Spain, Portugal or France? Comparing them for American retirees

How Spain, Portugal and France compare for Americans retiring on Social Security and IRAs: visas, residence rules, how each taxes US retirement income, wealth and inheritance, and part-year options.

Updated · Expat Academy · Education, not advice

All three countries welcome American retirees, and all three tax residents on worldwide income. The differences are in the details, and they can be worth thousands of dollars a year.

At a glance

Spain Portugal France
Retirement visa Non-lucrative visa: 400% of IPREM, about €2,400 a month for one D7: minimum wage, €920 a month for one Visitor visa: net minimum wage, about €1,443 a month per applicant
Long season without moving 90 days in 180 only Golden Visa (7 days a year) or 90 in 180 Temporary long-stay visa, 4 to 6 months
When residence starts Whole calendar years (no split) From your arrival (split year) From your arrival (split year)
The days test More than 183 in the calendar year More than 183 in any 12 months, or a habitual home Main place of stay, among four tests
IRA and 401(k) money Spain's scale, about 19% to 47%+ Portugal's scale, 12.5% to 48% Credited away: only the US tax
US Social Security Taxed by Spain, US source tax credited Read two ways Credited away: only the US tax
Interest, dividends, gains 19% to 30% 28% 12.8% (often credited) plus 18.6% social charges
Wealth tax Above €700,000 (relieved in Andalusia, Madrid) None Real estate above €1.3 million only
Inheritance to children Regional; 99% relief in several regions Exempt Taxed above €100,000 per parent

How to read it

  • If most of your income is Social Security and IRA withdrawals, France's treaty is unusually favourable: that income bears only US tax. Spain and Portugal tax it at their own rates, which are usually higher than the US.
  • If a large taxable account pays your way, compare Portugal's 28%, Spain's 19% to 23% at moderate amounts, and France's social charges.
  • If you want long seasons without moving, France's temporary visa and Portugal's Golden Visa offer more than Spain's 90 days.
  • If passing on wealth matters most, Portugal's exemption for children is hard to beat; Andalusia and Madrid come close.

What doesn't change

Whichever country you choose, the US keeps taxing you as a citizen: you file a US return every year, the FBAR once your foreign accounts pass $10,000, and you keep a US state domicile somewhere. Medicare doesn't pay abroad in any of the three, so healthcare is a budget line in each. And the exchange rate moves your costs in all of them, because your income is in dollars and your life is in euros.

Each country's guides go deeper: retiring to Spain, retiring to Portugal and retiring to France.

Questions

Which country taxes US retirement income least?

For many American retirees, France, because the US-France treaty leaves Social Security and IRA withdrawals taxable only in the US, with French tax credited away. Spain and Portugal tax that income at their own rates. Investment income is a different story, and your mix decides.

Which country is easiest for a long season without moving?

France offers a temporary long-stay visa for four to six months. Portugal's Golden Visa allows long stays with only seven days a year required. Spain has no seasonal visa for retirees, so seasons stay within 90 days in 180.

Which has the lightest inheritance tax?

Portugal, which exempts spouses, children and parents. Several Spanish regions relieve 99% for close family. France taxes children above a €100,000 allowance per parent.

Sources

Education, not advice. This guide explains general rules as of the date above. Rules change every year; confirm your own situation with a qualified adviser in the US and in France.