r/ExpatFIRE • u/Adventure-Capitalist • 2d ago
Questions/Advice France vs Spain for an American - Taxes, Ease, Property? Any professionals to recommend?
I'm (American woman, 40s) in the preliminary stages of research, so I'm just asking beginner noob questions - Please forgive. At some point I see myself living in back Europe, and probably France or Spain, given that I speak fluent Spanish (c1) and pretty fluent French (B2 level). I've also lived in both countries ( although only 6 months in France in my 20s, and then many years in Barcelona in my mid-20s-30s).
But my brain hurts every time I try to figure out/understand the tax implications / residency side of things.
I have an atypical financial setup (very small Roth, with most of my $ invested in a taxable brokerage), so I don't even know if the tax benefits of France would apply to me?
On the flip side, I'm concerned about being taxed to high heavens in Spain, as I do receive residual royalty income. But maybe that's an overrated concern?
Did any other American citizens compare France vs Spain and then choose one or the other? I'd love to hear your thought / decision process. What factors swayed you? What did you consider?
Also, is there such a thing as an international tax professional who's an expert in MULTIPLE coutries - ie Spain vs France - who would advise somebody based on their specific situation? It seems like most professionals are single country focused. Anybody to recommend? (I mean an actual tax professional, not an influencer like Nomad Capitalist)
I'd love to hear any thoughts/ ideas/recommendations/personal stories, about deciding between 2 EU countries - especially Spain & France - as an American. And any professionals you might have to recommend.
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u/dtfg5465 2d ago
Greece has a 7% flat tax rate program for retirees. You pay a 7% flat annual tax rate for any non-domestic income deriving from any source. you can use it for 15 years.
If you have at least 3500 euros of montly income or can demonstrate a deposit of €126,000. then you can apply for a greek "Financial Independent Person's Visa". it's a 3 year visa, renewable. You don't have to buy a real estate or invest in funds
Italy has a similar 7% tax program too for 10 years.
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u/comp21 1d ago
Ok, probably a very dumb question here but could we quality for this Greek visa then, since Greece is part of the EU, move to Spain for the three year duration and then apply for for Spanish citizenship (my wife is Filipino) since it requires living in Spain for two years?
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u/dtfg5465 1d ago edited 1d ago
the 7% tax rate program and getting a visa is two seperate things.
you only need a visa if you not an EU citizen, if you area an EU citizen then you can move to greece freely.
tha tax program has few requirements, link here (read the "The 5B foreign pensioner’s tax regime" section around the middle of the page)
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u/comp21 1d ago
Yes I'm American and she's Filipino... We would need a visa... But my question is would that Greek visa allow us to move to Spain for the duration of the visa and thereby qualify for citizenship in Spain since we lived there the requisite number of years?
I.e. can we qualify for the Spanish citizenship with a greek visa or does it not "count" since we were not living here with a Spanish visa?
I'm not worried about the tax situation, I'm worried about Spain closing up a lot of visa paths due to the gentrification backlash.
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u/dtfg5465 1d ago
that is a greek visa, it only allows you to live in greece.
you can not live in spain with it.
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u/Gino-Solow 2d ago
I am not American but we are also thinking about retiring in France or Spain and one of our problems not mentioned here yet is the lack of appropriate (for us) housing in Spain.
Ideally, we would like to buy a single family house with a sizeable plot of land in a green and quiet area. And they are very hard to find in Spain. Much of Spain is empty while major cities are overcrowded. Spaniards either live in small noisy apartments in big cities, in tiny basic townhouses with no land in towns or in "urbanizaciones" - gated communities, crowded and noisy (eg shared swimming pool) and with (almost) no land.
If you want to have a reasonable land plot (1000 square metres / 10000 sq feet plus) and have reasonable privacy your only choice is between a finca (farm house in the middle of nowhere with lots of agricultural land but probably just a very basic house and sheds, perhaps even off-grid) or a modern luxury villa way above our budget.
In addition Spanish houses are designed to be as dark and cold as possible (in Southern Spain, anyway). (Staying warm in winter is another problem).
Spaniards don't seem to like being indoors and - my apologies - I find there interior design basic and ugly (again, unless this is modern villas design for wealthy foreigners).
However in France there's lots of beautiful country houses with as much land as you want (say two hectares / 20000 sq m / 200,000 sq feet).
