New reporting requirements and changes to filing deadlines
Order HAC/623/2026, dated 12 June and published in the Official State Gazette (BOE) on 23 June 2026, introduces amendments to Form 210 (Modelo 210) for Non-Resident Income Tax (IRNR), applicable to taxpayers earning income in Spain without a permanent establishment, that is, without an office, branch or fixed place of business in the country.
The changes particularly affect imputed income from urban properties and income derived from the rental or subletting of properties, with the aim of improving the information available for verifying self-assessed tax returns and processing refund applications.
New Reporting Requirements for Form 210 from 2027
Regarding the content of the form, a specific annex is introduced to provide a breakdown of deductible expenses relating to rented or sublet properties.
In addition, new fields for "Number of Days" and "Ownership Share" are introduced to identify the number of days during which the property was available to the taxpayer or rented out, depending on the type of income, as well as the percentage of ownership held by the taxpayer filing the return.
A dividend breakdown annex is also introduced for certain cases involving grouped returns requesting refunds of withholding tax, together with new identification fields.
These changes to the form’s content will apply to self-assessed tax returns filed from 1 January 2027, regardless of the date on which the tax liability arose, in other words, even if the income being reported was earned before that date.
Changes to Form 210 Filing Deadlines
The filing period will run from 1 April to 31 December of the calendar year following the year in which the tax liability arises.
They must be declared between 1 April and 31 December 2027.
As a general rule, the filing deadline will be the first twenty calendar days of April of the following year, whether taxpayers opt for an annual grouped return or file separate returns.
Transitional Rules for Form 210 for Income Earned in 2025 and 2026
The sole final provision of the aforementioned Order specifies that imputed income for 2025 remains subject to the filing deadline applicable during 2026, until 31 December.
Likewise, rental income reported through separate returns (on a quarterly basis) for the months from April to September 2026 remains subject to the ordinary filing deadlines.
However, for separate returns, the new filing deadline applies to income accruing during the last quarter of 2026 (October to December).
For annual grouped returns (a single return covering the whole year), the new deadline applies to income earned throughout the entire 2026 tax year. In both cases, the return must be filed between 1 and 20 April 2027.
Tax Obligations and Recommendations for Non-Resident Property Owners
From a practical perspective, non-resident property owners in Spain and their advisers should review the filing calendar according to the type of income and filing method, as well as adapt their document collection procedures to substantiate deductible expenses, periods of property availability or rental, and ownership percentages.
It is important to distinguish between the date on which the tax liability arises and the filing date, as the new reporting requirements may apply from January 2027 even to income accrued in previous periods.
Tax planning should be carried out in accordance with Order HAC/623/2026 and the specific instructions published by the Spanish Tax Agency (AEAT).
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