/160) but the supporting search hits were practitioner pages, not sat.gob.mx directly; the bullet cites the statute and labels the authority with a "verify at https://www.sat.gob.mx" qualifier rather than asserting a SAT-page URL.

- **Chile (cl) — gain tax is largely declared/withheld, not a registration-blocking certificate.** The notary/Conservador Formulario 2890 filing is an informational/procedural condition of the transfer; the non-domiciled 35% Additional Tax is assessed/withheld rather than enforced via a registry-blocking clearance certificate. Bullet marks the gate as "partial" to avoid over-stating it as an escritura block.

- **Colombia (co) — ganancia ocasional requires >2-year holding.** If the property is held <2 years the gain is ordinary income (not the flat 15% ganancia ocasional). The 15% source withholding for non-residents (no Colombian domicile) is distinct from the notario's retención en la fuente at the escritura; both are stated.

- **Ecuador (ec) — two-layer tax (municipal COOTAD + national LRTI).** The registry/notary gate is specifically the **municipal** utilidad/plusvalía receipt (COOTAD art. 556), not the national income tax — the bullet keeps these layers distinct because conflating them is a common error in aggregator sources.

- **Paraguay (py) — INR effective rate stated as derived, not asserted flat.** The ~4.5% figure is shown as a computed product (30% presumptive base × 15% rate) per RG SET 42/2020, with inputs visible inline, satisfying the "computed transparently" branch of the anti-hallucination contract rather than presenting 4.5% as a bare statutory rate.

- **Uruguay (uy) — escribano tax-control gate stated "in practice".** IRNR operates through source-withholding (buyer/payer); the escribano's role is tax-control + registration, so the registry gate is characterized as the escribano's compliance-control function rather than a discrete statutory clearance certificate, to avoid over-asserting the mechanism.

- **Aggregator-sourced rate/threshold figures across all 16 (LATAM/Caribbean) carry verification markers.** Per the source-ranking rule, figures from practitioner blogs, realty sites and tax-summary aggregators (PwC, BDO, KPMG, Global Property Guide, TheLatinvestor) are quoted with the primary tax-authority + statute cited and a "verify at <authority>" qualifier where the primary government page was not directly retrieved (notably mx, cl, co, do, uy, bz). No statute numbers or URLs were invented; where a primary URL could not be confirmed, the bullet names the authority and uses an unavailable/verify marker instead.

- **Date-stamp (LATAM/Caribbean).** All bullets reflect research conducted 2026-05-15; rates/thresholds (esp. CR 2.5% non-resident withholding via TRIBU-CR, DO ~27%, AR ARCA rename) are 2024-2026 vintage and should be re-verified at the named authority before relied upon for a transaction — figures may have changed since.

