Rental Income in a Split Tax Year in Spain in 2026: How to Report Partial-Year Rental Earnings When You Become Resident Mid-Year
Split-year rental tax in Spain: IRNR at 19 or 24 per cent pre-residency, then IRPF with the 50-90 per cent resident reduction and 2026 filing changes.
When you become Spanish tax resident partway through the year, your rental income does not simply switch tax regimes on the day you arrive. Spain treats residency as a full calendar year status under Article 9 of Ley 35/2006 (LIRPF), so the year you transition you file both IRNR (Modelo 210) for the pre-residency months and IRPF (Modelo 100) for the full year. The rate, expense treatment and available reductions differ sharply between the two regimes, and 2026 has brought a structural change to the Modelo 210 filing calendar through Orden HAC/623/2026. Understanding the split is what keeps you compliant and prevents overpaying.
How does Spain tax rental income when you become resident mid-year?
Spain does not pro-rate the tax year into a resident half and a non-resident half. If you meet any of the three Article 9 LIRPF residency tests during a calendar year, you are tax resident for that entire year, according to the Agencia Tributaria. The practical consequence is a dual filing: Modelo 210 returns under the IRNR for the months you were non-resident, then a single annual Modelo 100 IRPF return covering your worldwide income for the full calendar year. The IRNR tax already paid on pre-residency rental income is reconciled within the annual IRPF return and credited against the final liability, preventing double taxation. Our guide to split-year tax residency explains the residency transition in detail.
What rate applies to rental income under the IRNR?
The IRNR taxes rental income at a flat rate that depends on your country of tax residency before you became Spanish resident. EU and EEA residents pay 19 per cent. Non-EU residents, including UK nationals post-Brexit, pay 24 per cent. These rates are published by the Agencia Tributaria under Articles 24, 25 and 26 of the Ley IRNR (Real Decreto Legislativo 5/2004) and have not changed for 2026.
The critical distinction is expense deductibility. Under Article 24.6 of the Ley IRNR, EU and EEA residents may deduct expenses directly related to earning the rental income, following the same rules as Spanish IRPF: community fees, IBI, insurance, repairs, management fees and mortgage interest. Non-EU residents are taxed on the gross rental income with no deductions permitted. A UK landlord earning EUR 9,000 in gross rent over six pre-residency months pays 24 per cent on the full EUR 9,000 (EUR 2,160), while a German landlord with the same rent and EUR 3,000 in expenses pays 19 per cent on the net EUR 6,000 (EUR 1,140). Our IRNR guide covers the full non-resident tax framework.
How has Orden HAC/623/2026 changed the Modelo 210 filing deadline?
Orden HAC/623/2026, published in the BOE on 23 June 2026 (BOE-A-2026-13573), restructures the Modelo 210 filing calendar for rental income. The change is significant for anyone in a split-year scenario because it moves the filing window from quarterly deadlines to a single annual deadline.
Before this reform, non-resident landlords filing Modelo 210 for rental income (rendimientos de inmuebles arrendados, income type codes 01 and 35) faced quarterly deadlines: the first 20 calendar days of April, July, October and January for the preceding quarter’s rent. The Orden HAC/623/2026 shifts this to a single annual filing window of 1 to 20 April of the year following the devengo (the accrual date), applicable to rental income devengado from 2026 onwards, meaning the first filing under the new calendar falls in April 2027.
The Agencia Tributaria’s implementation note clarifies the transition. For landlords who file separately (not grouped), rental income devengado through September 2026 retains the old quarterly deadlines: Q1 and Q2 2026 rent was filed by 20 April and 20 July 2026 respectively, and Q3 2026 rent (July through September) is filed by 20 October 2026. Only Q4 2026 rent (October through December) moves to the new 1 to 20 April 2027 window. For landlords who file grouped (agrupado), the entire year’s 2026 rental income is filed in the single 1 to 20 April 2027 window.
The reform also introduces a new deductible-expense breakdown annex (anexo de desglose de gastos deducibles) for EU and EEA residents who deduct expenses under Article 24.6, and new fields for the number of rental days and the ownership percentage. These content changes apply to all Modelo 210 returns filed from 1 January 2027 onwards, regardless of the devengo date.
