Levent, Istanbul: where agent commission is capped by law and who pays it, twelve countries compared

Real estate agent fees by country: who caps them, who pays them.

Agent fees, compared. 21 countries. Caps, who pays, VAT. Brinkman Data brand card.

// 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.

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.

CountryCommission rateWho paysVAT on the fee
JapanCapped: 5.5% / 4.4% / 3.3% by price band, tax includedEach client pays their own broker10%, included
TurkeyCapped: 4% of the price in totalSplit equally unless agreed otherwise20%
MalaysiaCapped: 3%, minimum RM1,000The client who appoints the agent8% service tax
Cyprus3% by law if the contract names no feeWhoever engages the agent19%
GermanyNot set; 4.76% to 7.14% incl. VAT was customary (2019 bill)Home buyer pays at most what the seller pays19%
ItalyNot set nationally; local custom (Pistoia: 2% each side)Both buyer and seller22%
FranceNot capped; maximum fees must be displayedPer the mandate, stated on every advert20%, included
GreeceFreely negotiated, in a written contractWhoever signed with the agent24%
SpainNot setWhoever signed with the agent21%
PortugalSet in the mediation contractWhoever signed with the agent23%
Dubai (UAE)By agreement (Bylaw No. 85 of 2006)Per the RERA contracts5%
PhilippinesNot set; licensed brokers onlyPer the written agreement12%
Bali (Indonesia)Set by regulation: 2% to 5% on a saleWhoever engages the firmEffectively 11%
CroatiaCapped at the agency's own price list (2026 Act)Whoever signed a contract; no advance fees25%
MontenegroNot capped; must be in the contract and inside the asking priceWhoever signed the contract21%
VietnamAgreed with a licensed firmThe firm's client10%
ColombiaAgreed, or the usual rateSplit equally by default19%
Costa RicaAgreed, or the usual market rateThe party the broker acted for13%
PanamaMarket rate unless agreed; licensed brokers onlyWhoever hired the broker7%
Mexico (Quintana Roo)As agreed; state licence requiredPer the agreement16%
Dominican RepublicAs agreed; no licensing law foundPer the agreement18%

Each country name opens the full page, with the law and the official source behind every figure.

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.

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.

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Frequently Asked Questions

Which countries cap real estate agent commission?
Of the twenty-one compared here: Japan (by price band, per client), Turkey (4% in total) and Malaysia (3%) cap it in law; Indonesia sets 2% to 5% by regulation; Croatia caps it at the agency price list; Cyprus sets 3% when the contract names no fee.
Does the buyer pay the real estate agent abroad?
It depends on the country: in Italy both sides pay, in Japan each client pays their own broker, in Turkey the fee is split, and in Germany a home buyer pays at most half.
Is VAT charged on estate agent fees?
VAT or a similar tax applies in all twenty-one, from 5% in the UAE to 25% in Croatia. In Japan and France the displayed fee already includes it.
Which country has the highest agent fees?
Where fees are not capped there is no official average. Germany's 2019 government bill put the customary total at 4.76% to 7.14% including VAT, the highest figure published by any official source here.

Header photo: ampersandyslexia, CC BY 2.0, via Wikimedia Commons. All credits: image credits.

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Disclaimer

Brinkman Data Analytics is an independent research service. Not financial, investment, tax, or legal advice. All yield figures are estimates based on historical research data and are not guaranteed. International real estate carries risk of partial or total loss of capital.