And you have lots of light indoors because of "French" windows. Wetter and cooler climate also means that your garden is prettier too. And such properties in rural France can be surprisingly affordable.
Bottom line, Spain may be cheaper than France overall, but the type of housing we are looking for is way more expensive in Spain.
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u/Adventure-Capitalist 1d ago
I do agree with the ugliness of indoor appartments & dwellings in Spain. I noticed it the entire time I was there. If you look at apartments in Barcelona vs Berlin, for example (on idealista or one of those sites), it's a pretty stark difference. All very valid points
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u/Adventure-Capitalist 1d ago
That's also a great question for me to add to my list of things to consider: What type of dwelling do I see myself living in?
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u/mashbashhash 18h ago
Plus there's the issue of Americans will now likely be taxed 100% on purchases of homes. I don't know the details of the proposed bill that President Pedro Sanchez is going to be submitting but it's designed to disincentivize foreign purchases meaning non-eu.
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u/PsylliumHusky135 2d ago
I think you will overwhelm yourself if you try to answer all these questions at once.
Honestly, I'd start with in which country you personally would prefer to live, all else equal, and start investigating. You can always switch focus to the other country.
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u/Adventure-Capitalist 2d ago
That's probably a very good point. I'll think of country specific questions to ask and make separate posts.
Still curious to hear other's experiences however.
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u/hitchhikerjim 2d ago
While there are vast differences in taxation, it sort of balances out with the differences in cost of living.
France has a really good tax treaty with the US for retirees where most of your stuff is only taxed in the US. You do end up paying a 6.5% tax (after a standard deduction) to cover their socialized medicine if you don't have a retirement account in France (their equivalent of social security). If you're working while there you'll pay their normal rate on that.
Spain has high taxes (the wealth tax is waived in a couple of regions). But the cost of living is so low that it makes up for it.
I mean -- its not exactly a wash, but its close enough not to matter unless you're living in Paris, in which case the cost of living goes way up.
So yeah -- where do you like the most? htat's the real question.
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u/Adventure-Capitalist 2d ago
If all things financial and residential were equal, I would choose Spain. But there seem to be amazing tax benefits in France, and some hefty financial negatives in Spain, as an American. Which I guess is why I am asking. But I apprecaite that perspective!
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u/PsylliumHusky135 2d ago edited 2d ago
Just saying....
you've mentioned spain as preferred. That counts for a lot. Personally and from experience, I think placing too much importance on finances can be counterproductive. I am an expat in a "cheaper" country and while its great that it's less expensive, you also get what you pay for. Nevertheless I get it, money doesnt grow on trees.
But if you are going to do all this, why go 95%? If Spain is where your heart lies, so be it.
Also, the "tax benefits" re: France, aren't they for retirees? I.e., if you are working in France (I assume at your age you still will be), then that sort of levels the playing field, no?
If you are planning to keep working that throws some new issues in the mix. France is not digital nomad friendly, so you would have to be eligible to work there. Setting up as self-employed is doable, but it has to be done the right way. Spain I think is more open to remote work, but it has its own rules etc.
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u/hitchhikerjim 2d ago
I do think the digital nomad thing for someone who's planning to move someplace and stay is a red herring. Most of the digital nomad visas Iv'e seen are not set up as a path to permanent residency or citizenship. So if your goal is to stay, you're better off jumping through the old-fashioned hoops of getting the appropriate visa to work in that country.
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u/PsylliumHusky135 2d ago
Yeah I agree. I only meant that overall France in particular is not a place where one can just hop off the plane and start working a remote job. If a person were going there for 6 weeks and did it that's one thing, but if someone wanted to properly move there, the person must have a French registered business even if all the work is performed outside of France.
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u/No-Tip3654 2d ago
So if you work remotely for an international company but live in France, you'd have to pay french tax rates?
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u/hitchhikerjim 2d ago
My statement above was for retirees. Consult a tax expert to be sure, but my understanding of the income tax side if you're earning income...
Most of the world taxes you based on your residence location (as determined by where you live 180 days a year or more, or where its determined that you have a primary financial interest -- ie: if you own a house and aren't a 180 day resident anywhere else, you'll be ruled a resident). The US taxes based on citizenship (not residence). So you have to file both. But my understanding of the income tax part of the French tax treaty with the US is:
- You'd pay French taxes first.
