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
- US-France income tax convention (1994), irs.gov
- Convenio España-Estados Unidos (BOE-A-1990-30940)
- US-Portugal income tax convention (1994), irs.gov
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.