Mortgage rules by country: how the UAE, UK, France, Spain, Portugal, Greece, Germany, and Switzerland differ

Mortgage rules aren’t harmonised. A 75% LTV that’s standard in the UK is the maximum non-resident loan you’ll get in Switzerland. A 25-year term that’s typical in France becomes a 30-year baseline in Portugal. The stamp duty that wipes out 7% of your purchase budget in France barely exists in Greece. If you’re shopping across borders, the rules are where the surprises live.

This guide walks through the eight countries the mortgage calculator covers — the same eight that account for most of our users’ cross-border portfolios. For each country: the four levers that actually determine what you pay (LTV cap, term, rate, transaction costs), plus the non-obvious rules that catch first-time buyers in that market.

The four levers, applied everywhere

Before going country by country, the framework. Every mortgage decision in every country comes down to four numbers:

1. Maximum LTV. What percentage of the property the lender will fund. The bigger this is, the smaller the deposit you need — but the higher the monthly payment.
2. Maximum term. How many years the loan can be amortised over. Longer term = lower monthly = more total interest.
3. Interest rate (and structure). Whether fixed for the whole term, fixed for a period then variable, or variable from day one. See the mortgage types guide for the structure trade-offs.
4. Transaction costs. Transfer tax, stamp duty, notary, agent, lender fees. Range from ~3% in Greece to ~12% in France. This is the sleeper cost most owners underestimate by half.

We’ll hit all four on every country below. Numbers are current as of mid-2026; rules change so verify with a local broker before committing.

🇦🇪 United Arab Emirates

LTV.Residents: up to 80% on properties at or below AED 5m, 70% above. Non-residents: 50% (40% above AED 5m). These are Central Bank caps; banks can’t lend higher.

Term. Max 25 years. Max borrower age 65 at maturity for most banks (some go to 70).

Rate structure. Variable (EIBOR-linked) is the default. Most products bundle a 1–5 year fixed introductory period before reverting to EIBOR + margin. True full-term fixed mortgages are rare.

Transaction costs. Dubai Land Department transfer fee: 4% of the price. Mortgage registration: 0.25% of the loan amount + ~AED 290 admin. Agent commission (buyer-side): 2%. Trustee fee: AED 4,000 fixed. Total completion costs typically 6–7% of price.

🇬🇧 United Kingdom

LTV. Residential: 90–95% for first-time buyers; 85% standard. Buy-to-let: 75% typical, some lenders to 80%. Non-resident BTL: usually capped at 70%, sometimes 65%.

Term. Residential up to 40 years. BTL up to 25–30. Max borrower age at maturity usually 75 (lender-specific).

Rate structure.Fix-then-revert is the dominant model: 2-year, 5-year, or 10-year fix, then reverts to the lender’s Standard Variable Rate (SVR) which is typically 2–4 percentage points higher than the headline fixed rate. Active investors remortgage 2–3 months before the fix ends.

Stress tests.BTL lenders require rental cover at a stressed rate (typically 125–145% of mortgage interest at SVR + 1pt, depending on tax status and property type). If the rent doesn’t cover the stressed payment, you don’t get the loan — irrespective of the actual current rate.

Transaction costs. Stamp Duty Land Tax (SDLT) is progressive and brutal on additional properties — a 5% surcharge applies across all bands. On a £350k investment property the SDLT alone is ~£23k. Plus solicitor (£1,500–3,000), survey (£600–1,200), lender arrangement fee (often £999–1,999). Total: ~7–9% of price on a BTL.

🇫🇷 France

LTV. Residents: up to 100% in theory; in practice 85% is the comfortable maximum without dipping into specialist lenders. Non-residents: 70–80% with French income proof, lower without.

Term. Max 25 years. Max borrower age at maturity 75. The High Council for Financial Stability (HCSF) caps debt-service-to-income at 35% — enforced strictly. If your existing debts + the new mortgage payment exceed 35% of net income, the loan is refused regardless of LTV headroom.

Rate structure.Long fixed-rate mortgages dominate — 20-year and 25-year fixes are normal pricing. The certainty premium is small. Early redemption charges (IRA — Indemnité de Remboursement Anticipé) apply if you sell or refinance early; capped at 3% of remaining principal or 6 months’ interest.

Transaction costs.“Frais de notaire” are ~7–8% of price on existing-build (predominantly transfer taxes, not the notary’s fee). On new-build (VEFA) the figure drops to ~2–3% but you pay 20% VAT on the price instead.

Mortgage life insurance. Assurance emprunteur is effectively mandatory and adds 0.2–0.4% per year on top of the headline rate. Comparing a French fixed rate to a UK fixed rate without including this is misleading.

🇪🇸 Spain

LTV. Residents: 80% of purchase or appraised value, whichever is lower. Non-residents: 60–70% maximum, depending on lender and proof of income.

Term. Up to 30 years. Max borrower age at maturity 75.

Rate structure. Historically Euribor + margin was the standard; competitive fixed-rate products (20–30 year) now win most new business. Discount-then-fixed structures are common.

Transaction costs. ITP (Impuesto de Transmisiones Patrimoniales) on resale ranges 6–10% by autonomous community — Madrid 6%, Catalonia 10%, Andalusia 7%. New-build attracts 10% VAT + 1.5% AJD stamp duty instead. Plus notary, registry, legal, gestoría — another ~2%. Total: 9–13% of price.