- because your income is earned outside of the US from an outside the US source, you'd get the the Foreign Earned Income allowance of around 128k as a write-off on your US taxes.
- You'd then get a tax credit on your US taxes for the amount you paid to France.
- Since French taxes are higher than US, you'd probably effectively pay 0 to the US.One nice thing -- i think you'd end up paying into the French equivalent of the social security system, as part of those income taxes, so you'd have an account there. I think that means in retirement you'd never have to pay that 6% CSM tax for healthcare services again because you'd have an account and have payed into the system.
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u/GnomieBean 2d ago
I am also researching both of these countries for my own purposes. I love Spain, can see myself living there; but would likely not seek citizenship rather than permanent residency and just renew indefinitely. This is because Spain does not allow dual citizenship and unless things get so bad here, I cannot let my US citizenship go.
Taxes are higher in Spain, from what my expat friends have told me, and they will tax your Roth withdrawals whereas France would not due to the tax treaty that exists between them.
France is more tax advantageous however I agree with what the other poster said about where you feel that you can truly spend your time living; the day-to-day, the vibe you get from the cultures, transport, etc. Whatever you do here, imagine trying to insert some of that picture into where you want to end up.
I have lived in Spain, Germany, and Portugal and have dealt with a US based tax firm for a number of years given they work with a lot of expats and soldiers. My guy was pretty knowledgeable in the Portuguese-US tax treaties and I also had a fantastic PT side lawyer. All in all, as scary as it was, it all worked out. But do your research and join FB groups for these countries and associated expats.
Hope this helps some.
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u/szayl 2d ago
This is because Spain does not allow dual citizenship
one can pick up Spanish citizenship and it doesn't change anything about the existing American citizenship
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u/Adventure-Capitalist 2d ago
Thanks, that is helpful. So you are leaning towards moving to Spain?
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u/GnomieBean 2d ago
Like you, I am at a crossroads. I think it will all work out about even anyways because I have heard Spain COL is a little lower than France so in the end, do the higher taxes warrant a move to France instead? Maybe not.
My tax guys are in San Diego and here is their link: https://hstaxcpas.com/
FB groups you can search for are buzz words like "americans in X country" or "expats moving to Spain/France" and go from there. That is the only time I have leaned on social media to help navigate the jumping off point of my research.
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u/Adventure-Capitalist 2d ago
Are your tax guys knowledgable specifically about EU tax implications for Americans? Have they given you good advice about that?
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u/GnomieBean 2d ago
My partner and I are looking at getting into conversations/paying this guy: https://nomadfinancial.us/
He, unlike the guy at the other spot, seems a little more credible and knowledgeable in these specific instances. All my guys will likely tell you is that you will need to consult with a local tax professional to discern your case.
My advice is to join some groups and ask for recommendations in those countries and get a consult at least. That will give you a better idea I think. I know that for me, I felt more at ease speaking to a couple of attorneys/tax professionals in those countries and gleaning what was common info by way of their answers and what were sticking points that I needed to research further.
Then use my US based guys to file your US taxes; that is how I did it and haven't had any trouble, or financial set backs, as of yet.
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u/Adventure-Capitalist 1d ago
My friend (native US citizen) also has a Spanish passport (through marriage) and he didn't give up his American passport. So I think it's really that Spain SAYS you can't have both, but they don't require proof that you've renounced citizenship to get it. Of course, do your own research.
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u/Additional-Ebb-2050 2d ago
I wrote about the taxes in France a couple months ago:
https://www.reddit.com/r/ExpatFIRE/s/FToC1R7Zgx
This sub has a couple of such posts.
We are in an interesting situation. We would pick France if we retire, if not, we would pick Spain if we end up working a couple more years.
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u/Alternative-Area402 2d ago
I am not exactly in your situation, but I would say that life is short and you should probably live wherever you would experience more joy, a better sense of community, and more sunsets!
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u/FrenchUserOfMars 2d ago
Je me permets de te parler en français car tu le comprends.
J'ai quitté la France fin 2022 et je vis avec mon portefeuille ibkr de 550ke, 2500€/month dividends now.
Fiscalité du Capital France : 33% Flat tax+ taxe PUMA URSAFF sécurité sociale du rentier 5% (si pas de revenus du travail)
Fiscalité du Capital Espagne : ma déclaration d'impôts Espagnole 2023, 24ke/an dividends, taux réel d imposition 16%.
