Order HAC/623/2026, of 12 June, introduces changes to both the content and filing deadlines of Form 210 for Non-Resident Income Tax, in relation to imputed income from urban properties and income derived from rented or sublet properties.
Changes to the content of Form 210
From 1 January 2027, the tax returns filed must include the following changes:
- A new annex providing a breakdown of deductible expenses relating to rented or sublet properties.
- A new “Number of days” box, to indicate the number of days during which the property has been available to the taxpayer or has been rented out.
- A new “Ownership percentage” box, to indicate the taxpayer’s percentage ownership of the property.
These changes will apply to tax returns filed from 1 January 2027 onwards, regardless of the date on which the income arose.
Imputed income from urban properties
The filing period will run from 1 April to 31 December of the year following the year in which the income arises, instead of starting on 1 January.
This new deadline will apply for the first time to imputed income corresponding to the 2026 tax year, which must be declared between 1 April and 31 December 2027.
Imputed income corresponding to 2025 will retain the usual filing period, from 1 January to 31 December 2026.
Income from rented or sublet properties
Tax returns resulting in an amount payable must be filed during the first 20 calendar days of April of the year following the year in which the income arises, regardless of whether the income is declared separately or on an aggregated basis.
Where payment is made by direct debit, the deadline will run from 1 to 15 April.
For income declared on an aggregated basis, the new deadline will apply to income corresponding to the 2026 tax year.
Where income is declared separately, the new deadline will apply only to income arising during the final quarter of 2026.
Therefore, a non-resident taxpayer who rented out their property during July, August and September 2026 and chose to declare each rental income amount separately must file the corresponding Form 210 returns, without the latest amendments, during the first 20 calendar days of October 2026.
For rental income corresponding to October, November and December 2026, Form 210 must be filed incorporating the latest amendments introduced by Order HAC/623/2026, within the period from 1 to 20 April 2027.
In addition, for income arising from 2024 onwards, the aggregation period for rental income from properties is annual.
These changes affect both the content of Form 210 and the filing deadlines applicable to certain types of property income obtained by non-resident taxpayers.
At MDG Advisors, we can assist non-resident clients with reviewing their tax obligations in Spain, as well as with the preparation and filing of their Form 210 tax returns in accordance with the applicable regulations.