Capital Gains Tax Across the World: A Comparative Map

Capital gains tax (CGT) rates vary enormously: 0% in the UAE, Singapore (on most non-trading gains), New Zealand, Hong Kong, Switzerland (private investors), Belgium (long-held shares), and the Gulf generally; 10–20% in the UK; 19–28% across most of the EU; 20% federal plus state in the US; up to 33% in France and Ireland; and over 40% effectively in some Nordic systems.

Two investors with identical pre-tax returns from the same Aqmār deal can end up with wildly different post-tax outcomes purely because of residency.

Several jurisdictions reward longer holding periods with reduced rates: the US distinguishes long-term (>1 year) from short-term gains; Germany historically gave full exemption after 12 months for shares held privately; Belgium and the Netherlands have specific regimes; France offers tapering relief.

If your portfolio leans toward private deals with multi-year holds, the long-term rate is usually the relevant one — but model it explicitly. A high IRR on a 3-year exit can be silently halved by short-term treatment if you misjudge the boundary.

Many jurisdictions exempt capital gains on the sale of substantial shareholdings held by a company (the participation exemption). The Netherlands, Luxembourg, Spain, Singapore and the UK all have versions. This is one reason serious investors hold private positions through a corporate structure rather than personally — the corporate sells the shares tax-free, and tax is only paid on dividends drawn out.

This is structuring, not avoidance. Done correctly with substance and proper advice, it is how almost every family office in Europe owns its private investments.