The Spanish Tax Agency has issued an important clarification regarding the changes introduced by Order HAC/623/2026 to Form 210, which is used by non-resident taxpayers to report Spanish-source income without a permanent establishment.
The key point is that the new filing deadlines do not apply to all 2026 rental income declared separately.
For non-resident taxpayers declaring rental income from Spanish properties on a separate basis, income accrued in April, May, June, July, August and September 2026 keeps the existing filing deadlines:
- April to June 2026: filing during the first 20 calendar days of July 2026.
- July to September 2026: filing during the first 20 calendar days of October 2026.
The new April filing deadline will only apply, for separately declared rental income, to income accrued in the last quarter of 2026.
For rental income declared on an annual grouped basis, the 2026 income will be filed between 1 and 20 April 2027.
For deemed income from urban real estate, the filing deadline for 2025 remains unchanged: 1 January to 31 December 2026. For 2026 deemed income, the new filing period will run from 1 April to 31 December 2027.
The Order also introduces changes to the content of Form 210, including a new annex for deductible expenses and new fields for the number of days and ownership percentage. These content changes will apply to returns filed from 1 January 2027.
The subsequent correction of errors does not alter these conclusions, as it does not affect Form 210 deadlines.
At MDG Advisors, we recommend reviewing the filing calendar carefully to avoid applying the new deadlines too broadly, especially for separately declared rental income accrued before the last quarter of 2026.