Spain · IRNR · Non-Residents · 2026
Spanish Non-Resident Tax Explained: IRNR Guide 2026
Who must file, the 19%/24% rate split, imputed income on unrented property, Modelo 210 deadlines, and what happens if you don't file.
19% / 24%
EU/EEA vs. non-EU/EEA tax rate on Spanish-source income
1.1% / 2%
Imputed income rate on cadastral value if property isn't rented
Modelo 210
The standard non-resident tax filing form
Source: Real Decreto Legislativo 5/2004 (Ley IRNR) · Ley General Tributaria art. 27 · Agencia Tributaria Modelo 210 instructions
Direct answer
Every non-resident who owns Spanish property owes tax — even with no rental income — via "imputed income" of 1.1% or 2% of the cadastral value. EU/EEA residents pay 19%; everyone else pays 24%. Filing is via Modelo 210, with deadlines that vary depending on whether the property is rented or not.
Frequently asked questions
Who has to pay Spanish non-resident tax (IRNR)?
Any individual who owns property in Spain but is not a Spanish tax resident (spends fewer than 183 days per year in Spain and does not have their main economic interests there) is liable for Impuesto sobre la Renta de No Residentes (IRNR), regulated by Real Decreto Legislativo 5/2004. This applies whether the property is rented out, used only as a holiday home, or left empty — the tax base and obligations differ depending on which of these applies, but a filing obligation exists in every case.
What tax rate applies — 19% or 24%?
The rate depends on tax residency, not nationality. Residents of the EU, Iceland, Norway or Liechtenstein pay 19% on Spanish-source income (rental income or imputed income). Residents of all other countries, including the UK since Brexit and the US, pay 24%. EU/EEA residents can also deduct directly-related expenses (mortgage interest, community fees, IBI, insurance, maintenance) from rental income before applying the 19% rate; non-EU/EEA residents historically could not deduct expenses, though this has been contested under EU free-movement case law in some circumstances.
What is "imputed income" and why do I owe tax even if I never rent out my property?
If a non-resident owns a Spanish property that is not rented out (used only personally or left vacant), Spanish tax law deems a notional "imputed income" to exist simply from owning the asset, taxed under art. 24.5 Ley IRNR. The imputed income is calculated as 1.1% of the property's cadastral value (valor catastral) if it was revised after 1994, or 2% if not revised or revised before that date. This deemed income is then taxed at the standard 19%/24% rate. This obligation surprises many foreign owners who assume that no rental income means no tax liability.
How and when do I file Modelo 210?
Modelo 210 is the standard form for non-resident tax without a permanent establishment in Spain. For imputed income on a non-rented property, the filing deadline is the calendar year following the tax year, typically by 31 December of the following year. For rental income, non-residents must file quarterly (within the first 20 calendar days of April, July, October and January, covering the preceding quarter) if using the accrual method, or can file per rental payment received. Filing can be done online via the Agencia Tributaria's Sede Electrónica with a digital certificate, Cl@ve PIN, or through a registered tax representative.
What happens if I don't file Modelo 210?
Non-filing exposes the property owner to surcharges for late filing (recargo por presentación extemporánea, ranging from 1% to 15% depending on delay, under art. 27 Ley General Tributaria) plus late-payment interest, and potentially a formal penalty procedure if the Agencia Tributaria discovers the omission through its own data crossing (Spanish notaries, land registries and utility companies report property transactions and tenancy data that the tax agency cross-references against non-resident tax filings). Non-payment can also complicate a future property sale, since outstanding tax debts can surface during the transaction.
Do I need a fiscal representative in Spain?
EU/EEA residents are generally not legally required to appoint a fiscal representative to file IRNR, though many choose to use a gestor or asesor fiscal for convenience given the language and administrative complexity. Residents of non-EU/EEA countries that Spain considers a tax haven, or in specific circumstances defined by the Agencia Tributaria, may be required to designate a representative with a Spanish address for notification purposes. In practice, most non-resident property owners — regardless of nationality — engage a Spanish tax advisor to handle Modelo 210 filings correctly and on time.
Does owning through a company instead of personally change the tax treatment?
Yes, significantly. Non-resident companies owning Spanish property without a permanent establishment are also subject to IRNR, but under different rules than individuals, and may additionally be subject to the Impuesto sobre Bienes Inmuebles de No Residentes en régimen especial (a special annual 3% tax on cadastral value) if the company is resident in certain listed jurisdictions and beneficial ownership is not disclosed to the Agencia Tributaria — a measure aimed at deterring the use of opaque corporate structures to hold Spanish real estate. Whether personal or corporate ownership is more tax-efficient depends heavily on the owner's home-country tax treatment and should be assessed case by case.
How can IgeraGestories help with non-resident tax questions?
IgeraGestories provides RAG-based assistance for foreign property owners and the gestorías/tax advisors who serve them: it indexes the applicable Ley IRNR articles, double taxation treaties relevant to the client's country of residence, and the client's own property/rental documentation, then answers questions like "what is my imputed income liability this year" or "when is my Modelo 210 deadline" citing the exact article and deadline — available for gestorías serving international clients from €99/month.
Answer non-resident tax questions instantly
IgeraGestories indexes IRNR law and your client's documents, and answers questions citing the exact article and deadline.
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