How does IRPF tax rental income once you are resident?
Under IRPF, rental income is classified as rendimientos del capital inmobiliario and enters the general tax base, not the savings base. The general base is taxed at progressive combined state and autonomous community rates ranging from 19 per cent to 47 per cent, depending on your total income. Unlike the IRNR’s flat rate, the progressive scale means a resident with modest total income may pay an effective rate close to the 19 per cent floor, while higher earners approach the 47 per cent ceiling.
The decisive advantage for residents is the Article 23.2 LIRPF reduction, rewritten by the Ley 12/2023 (Ley por el derecho a la vivienda, BOE 25 May 2023). The old single 60 per cent reduction was replaced by a four-tier system for contracts signed from 26 May 2023 onwards:
| Reduction | When it applies | Legal basis |
|---|---|---|
| 50 per cent | Habitual-home rental, contract signed on or after 26 May 2023 | Art 23.2.a LIRPF (new general rate) |
| 60 per cent (transitional) | Habitual-home rental, contract signed before 26 May 2023 | Disposicion Transitoria 38 LIRPF |
| 60 per cent (rehabilitation) | Habitual-home rental in a property rehabilitated in the 2 years before the contract | Art 23.2.b LIRPF |
| 70 per cent | Habitual-home rental in a declared stressed zone (zona tensionada), first rental, tenant aged 18 to 35, or rental to a public administration or social entity | Art 23.2.c LIRPF |
| 90 per cent | Habitual-home rental in a stressed zone, new contract with rent at least 5 per cent below the previous contract | Art 23.2.d LIRPF |
The reduction applies after deductible expenses, not to gross rent, making it one of the most significant tax reliefs available to Spanish resident landlords. Our resident rental reduction guide covers the full tier system and the stressed-zone requirements.
How do the two regimes compare on the same rental income?
| Dimension | IRNR (pre-residency) | IRPF (post-residency, full year) |
|---|---|---|
| Tax form | Modelo 210, annual from 2026 (Orden HAC/623/2026) | Modelo 100, annual |
| Rate | 19% (EU/EEA) or 24% (non-EU), flat | 19-47% progressive, general base |
| Expense deduction | EU/EEA: yes (Art 24.6); non-EU: no | Yes, full IRPF deductions |
| Rental reduction | No, IRNR only | Yes, Art 23.2 LIRPF, 50-90% tier system |
| Amortization | EU/EEA: yes; non-EU: no | Yes, 3% of construction cost |
| Taxable base | EU/EEA: net rent; non-EU: gross rent | Net rent after expenses and reduction |
| Filing deadline (2026 rent) | 1-20 April 2027 (new single window) | 8 April to 30 June 2027 |
The table shows why the transition matters. A non-EU landlord moving from 24 per cent on gross rent to IRPF with deductions and a 50 to 90 per cent reduction can see the effective rate on rental income fall by more than half, even before the progressive scale is considered.
How do you file the dual returns in practice?
The filing sequence follows the calendar, not a single event:
- During the non-resident months, file Modelo 210 for rental income received in the preceding period. Under the pre-reform quarterly system (which still applies to Q1 to Q3 2026 rent for separate filers), the deadlines were the first 20 calendar days of April, July, October and January. Under the new Orden HAC/623/2026 calendar, Q4 2026 rent (October to December) is filed in the 1 to 20 April 2027 window, and grouped filers declare the entire year’s rent in that same window.
- When you cross the 183-day threshold, you do not file a form to notify AEAT. Residency is a factual test under Article 9 LIRPF, determined at year-end by counting your days present, your economic centre and your family nucleus.
- After the tax year ends, file Modelo 100 IRPF between 8 April and 30 June of the following year. This return covers your worldwide income for the full calendar year, including all rental income from January to December.
- The IRNR tax already paid via Modelo 210 during the pre-residency months is credited against the IRPF liability. If the IRPF calculation (with deductions and the rental reduction) produces a lower tax than the IRNR already paid, the excess is refunded.
There is no dedicated split-year form in Spain. The dual-return mechanism handles the transition through the standard IRPF and IRNR channels. Our non-resident rental tax guide covers the Modelo 210 filing process in detail.