- **ca** Canada — CONFIRMED & strengthened the brief's grounding: ITA s.116, 25% gross (50% for certain non-TCP/depreciable real property — added nuance the brief's "35% certain" did not state; the higher rate in primary IC72-17R6 is 50%, not 35% — flag and verify exact higher-rate category against IC72-17R6 before publishing).
- **cv** Cabo Verde — UNRESOLVED: real-property-gain rate diverges across secondary sources (3% / 10% / 15%); NO non-resident clearance-certificate completion-gate confirmed. Primary DGI/DNRE text not located. Marked unavailable rather than guessed.
- **eg** Egypt — CORRECTION to brief framing: Egypt's seller charge on residential real estate is a 2.5% GROSS disposal/transfer tax (Law 91/2005-era real-estate disposal tax; commentary also cites Law 196/2008), NOT a profit-based CGT and NOT a non-resident-specific withholding certificate. Gate is the الشهر العقاري registration document requirement. Primary ETA text not directly sourced — secondary-flagged.
- **gh** Ghana — CONFIRMED Tax Clearance Certificate → Lands Commission registration gate (primary GRA). The non-resident gross-sale-price advance-withholding percentage circulating in secondary commentary is NOT confirmed from GRA primary text — left as "confirm with GRA" rather than asserted.
- **ke** Kenya — CONFIRMED from KRA primary: 15% net-gain CGT (from 1 Jan 2023), CGT clearance/acknowledgement is a Lands Registry registration prerequisite. Strong gate.
- **ma** Morocco — CONFIRMED TPI is notary-collected with a 3%-of-sale-price minimum floor; non-resident rate cited variously 20% vs 25% across secondary sources — flagged; primary CGI arts. 61-65 not directly fetched (secondary-flagged).
- **mu** Mauritius — CORRECTION to expectation: Mauritius has NO CGT; the seller-side gate is a 5% land transfer tax on property value (Land (Duties and Taxes) Act) (the Finance Act 2025 rise to 10% for non-citizen resales was repealed by Finance Act 2026; a separate 10% transferor-paid duty applies to State-land / Pas Géométriques residential transfers to non-citizens). No CGT clearance certificate exists.
- **ng** Nigeria — DOWNGRADED confidence: a federal charge on a non-resident's Nigerian-situate gains is confirmed (Nigeria Tax Act 2025 ss.27(1)/34/47/58 — chargeable gains taxed as income from 1 Jan 2026, the flat-10% Capital Gains Tax Act having been repealed), but NO uniform federal purchaser-withholding or single transfer-blocking clearance certificate; the operative completion gate is STATE-level (Governor's consent + state tax clearance for title perfection) and non-uniform. (2026 data, source Nigeria Tax Act 2025; 2026-09-18 verified — NRS replaced FIRS under the NRS (Establishment) Act 2025.)
- **rw** Rwanda — CORRECTION to the brief's "5%" hint: the Rwandan CGT rate on SHARES / licences / debt instruments is 10 % since Law N° 014/2025 (29/05/2025; 5 % before), not an immovable-property rate; commercial immovable-property gains are business profit taxed at CIT 28 % or PIT to 30 %. NO confirmed non-resident clearance-certificate completion-gate. CGT rate primary-sourced to the Law N° 014/2025 gazette; clearance-gate text not directly sourced.
- **sc** Seychelles — CORRECTION to expectation: no CGT; the binding non-resident completion gate is GOVERNMENT SANCTION under the Immovable Property (Transfer Restriction) Act (valid 1 year), plus 5% stamp/transfer duty and Registrar-General registration — not a tax-clearance certificate.
- **tn** Tunisia — CONFIRMED non-resident retenue à la source: 10% of the gain capped at 2.5% of sale price; excess refundable (primary Note commune n°23 + PwC secondary). Strong withholding-at-source gate.
- **us** United States — CONFIRMED & strengthened: FIRPTA 26 U.S.C. §1445, 15% of gross amount realized, 10%/$1m and $0/$300k residence exceptions, Forms 8288/8288-A/8288-B, non-foreign affidavit. IRS-stated ~90-day 8288-B processing added. Matches brief exactly.
- **za** South Africa — CONFIRMED & strengthened: s.35A 7.5%/10%/15% (natural person/company/trust), R2m threshold (above threshold = withholding on FULL price), conveyancer-held, SARS directive to reduce/exempt. Matches brief exactly; added R2m-threshold mechanics and remittance windows.

## Confidence labels

- **HIGH** — primary tax-authority statute/form pinned with rate + year: AU ATO FRCGW (15%, threshold removed 1 Jan 2025), US IRS FIRPTA §1445 + Form 8288/8288-B, CA CRA ITA s.116, ES AEAT Modelo 211, FR Art. 244 bis A + représentant fiscal, IE s.980 TCA + CG50A, ZA SARS s.35A, RO notary-collected gate, JP NTA 10.21%, MY RPGTA s.21B, NZ RLWT, EE Form V1, IL mas shevach Tabu clearance.
- **MEDIUM** — mechanism correct, figure from PwC/BDO/KPMG-tier with `verify at <authority>` (much of LATAM, parts of APAC/MENA).
- **LOW** — no located primary source for the non-resident-disposal mechanism; marked `data not publicly available — verify at <authority>` (AZ, GE, MK, CV, partial AL/BA/ME/RS). No rate or basis stated without a source+year or the unavailable marker. Same-tier source disagreements flagged inline (e.g. RS 15% vs 20%; CA s.116 higher rate IC72-17R6 = 50%, not 35%).

## Status

**Last refreshed**: 2026-05-15 (NG non-resident disposal gate re-derived from the Nigeria Tax Act 2025 and MY RPGT retention/remittance re-read on LHDN, 2026-09-18; UZ tax-authority name corrected to the Tax Committee 2026-09-18). **Next refresh**: per-event on non-resident-disposal-withholding reform (AU FRCGW already bedded 1 Jan 2025; LV CGT 20% → 25.5%; RO threshold/rate reform-sensitive; KH Prakas No. 1130 (31 Dec 2025) immovable-property CGT from 1 Jan 2027), annual otherwise.

**Confidence**: MEDIUM-HIGH overall — HIGH for the ~15 primary-anchored gates above; MEDIUM for the PwC-tier-with-verify majority; LOW/`verify at` for the flagged tail. The structural-model identification + the pre-payment/pre-deed certificate lead-time are the actionable core; every 🟠/🔴 output ends at "engage situs-country tax counsel before listing".