Real estate agent fees by country: who caps them, who pays them.
// Short answer
Of the twenty-one countries we checked, three cap an agent's commission in law: Japan (3.3% of the price above JPY 4 million, per client, tax included), Turkey (4% in total) and Malaysia (3%). Indonesia sets a 2% to 5% band by regulation, Croatia caps it at the agency's price list, and Cyprus sets 3% when the contract names no fee. Everywhere else the rate is whatever you sign, which makes who pays the bigger question: in Italy and Japan the buyer pays an agent too, and in Germany a home buyer pays at most half.
Rules and rates as of October 2026, as published on each country page. Not legal or tax advice.
On this page
Where is real estate agent commission capped by law?
Japan, Turkey and Malaysia. Japan caps the fee per client by price band (3.3% above JPY 4 million, tax included); Turkey caps the total at 4% of the price before VAT; Malaysia caps it at 3% with a minimum of RM1,000. Cyprus sets a 3% default when the contract is silent.
| Country | Commission rate | Who pays | VAT on the fee |
|---|---|---|---|
| Japan | Capped: 5.5% / 4.4% / 3.3% by price band, tax included | Each client pays their own broker | 10%, included |
| Turkey | Capped: 4% of the price in total | Split equally unless agreed otherwise | 20% |
| Malaysia | Capped: 3%, minimum RM1,000 | The client who appoints the agent | 8% service tax |
| Cyprus | 3% by law if the contract names no fee | Whoever engages the agent | 19% |
| Germany | Not set; 4.76% to 7.14% incl. VAT was customary (2019 bill) | Home buyer pays at most what the seller pays | 19% |
| Italy | Not set nationally; local custom (Pistoia: 2% each side) | Both buyer and seller | 22% |
| France | Not capped; maximum fees must be displayed | Per the mandate, stated on every advert | 20%, included |
| Greece | Freely negotiated, in a written contract | Whoever signed with the agent | 24% |
| Spain | Not set | Whoever signed with the agent | 21% |
| Portugal | Set in the mediation contract | Whoever signed with the agent | 23% |
| Dubai (UAE) | By agreement (Bylaw No. 85 of 2006) | Per the RERA contracts | 5% |
| Philippines | Not set; licensed brokers only | Per the written agreement | 12% |
| Bali (Indonesia) | Set by regulation: 2% to 5% on a sale | Whoever engages the firm | Effectively 11% |
| Croatia | Capped at the agency's own price list (2026 Act) | Whoever signed a contract; no advance fees | 25% |
| Montenegro | Not capped; must be in the contract and inside the asking price | Whoever signed the contract | 21% |
| Vietnam | Agreed with a licensed firm | The firm's client | 10% |
| Colombia | Agreed, or the usual rate | Split equally by default | 19% |
| Costa Rica | Agreed, or the usual market rate | The party the broker acted for | 13% |
| Panama | Market rate unless agreed; licensed brokers only | Whoever hired the broker | 7% |
| Mexico (Quintana Roo) | As agreed; state licence required | Per the agreement | 16% |
| Dominican Republic | As agreed; no licensing law found | Per the agreement | 18% |
Each country name opens the full page, with the law and the official source behind every figure.
Sources
Does the buyer pay the estate agent?
In some countries, yes, by law or by design. In Italy the agent is owed a commission by each party. In Japan each client pays their own broker, up to the cap. In Turkey the fee is split equally unless agreed otherwise. In Germany, since 2020, a home buyer pays at most what the seller pays.
In France the split is printed on every sale advert. In Spain, Portugal, Greece and Cyprus it is whoever signs with the agent, so read anything you are asked to sign before a viewing.
Sources
How do I check that a foreign estate agent is licensed?
Most of these countries license agents and publish a register: the PRC in the Philippines, LPEPH in Malaysia, the Ministry of Trade's TTBS in Turkey, MLIT in Japan, the DLD in Dubai, IMPIC in Portugal, the Registration Council in Cyprus. Spain has no national licence; Catalonia keeps its own register.
In Cyprus a deal with an unlicensed agent is invalid; in the Philippines only a licensed broker may collect a fee. The search link for each register is on the country page.
Sources
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See the $499 report, page by pageFrequently Asked Questions
Which countries cap real estate agent commission?
Does the buyer pay the real estate agent abroad?
Is VAT charged on estate agent fees?
Which country has the highest agent fees?
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