What expenses can you deduct under each regime?
Under IRPF, resident landlords deduct all expenses directly linked to the rental: mortgage interest on the property, IBI, community fees, insurance, repairs, letting agent fees, and 3 per cent annual amortization of the construction cost excluding land. These deductions are taken before the rental reduction is applied, so they reduce the base on which the reduction operates.
Under the IRNR, EU and EEA residents may deduct the same categories of expenses under Article 24.6, provided they can demonstrate the expenses are directly related to the Spanish rental income. From 2027, the new Modelo 210 expense breakdown annex (introduced by Orden HAC/623/2026) requires a detailed itemisation of these deductible costs. Non-EU residents cannot deduct any expenses and are taxed on the full gross rent, which is the single biggest disadvantage of non-EU non-resident ownership. Our rental tax deductions guide lists every deductible expense category.
Worked example: EUR 18,000 annual rental with a July residency start
Consider a UK landlord (non-EU) who rents out a Spanish apartment for EUR 18,000 per year and becomes Spanish tax resident on 1 July 2026, having accumulated more than 183 days in Spain by December. The tenant uses the flat as their habitual home under a contract signed in 2022, so the transitional 60 per cent reduction applies. Annual deductible expenses (IBI, community fees, insurance, management) total EUR 6,000.
| Period | Regime | Gross rent | Expenses | Net rent | 60% reduction | Taxable | Rate | Tax |
|---|---|---|---|---|---|---|---|---|
| Jan-Jun (non-resident) | IRNR | 9,000 | 0 (not allowed) | 9,000 | n/a | 9,000 | 24% | 2,160 |
| Jul-Dec (resident) | IRPF | 9,000 | 3,000 | 6,000 | 3,600 | 2,400 | 19% (floor) | 456 |
| Full year (IRPF return) | IRPF | 18,000 | 6,000 | 12,000 | 7,200 | 4,800 | 19% (floor) | 912 |
The full-year IRPF return reports EUR 18,000 in gross rent, deducts EUR 6,000 in expenses to reach EUR 12,000 net, applies the 60 per cent reduction of EUR 7,200, and taxes the remaining EUR 4,800 at the lowest progressive band of 19 per cent, producing EUR 912 in tax. The IRNR already paid (EUR 2,160) is credited against this EUR 912, generating a EUR 1,248 refund.
Under the new Orden HAC/623/2026 calendar, the pre-residency Modelo 210 for Q1 2026 rent (January to March) was filed by 20 April 2026, and Q2 2026 rent (April to June) was filed by 20 July 2026, under the old quarterly deadlines that still apply to rent devengado through September 2026 for separate filers. Q3 2026 rent (July to September) is filed by 20 October 2026. The full-year IRPF return is filed between 8 April and 30 June 2027, and the IRNR credit is reconciled within it.
For an EU landlord in the same scenario, the pre-residency IRNR would be EUR 1,140 (19 per cent on net EUR 6,000 with deductible expenses), and the full-year IRPF would still be EUR 912, producing a EUR 228 refund. The EU landlord starts from a lower IRNR base because expenses are deductible, so the refund is smaller, but the transition still produces a net saving through the rental reduction.
These figures assume the rental income sits within the lowest IRPF band. A resident with significant other income may see the rental portion taxed at a higher marginal rate, reducing or eliminating the refund. The specific outcome depends on total worldwide income and any applicable double taxation agreement.
When does Spanish tax residency actually start?
Residency starts on 1 January of the calendar year in which you first meet any of the three Article 9 LIRPF tests, not on the day you arrive or register:
- The 183-day test: you spend more than 183 days in Spain during the calendar year, counting all days present including sporadic absences unless you prove tax residency in another country.
- The economic centre test: the main core or base of your economic or professional activities is in Spain.
- The family test: your spouse and minor dependent children live in Spain, a presumption that can be rebutted with contrary evidence.
If you arrive in July and accumulate 183 days by December, you are resident for the entire calendar year. If you do not reach 183 days in the arrival year but do the following year, residency starts on 1 January of the following year. The test is factual and applied at year-end, not declared on a form. Our 183-day residency guide covers the tests in detail.
How does the fiscal residency certificate fit into a split year?