🇵🇹 Portugal

LTV. Residents: up to 90% for own residence, 80% for other. Non-residents: 70% typical, occasionally 80%.

Term. Up to 35 years, but tighter for older borrowers (often 75 minus your current age, so a 50-year-old maxes at 25 years).

Rate structure. Traditionally Euribor-linked. Banks now offer mixed products: 3, 5, 7, or 10-year fixes then revert to variable. Long full-term fixes are uncommon.

Transaction costs. IMT (Imposto Municipal sobre as Transmissões) is progressive. For permanent home: 0% under €92k, then bands at 2% / 5% / 7% / 8% / 6% / 7.5%. For secondary/investment: bands start at 1% (lower floor) but escalate similarly. Plus Imposto do Selo (stamp duty) at 0.8% on the price + 0.6% on the mortgage. Notary, registry, legal: ~1%. Total: 6–9%.

🇬🇷 Greece

LTV. Residents: 80% maximum. Non-residents: 60% in practice, often with a requirement to bank locally.

Term. Up to 30 years. Lending market still narrower than pre-2010s — fewer products, more conservative underwriting.

Rate structure. Predominantly Euribor + margin (variable). Short fixes available. Long fixes rare.

Transaction costs. Transfer tax 3.09% on resale — the lowest of any country on this list. New-builds (post-2006 licence) attract 24% VAT instead, which essentially makes them only feasible to buy if you can recover the VAT (commercial activity). Plus notary (~1.5–2%), legal (~1%), agent commission (~2% buyer-side), and registration fees. Total: 7–9% for resale.

Mandatory lawyer + engineer. Greek purchase contracts require a lawyer; an engineering survey is technically optional but strongly advised (illegal additions and planning anomalies are common). Budget €2,000–4,000 for both combined.

🇩🇪 Germany

LTV. Residents: up to 80% (occasionally 90% with very strong income). Non-residents: typically 60%, sometimes 70% with German income.

Term. Up to 35 years.

Rate structure. Long Zinsbindung (fixed-rate period) is the German default — 10, 15, 20, even 30 years. The Tilgung (annual amortisation rate, separate from the interest rate) is negotiated upfront — typically 2–3% of the original loan, meaning the loan amortises slowly. Most borrowers remortgage at the end of the Zinsbindung period.

Transaction costs. Grunderwerbsteuer (transfer tax) varies by Bundesland: 3.5% (Bayern, Sachsen) up to 6.5% (NRW, Schleswig-Holstein, Saarland). Notary + Grundbuch (land registry): 1.5–2%. Buyer-side agent commission: 1.78–3.57% by region (Provisionsteilung — shared with seller since 2020). Total: 7–12%.

🇨🇭 Switzerland

LTV. Residents: 80% maximum, with at least 10% of the purchase price from non-pension equity (the other 10% can come from pillar 2 pension). Non-residents: 50–60%, subject to Lex Koller restrictions on foreign ownership of holiday homes.

Mandatory amortisation. Any loan above 66.6% LTV must be amortised down to 66.6% within 15 years. So a borrower at 80% LTV has to make additional principal payments (above the standard amortisation) over the first 15 years.

Affordability stress test. Imputed mortgage payment + maintenance must not exceed 33% of gross income — at a stress rate of ~5%, not the actual market rate. Swiss banks reject mortgages routinely on affordability grounds even when LTV is fine.

Rate structure. Long-term fixed (10, 15-year) competitively priced vs SARON-linked products. Mix of fixed + flex tranches common — split a CHF 1m loan into 60% fixed for 10 yrs, 40% on SARON, for example.

Transaction costs. Vary significantly by canton. Transfer tax + notary + registry: 2.5–4% combined. Geneva and Vaud at the high end; Zurich and Schwyz lower.

Cross-border patterns: what changes when you cross a border

A few generalisations that hold up across these eight markets:

1. Non-resident LTV is always lower.Expect a 10–25 percentage point haircut on max LTV when you’re not a tax resident. Plan for it in your deposit calculation.
2. Transaction costs are bigger than you think. The minimum is ~5% (Greece resale), the maximum is ~13% (Spanish region + new-build VAT combinations). Most owners underestimate by 30–50% on first cross-border purchases.
3. Stress tests bite differently. UK BTL applies a rental cover ratio. France applies a household DTI cap. Switzerland applies an income cap at a stressed rate. Knowing which stress test your lender will apply is often more important than the headline rate.
4. Currency exposure matters.Borrowing in EUR to buy a Greek property when your income is in AED creates a currency-mismatch risk that doesn’t show up on the mortgage application. Multi-currency portfolios need a deliberate position on this.
5. Local equivalents are not always actually local. Some international banks (HSBC, BNP Paribas, Banco Santander) offer mortgages in multiple countries to existing private-banking clients, sometimes cross-collateralised. This can occasionally beat the local market — worth asking if you already have a relationship.

What to bring to your first conversation with a lender

Whatever the country, the documents are remarkably similar:

• Passport + visa / residency status proof
• Last 6 months bank statements (all accounts, all currencies)
• Last 2 tax returns + 3 months payslips (or 2 years of accounts if self-employed)
• Property details: address, agreed price, type, square metres, any agreed conditions
• Source of funds declaration for the deposit (AML)
• Global asset declaration (mortgages, investments, other property) — increasingly required cross-border

Allow 6–8 weeks from first contact to mortgage offer; another 4–6 weeks to drawdown. Cross-border applications take longer — the lender will request translations and notarisations you didn’t expect.