Same Salary, Less Mortgage: the Real Reason

Two buyers, the same net income, the same flat — one in Munich, one on the Costa Blanca. In Germany the bank waves the financing through, if need be up to the last euro of the price. In Spain the same buyer is suddenly asked to bring well over €100,000 of their own money. Why?

The answer you read everywhere is wrong. It is not the interest rate, and it is not the much-quoted “35% of income in Spain, 40% in Germany” rule. The real difference lies elsewhere — and knowing it keeps you out of the cash trap.

The myth first: the 35%/40% rule explains almost nothing

At their core both countries use the same affordability logic of around 35%. The German 40% is just the upper end of that same range, and in Spain the 35% limit is applied to your total debt service. Five percentage points either way never explain why the same salary carries tens of thousands less in Spain. Three quite different things do.

What really decides it

Loan-to-value. A purchase in Germany is financed, with sound credit standing, up to 100% of the price. A Spanish bank finances non-residents at only up to 70% — and on the lower of price and Tasación (the bank’s own valuation). On a €400,000 property that means €120,000 of equity for the price alone instead of €0. If the Tasación comes in below the price — common with international buyers and coastal locations — the gap grows further.

Purchase costs. In Spain roughly 10 to 13% of the price, which no bank finances. Transfer tax (ITP) alone ranges from 6.5% in the Canaries through 9% on the Costa Blanca to a tiered 13% in the Balearics — plus notary, land registry and gestoría. Together with the equity, our example quickly needs around €160,000 in cash — about 40% of the price.

Age limit. Spanish banks usually require that age plus term not exceed 75. Buy at 55 and you rarely get more than a 20-year term — and a shorter term means, at the same instalment, a smaller loan.

And the law? A real difference — but a different one

Yes, there is a sharp legal difference between the two countries. But it concerns not how much you get, but your rights if the bank assesses you incorrectly. Germany transposed the EU Mortgage Credit Directive (2014/17/EU) with strong consumer rights: if the bank assesses creditworthiness incorrectly, § 505d BGB provides that the rate drops to the market rate and the borrower can exit without a prepayment penalty. Spain transposed the same directive in Ley 5/2019 (LCCI); the solvency check (Art. 11) is mandatory, but the consequences of getting it wrong are mostly supervisory — weaker for the borrower. Important to know, but it is a difference in your rights in a dispute, not a reason for a lower loan amount.

The route hardly anyone uses

There is a way around the 70% ceiling: anyone who owns a lightly encumbered property in Germany can raise capital against it up to 80% of its lending value and finance the Spanish purchase that way — often faster, because no Spanish bank assessment, no Tasación and no age brake come into play. For many buyers that turns “a third in cash” back into “doable”.

I run both routes for you on your real figures — and tell you honestly which one gets the most mortgage out of your equity. The detailed comparison with a worked example is on our sister site: Mortgage in Spain vs. Germany — the real reason.

Sources: Perini’s own brokerage practice (LTV non-residents 70%, purchase in Germany up to 100%, as of 07/2026) · regional ITP rates Spain (Canaries 6.5%, Andalusia 7%, Valencia 9%, Balearics tiered up to 13%) · common age limit age + term ≤ 75 · § 505d BGB · Ley 5/2019 (LCCI), Art. 11 · Directive 2014/17/EU.