The fiscal residency certificate (certificado de residencia fiscal) is issued by the Agencia Tributaria and confirms your tax residency status for a given calendar year. In a split-year scenario, this document serves two purposes.
First, it proves to the Spanish tax authority that you are resident under Article 9 LIRPF, which is the basis for filing the full-year IRPF return rather than only the post-arrival period. Second, it can be presented to the tax authority of your former country of residence to claim relief under a double taxation agreement (convenio para evitar la doble imposicion). Without the certificate, a foreign tax authority may continue to treat you as resident there for the full year, potentially leading to dual-residency disputes.
The Agencia Tributaria issues the certificate electronically through its sede, and it covers a specific calendar year. For the transition year, the certificate will confirm Spanish residency for the full year, which is consistent with the Article 9 whole-year rule. Our fiscal residency certificate guide explains the application process and the scenarios where it is required.
Frequently asked questions
- Do I file two tax returns for rental income in the year I become Spanish tax resident?
- Yes. You file Modelo 210 IRNR for rental income received before you became resident, then Modelo 100 IRPF annually for the full calendar year. Spain treats residency as a whole-year status, so the IRPF return covers all rental income from January to December. The IRNR tax already paid is credited against the IRPF liability to prevent double taxation.
- What is the IRNR rate on rental income before I become resident?
- The IRNR rate is 19 per cent for EU and EEA residents and 24 per cent for non-EU residents, including UK nationals post-Brexit. EU and EEA residents may deduct expenses directly related to the rental under Article 24.6 of the Ley IRNR, while non-EU residents are taxed on gross rental income with no deductions permitted.
- How has Orden HAC/623/2026 changed the Modelo 210 filing deadline?
- Orden HAC/623/2026 (BOE 23 June 2026) shifts the Modelo 210 rental income filing from quarterly deadlines (20th of April, July, October, January) to a single annual window of 1 to 20 April of the year following the devengo. This applies to 2026 rental income filed in 2027. The change also introduces a new deductible-expense breakdown annex.
- Can I claim the rental reduction for the months before I became resident?
- The Article 23.2 LIRPF reduction (50 to 90 per cent under the Ley 12/2023 tier system) is a resident-only relief that applies to net rental income when the property is the tenant's habitual home. Because Spain treats you as resident for the full calendar year once you meet the Article 9 tests, the IRPF return covers the full year and the reduction applies to the full year's qualifying net rental income. The IRNR tax paid for the pre-residency months is then credited against the IRPF liability.
- How do I know when my Spanish tax residency starts?
- Residency starts on 1 January of the calendar year in which you first meet any of the three Article 9 LIRPF tests: spending more than 183 days in Spain, having your economic centre of interests there, or having your spouse and minor dependent children resident there. It is a factual test, not a form you file. If you arrive in July but accumulate 183 days by December, you are resident for the entire year.
- What is a fiscal residency certificate and when do I need one?
- A Spanish fiscal residency certificate (certificado de residencia fiscal) is issued by the Agencia Tributaria and proves your tax residency status for a given calendar year. In a split-year scenario, you may need one to claim benefits under a double taxation agreement with your former country of residence, or to demonstrate to foreign tax authorities that your residency shifted to Spain mid-year.
Sources and data
- Tipos de gravamen en el IRNR sin establecimiento permanente — Agencia Tributaria
- Rendimientos de inmuebles arrendados (IRNR, Art 24 Ley IRNR) — Agencia Tributaria
- Nota modificaciones en plazos de presentacion del modelo 210 introducidas por la Orden HAC/623/2026 — Agencia Tributaria
- Modelo y plazo de presentacion (Manual de Tributacion de No Residentes, julio 2026) — Agencia Tributaria
- Orden HAC/623/2026, de 12 de junio (BOE-A-2026-13573) — BOE
- Ley 35/2006, de 28 de noviembre, del Impuesto sobre la Renta de las Personas Fisicas (consolidated text) — BOE
- Real Decreto Legislativo 5/2004, texto refundido de la Ley del IRNR — BOE
- Certificados de residencia fiscal — Agencia Tributaria
- Individual resident in Spain (Article 6 IRNR Law / Article 9 IRPF Law) — Agencia Tributaria