Spain’s tax agency has moved the filing window for the annual return that every non-resident property owner has to file. From the 2026 tax year the Modelo 210 for rental income with tax to pay falls due in the first twenty days of April instead of January, and the window for imputed income opens on 1 April instead of 1 January. The change comes from Order HAC/623/2026, published in the official gazette on 23 June 2026 and in force since 24 June.
That order also replaces the form itself. Returns filed from 1 January 2027 use a new version that asks how many days the property was rented out or at the owner’s disposal, what share of it the owner holds, whether it has a cadastral reference, and a category-by-category breakdown of deductible expenses. For an agent with British, German or Dutch clients, this is a compliance item with a date attached, not a talking point.
Why the January Window Disappears in 2027
Since 2024 a non-resident landlord has been able to group a whole year of rental income into a single Modelo 210. Where that return showed tax to pay, it was filed in the first twenty days of January. Order HAC/623/2026 moves the window to the first twenty days of April of the year after the income accrues. Rent received during 2026 is therefore declared between 1 and 20 April 2027, and a direct debit has to be in place by 15 April. The Local set out the new dates on 9 October.
Imputed income runs on a different rhythm. A non-resident who leaves a Spanish property empty still files, because simply having the home at their disposal generates a notional income, and the annual property tax return is how it is declared. That window used to span the whole following calendar year. It now opens on 1 April and closes on 31 December, with 23 December as the cut-off for a direct debit. The first year affected is 2026, so the window opens on 1 April 2027. The tax agency’s own note sets out both dates.
The New Filing Calendar for Non-Residents
Only part of the calendar moves, and that is where clients get confused. Only returns that show tax to pay change. A return that comes out at zero or below keeps its old window, and a claim for a refund still opens on 1 February. The three cases sit side by side here:
| Return | Window before | Window now |
|---|---|---|
| Rental income 2026, tax to pay | 1 to 20 January 2027 | 1 to 20 April 2027 |
| Rental income 2026, nil or negative | 1 to 20 January 2027 | 1 to 20 January 2027 |
| Imputed income 2026 | any time in 2027 | 1 April to 31 December 2027 |
| Imputed income 2025 | 1 January to 31 December 2026 | unchanged |
| Refund claim | from 1 February | from 1 February |
Two exceptions catch people out. A landlord who declares each period separately instead of grouping the year keeps the old rhythm for the first three quarters of 2026, so rent for July to September is still declared in the first twenty days of October 2026 and only the October to December period shifts to April 2027. Separately, the tax agency confirmed that the 2025 imputed income return is untouched and can still be filed up to 31 December 2026, which leaves an owner about eleven weeks from today.
What the New Form Asks Non-Resident Owners
From 1 January 2027 every Modelo 210 uses the revised form, and that includes a return for an earlier year filed late. The additions are few in number and awkward in practice:
- the number of days the property was rented out, or the number of days it was available to the owner
- the percentage of the property the taxpayer owns, which matters when a couple hold it jointly
- whether the property has a cadastral reference, plus the reference itself
- deductible expenses, itemised in a new annex instead of declared as one figure
- a dividend breakdown, where dividends from the same company are grouped into one return
The expense annex is the one to plan for. Categories run from mortgage interest and repairs to community fees, insurance, local taxes such as IBI, and depreciation of furniture and of the building itself, so an owner who has been keeping a single running total needs the invoices separated. Deductions are available only to residents of the EU or of EEA states that exchange tax information, which leaves a British owner taxed on gross rent and filing the annex anyway.
What Agents Should Tell Owners This Month
Nothing here needs a decision before the end of the year, with one exception, and that one is the 2025 return. Five things are worth putting in front of a client now:
- Delete the January 2027 reminder for rental income and diarise 1 to 20 April 2027 instead
- Check whether the 2025 imputed income return has been filed, because that window closes on 31 December 2026
- For a property bought during 2026, expect a part-year imputed income return in the 2027 window
- Start separating expense invoices by category, since the new annex asks for them item by item
- Find the cadastral reference and the ownership share before the form asks for them
What the April Deadline Means for Owners
This is a procedural change, not a tax rise. Rates are untouched, the capital gains deadline of four months from a sale is untouched, and the four-year window for reclaiming an overpayment is untouched. What moves is when money leaves an owner’s account, and how much of the paperwork behind the return has to be defensible.
That makes April 2027 the first real test. A landlord who grouped 2026 income will file on the new form, with the new annex, inside a window that plenty of owners and agents still associate with January. The practical answer is to treat the shift as a deadline worth repeating twice, once now and once in the new year.
Questions Agents Ask About Spain’s Modelo 210
These come up as soon as a client realises the return is annual rather than something their bank handles on their behalf.
Who has to file a Modelo 210?
Any non-resident who owns property in Spain, whether it is rented out, used for holidays or left empty. Owners who hold a home jointly each file their own return, which is how one flat generates two filings a year.
Does the change affect the 2025 return?
No. The 2025 imputed income return keeps its old window and can be filed until 31 December 2026. Rental income for 2025 was already due in January 2026 under the old rule. The new calendar starts with income accrued during 2026.
What happens if a client files late?
Spain’s general tax law adds a surcharge on top of the tax due, and the surcharge grows the longer the return is outstanding. Filing voluntarily is cheaper than waiting to be asked, which is the argument for moving the reminder rather than dropping it.
Do foreign buyers pay this tax as well?
Yes, and the obligation starts with ownership rather than with a rental contract. Foreign buyers who complete on a Spanish property during 2026 should expect a first imputed income return covering the part of the year they owned it, filed between April and December 2027.
Is the Modelo 210 the same as the wealth declaration?
No. Modelo 210 declares income from Spanish property. Modelo 720 is a separate informative declaration that residents of Spain file about assets held abroad, and it does not apply to a non-resident owner.
