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Modelo 210: the deadlines changed, and most owners have not noticed.

Order HAC/623/2026 of 12 June rewrote when non-residents file on Spanish property. Rental income moved from quarterly to annual grouping. Imputed income now opens on 1 April instead of 1 January. And the form itself gains new boxes from 2027. Here is exactly which deadline applies to you.

Find your deadline ↗ Based on the Agencia Tributaria's own note of 2 July 2026
Rental grouping
Annual
Changed from quarterly for accruals from 2024 onwards.
Imputed income window
1 Apr
Opening moved from 1 January to 1 April of the following year.
New form content
1 Jan 2027
Applies to every return filed from that date, whatever year it relates to.
The short answer

What is Modelo 210 and who has to file it?

Modelo 210 is the Spanish non-resident income tax return. Anyone who is not tax resident in Spain but owns property here must file it — whether the property is rented out or sits empty, because Spain taxes an imputed income on property held for personal use. It is filed per owner and per property, and it is due even in a year with no rent and no tenant.

Order HAC/623/2026, published in the Official Gazette on 23 June 2026, made three separate changes to this return. They take effect on three different dates, they apply differently depending on whether you group your income or file it separately, and the tax agency published a clarifying note in July precisely because the transitional rules are confusing.

This article works through them in the order that matters to an owner: what changed, which rule applies to your situation, and what the new form asks for that the old one did not.

The three changes.

01
Grouping went annualFor rental income accrued from 2024, the grouping period changed from quarterly to annual. One return a year for the property instead of four.
02
Windows movedImputed income now opens on 1 April rather than 1 January. Rental income with tax to pay is due in the first twenty days of April.
03
The form grewA new annex itemising deductible expenses, new boxes for days and ownership share, and a dividend breakdown annex.

Which deadline applies to you.

The transitional rules are the part that catches people out, because the new dates do not arrive all at once. This table follows the tax agency's own worked position.

Your situationIncome yearFiling window
Empty property, own use (imputed income)20251 Jan – 31 Dec 2026 — unchanged
Empty property, own use (imputed income)20261 Apr – 31 Dec 2027 — new window
Rented, filing grouped for the year20261 – 20 April 2027
Rented, filing separately, Apr–Jun 20262026First 20 days of July 2026 — unchanged
Rented, filing separately, Jul–Sep 20262026First 20 days of October 2026 — unchanged
Rented, filing separately, Oct–Dec 202620261 – 20 April 2027 — new window
The trap in row four and five

If you file separately, nothing changed for most of 2026.

An owner who declares each rental payment separately still had ordinary quarterly deadlines in July and October 2026 for the second and third quarters. Only the fourth quarter of 2026 moves to the new April window. Assuming the change applied from the start of the year is the fastest way to miss two filings.

Direct debit windows are narrower than filing windows and are easy to miss. For imputed income, payment can be domiciled from 1 April to 23 December of the year following accrual. For rental income, whether grouped or separate, from 1 to 15 April.

Two worked examples.

Own use

A German resident buys in Malaga on 1 April 2026

The flat is for personal use. Imputed income is declared for the proportional part of 2026 — nine months — on the new version of Modelo 210, in the window from 1 April to 31 December 2027. Nothing is due in January 2027, which is when the owner would previously have expected to file.

Rented, grouped

A Norwegian resident lets a villa in Alicante from July 2026

The owner elects to declare the whole year grouped. All 2026 rental income goes on one return, filed 1 to 20 April 2027, on the new form — which means completing the deductible expenses annex if expenses are being claimed.

Take the same Norwegian owner filing separately rather than grouped, and the year splits in two. July, August and September 2026 are declared on the old form in the first twenty days of October 2026. October, November and December 2026 are declared on the new form between 1 and 20 April 2027. One property, one year, two form versions and two deadlines — which is a strong practical argument for choosing to group.

What the new form asks for.

The content changes apply to every return filed from 1 January 2027, regardless of which year the income relates to. A late 2024 return submitted in 2027 uses the new form.

New elementWhat it is forPractical consequence
Deductible expenses annexItemised breakdown of expenses claimed against rental incomeClaims must now be broken out, not stated as a single figure
Box: number of daysDays the property was at your disposal, or days it was letPart-year ownership and mixed use become explicit
Box: ownership shareYour percentage of title in the propertyCo-ownership is stated on the form rather than inferred
Dividend breakdown annexDetail for dividend income, unrelated to propertyRelevant to non-residents with Spanish shareholdings

Read together, these boxes point in one direction: the return is becoming more granular and therefore easier to cross-check against the cadastre, the property register and the tax agency's own data. Approximations that survived on the old form are less likely to survive on this one.

The underlying tax, briefly.

None of the above changes what you owe — only when and how you declare it. The substantive rules are unchanged, and they are where the real money sits.

EU and EEA residents

19%, expenses deductible

Rental income taxed at 19%, with mortgage interest, community fees, IBI, insurance, repairs, agent commission and depreciation deductible in proportion to the days let. The new annex is where these are itemised.

Everyone else

24%, on gross

Rental income taxed at 24% with no deduction for expenses. For a US, UK, Canadian or Australian owner the effective burden is far above the five-point rate gap, and the expenses annex is simply not available.

