If you own a home in Spain but live abroad, the annual Modelo 210 tax return is probably already on your radar. Now there is important news: the Modelo 210 deadlines are changing. On 23 June 2026, the Spanish Official State Gazette (BOE) published Order HAC/623/2026, of 12 June, which amends the rules governing the form and, crucially, moves the filing windows for non-resident property owners. If you have a January reminder in your calendar, you will need to update it.
In this article we explain what changes, when the new rules first apply, and what practical steps you should take before the 2027 filing season.
⚖️ A Quick Refresher: What Is Modelo 210 and Who Must File It?
Modelo 210 is the tax return for Spain’s Non-Resident Income Tax (Impuesto sobre la Renta de no Residentes, or IRNR), used by non-residents who earn income in Spain without a permanent establishment.
Here is the point that still surprises many British and European owners: you must file Modelo 210 even if you never rent out your Spanish property. Under Articles 13.1.h) and 24 of the consolidated Non-Resident Income Tax Act (Real Decreto Legislativo 5/2004, known as the TRLIRNR), simply having a property in Spain at your disposal generates what is called imputed income (renta imputada) — a notional income calculated on 2% of the property’s cadastral value (valor catastral) as a general rule, or 1.1% where the cadastral value has been revised within the previous ten tax periods, according to the Spanish Tax Agency’s own guidance.
In short: every non-resident who owns Spanish property has a Modelo 210 obligation — whether the property sits empty, is used for holidays, or is let to tenants.
Do not confuse Modelo 210 with Modelo 720, which is a purely informative declaration for residents of Spain about assets held abroad — we explain the difference in our article Modelo 720: A Crucial Tax Obligation for Residents.
📍 The New Modelo 210 Deadlines under Order HAC/623/2026
Order HAC/623/2026 amends Order EHA/3316/2010 — the ministerial order that approved forms 210, 211 and 213 and whose Article 5 sets the filing deadlines. There are three key changes.
🧾 Change 1: Imputed Income — Filing Now Starts on 1 April, Not 1 January
For the imputed income return (the one you file when the property is at your own disposal and not rented out):
- Old rule: the return could be filed at any point during the entire calendar year following the tax year — from 1 January to 31 December.
- New rule: the filing window runs from 1 April to 31 December of the calendar year following the year in which the income accrues.
First application: imputed income for 2026, which you will be able to file from 1 April 2027 onwards. In practice, you lose the option of filing in the first quarter of the year — a habit many owners (and their advisers) had built around the January-to-March period. One practical nuance: if you pay by direct debit (domiciliación bancaria), the Order sets an earlier cut-off of 23 December.
🏠Change 2: Rental Income with Tax Payable — Moves from January to April
Since 2024, non-residents letting Spanish property have been able to group a full year’s rental income into a single annual Modelo 210. Where the result was tax payable, that annual return was due in the first 20 days of January of the following year.
Order HAC/623/2026 changes this:
- New rule: annual returns for rental income with tax payable must be filed within the first twenty calendar days of April of the year following the year of accrual.
- This already applies to 2026 rental income: rent accrued during 2026 will be declared between 1 and 20 April 2027 — not in January 2027.
Key takeaway: if you let your Spanish property, delete that January reminder. Your 2026 annual rental return is now an April 2027 obligation.
🛠️ Change 3: A New, More Detailed Form from 1 January 2027
From 1 January 2027, a revised version of Modelo 210 comes into use, and it asks for noticeably more detail:
- An annex breaking down, item by item, the deductible expenses claimed against rental income — required whenever you deduct expenses on the new form;
- New informative boxes, including the number of days the property was at the owner’s disposal, the percentage of ownership, and the cadastral reference (referencia catastral) of the property.
In other words, it will no longer be enough to declare a single net figure: the Tax Agency wants to see which expenses you deducted, item by item.
đź§ Why the Expense Annex Matters More for Some Owners Than Others
The new expense breakdown is particularly relevant because of who can actually deduct expenses in the first place. Under Article 24.6 of the TRLIRNR, only taxpayers resident in the EU or in EEA states with effective exchange of tax information may deduct expenses (mortgage interest, community fees, repairs, insurance and so on) from their Spanish rental income. Combined with the rates in Article 25 of the same law, the general picture is:
- EU/EEA residents: taxed at 19% on net rental income (income minus deductible expenses);
- UK residents (post-Brexit) and other non-EU/EEA residents: taxed at 24% on gross rental income, with no deductions.
So if you are resident in Ireland, Germany or the Netherlands, the new annex means you will need your expense invoices organised with far more granularity than before. If you are UK-resident, the annex changes little for you — but the deadline changes very much do. And if you let your property to holidaymakers, remember there may be additional obligations, as we covered in Tourist Rentals & VAT in Spain.
⚠️ What Happens If You File Late?
Missing a Modelo 210 deadline is not cost-free. Under Article 27 of the General Tax Law (Ley 58/2003), filing after the deadline without a prior demand from the Tax Agency triggers late-filing surcharges on top of the tax due, and the position worsens the longer you wait. As a general rule, filing voluntarily — even late — is always better than waiting for the Tax Agency to come to you, but the best outcome is simply to diarise the new dates now.
âś… Expat Checklist: Getting Ready for the New Deadlines
- Update your calendar reminders now. Imputed income for 2026: filing opens 1 April 2027 (window runs to 31 December 2027, or 23 December if paying by direct debit). Annual rental returns with tax payable for 2026: 1 to 20 April 2027.
- Delete any January 2027 reminder for your annual rental return — filing in January will no longer be the correct window.
- Keep and organise expense invoices (EU/EEA residents): the new form will require an itemised breakdown of the expenses you deduct.
- Locate your referencia catastral (it appears on your IBI council tax receipt) and note your exact ownership percentage — the new form asks for both.
- Track the days the property was at your disposal versus rented out during the year — another new informative box.
- Co-owners each file their own return as a general rule, so make sure every owner (spouses included) has the new dates in their diary.
- If you have missed past years, take advice on regularising voluntarily before the Tax Agency contacts you, to limit Article 27 surcharges.
đź”— Sources and Further Reading
- Order HAC/623/2026, of 12 June — full text (BOE no. 152, 23 June 2026)
- Spanish Tax Agency — official Modelo 210 page
- Tax Agency guide: Non-Resident Income Tax without permanent establishment
- Tax Agency: taxation of property owned by non-residents
- Consolidated text of the Non-Resident Income Tax Act (TRLIRNR)
📍 Need Help with Your Modelo 210?
At MT Solicitors in Vera (AlmerĂa), we prepare and file Modelo 210 returns for non-resident property owners across the region — whether your property is empty, used for holidays or rented out. We can review your position under the new rules, set up the correct filing calendar for 2027 and, if needed, help you regularise previous years.
Get in touch at sara@mtsolicitors.com for personalised advice on your Spanish tax obligations.
This article provides general information about Spanish law and does not constitute legal advice. For advice tailored to your situation, contact MT Solicitors.