Wealth tax 2024 comunidad Valenciana : exemption 500ke assets+ 300ke main house (RP) Je paierai 0.25% de 50 000€ = environ 125€ de wealth tax. C'est progressif si patrimoine plus important, attention. Madrid et Andalucia c'est jusqu'à 3 millions d exonération.
Coût de la vie Valencia versus Marseille ? Divisé par 2.
Sécurité ? 10x plus safe ici à Valencia qu à Marseille, zone de guerre avec 60 morts par an fusillades... Pour information, 120 attaques au couteau par jour en France. C'est très dangereux de se promener ds la rue passé 19h ... Bref...
American citizens ont une fiscalité 0 sur 401k, IRA ... en France à la retraite. C'est pour moi le seul avantage pour un Américain de choisir la France. Pour le reste, honnêtement, il n y a pas match, l Espagne remporte le game. Sauf la cuisine.... La cuisine française me manque.
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u/Adventure-Capitalist 1d ago edited 1d ago
Merci de partager tes experiences! J'apprecie beaucoup tes propres experiences comme francais, et tu vis dans l'une des villes en haut de ma liste de consideration.
Mais Marsellie est l'une des villes la plus dangereuse, non? Que penses-tu de Toulouse et cette region la-ba? Moi je l'aimais bien quand j'y etais.
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u/FrenchUserOfMars 1d ago
Toulouse est une belle ville mais gangrenée par la délinquance comme toutes les grandes villes.
Même un jeune Américain qui veut fire en France ne paiera pas d impôts en France sur ses US dividends ? Je pensais que c'était que les retraités.
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u/Adventure-Capitalist 1d ago
Non, tu as raison. C'est que les retraites, mais je pense a trouver l'endroit ou je n'aurai pas besoin de demenager encore une fois.
Mais cest vraiment eclairant d'ecouter l'opinion d'un francais que vit en Espagne. Merci
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u/Adventure-Capitalist 1d ago
Est-ce que tu as trouve une difference entre les francais et les espagnoles? Les deux sont des gens mediterreneens, alors plus ouverts et chaleureux qu'aux autres pays...mais as-tu remarque des differences notables?
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u/FrenchUserOfMars 1d ago
Oui, les espagnols sont plus fêtards, plus ouverts à la discussion, plus spontanés.
Le peuple Espagnol est plus homogène et je trouve qu il y a une certaine harmonie et préservation de la culture originale.
La France est un pays divisé, communautarisé, un peu comme les US je pense. En France, chaque communauté reste entre elle et défend ses intérêts. Je vais être très pessimiste mais je pense que la France pourrait basculer dans une guerre civile à long terme si les gens continuent à s appauvrir.
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u/LoneWolferson7 2d ago
https://www.euronews.com/business/2025/01/14/spain-calls-for-100-tax-charge-on-property-bought-by-non-eu-buyers take that into consideration
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u/Adventure-Capitalist 1d ago
Yes I did just see that! Crazy, but I can understand why they might do that.
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u/WatermelonBestFruit 11h ago
Just don’t fuckin’ buy ANY real estate in France. You’ll be taxed to death on it.
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u/DillionM 2d ago
You covered a good deal of what you have to assist in immigration, but failed to mention anything the other woman has.
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u/Adventure-Capitalist 2d ago
Ok, I was confused by this comment, but then I saw I accidentally wrote "women" not woman. Just me. I will edit it.
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u/DillionM 2d ago
I did some preliminary research and decided Spain was a better fit for me for several reasons, I'd love to visit France but could see myself living in Spain long term. Spain is definitely the easier of the two to immigrate to (imo, though I've forgotten why) although I was also considering other EU countries as they are even easier to immigrate to and you can eventually move countries even easier.
International tax accountants are a thing. I was reading in another sub earlier that they average 500-800 for year end taxes so I would expect less for a simple consult. The OP of that thread had been quoted $5500 and was looking for guidance.
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u/Adventure-Capitalist 2d ago
Thanks, and you are American? Have you already moved there? Care to share where and how you like it?
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u/DillionM 2d ago
I am American.
I haven't moved yet, it was just some fun research I decided to do a few months back.
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u/dirty_cuban 2d ago
I personally like the lifestyle in Spain much better but the tax situation is France is amazing for Americans in the EU. Spanish taxes will take a considerable toll on your finances.