Imputed income, calculated

1.1% or 2% of the cadastral value, taxed at 19% or 24%.

The rate is 1.1% where the cadastral value was revised within the relevant recent period, and 2% otherwise — a difference that doubles the base, so it is worth checking which applies to your property rather than assuming. Apply the 19% or 24% rate to that figure and pro-rate for days owned and ownership share.

What tends to go wrong.

Six recurring errors
  • One return for a jointly owned property. Each co-owner files their own, for their own share. A couple owning together files two returns, not one.
  • Assuming the empty flat needs nothing. Imputed income is the single most commonly missed Spanish obligation among foreign owners, and it accumulates quietly for years.
  • Deducting expenses from outside the EU. Not available. Returns claiming them are corrected, with interest.
  • Using the wrong imputed rate. Applying 1.1% where 2% is due understates the base by half.
  • Surfacing it all at sale. Unfiled years typically emerge when a sale requires a clean position, at the worst possible moment for negotiating leverage.
  • Missing the direct debit window. Filing on 18 April and expecting to domicile the payment does not work; domiciliation closes on the 15th.
Where this becomes a decision

If several years are outstanding, the order of operations matters.

Voluntary regularisation before an enquiry carries materially lower surcharges than correction after one. We assess what is open, what is time-barred and what sequence produces the lowest total cost.

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Terms on the form
IRNR
Impuesto sobre la Renta de No Residentes — non-resident income tax.
Devengo
Accrual. The date the income arises, which determines which deadline rule applies.
Renta imputada
Imputed income. Notional income on property held for your own use. Income code 02.
Rendimientos de inmuebles arrendados
Income from let property. Income codes 01 and 35.
Agrupacion
Grouping. Declaring a period's income on one return rather than each payment separately.
Valor catastral
Cadastral value. The administrative value of the property, and the base for imputed income and IBI.
Cuota de participacion
Ownership share. A new box on the form, stating your percentage of title.
Domiciliacion
Direct debit of the payment, available only in a narrower window than the filing period.
Modelo 211
The related form through which a buyer pays over the 3% retention when purchasing from a non-resident.
Frequently asked
What changed for Modelo 210 in 2026?
Order HAC/623/2026 of 12 June made three changes. Rental income grouping moved from quarterly to annual for accruals from 2024. The filing window for imputed income on urban property moved from starting 1 January to starting 1 April of the following year, first applying to 2026 income. And the form itself gained a deductible expenses annex, boxes for number of days and ownership share, and a dividend breakdown annex, applying to all returns filed from 1 January 2027.
When do I file Modelo 210 for 2026?
It depends on the income. Imputed income on a property for your own use: between 1 April and 31 December 2027. Rental income declared grouped for the year: between 1 and 20 April 2027. Rental income declared separately: the ordinary quarterly deadlines still applied for the second and third quarters of 2026, and only the fourth quarter moves to the 1–20 April 2027 window.
Has the deadline for 2025 imputed income changed?
No. The tax agency has confirmed explicitly that imputed income for 2025 keeps its existing window of 1 January to 31 December 2026. The new April opening applies from the 2026 tax year onwards.
Do I have to file if my Spanish property is empty?
Yes. Spain imputes a notional income of 1.1% or 2% of the cadastral value on property held by a non-resident for personal use, and taxes it at 19% or 24% depending on where you are resident. It is due annually regardless of whether the property produced any actual income. This is the obligation foreign owners miss most often.
Should I group my rental income or declare it separately?
Grouping is now generally simpler: one return a year rather than four, one deadline to track, and for the 2026 transition it avoids the awkward split where part of the year uses the old form and old deadlines and part uses the new. Separate declaration remains available and can suit irregular short-term lets, but it multiplies the filings.
Can I deduct my mortgage interest?
If you are tax resident in the EU or EEA, yes — interest, community fees, IBI, insurance, repairs, agent commission and depreciation are deductible in proportion to the days the property was let, and are now itemised on the new annex. If you are resident elsewhere, no deduction of any kind is available and tax is charged at 24% on gross rent.
What if I have not filed for several years?
Voluntary regularisation before the tax agency contacts you attracts a surcharge that increases with delay but is materially lower than the penalty regime that applies once an enquiry has been opened. Older years may be time-barred. The correct sequence depends on what is open and how the years interact, so it is worth establishing the full picture before filing anything.
Does my property manager file this for me?
Rarely, unless you have specifically engaged them for it. Letting agents typically handle the tenancy, not the owner's tax return, and the obligation sits with the owner personally. Assuming someone else is filing is a common route to a multi-year gap.
Summarised from Order HAC/623/2026 of 12 June, published in the BOE on 23 June 2026, and the Agencia Tributaria's explanatory note last updated 2 July 2026. Deadlines and form content described as at September 2026; individual circumstances, income codes and treaty positions change the analysis. General information, not tax advice — confirm your own position before filing.

The rules moved. Make sure your filing moved with them.

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About the author
AB

Alexander Baranov

Founder, Voixa Consultors · International corporate structuring since 2008

Seventeen years designing and delivering cross-border corporate structures — incorporation, tax, holding, banking and market entry — for founders and companies expanding into Spain and the EU. Author of professional books on entering the Spanish market.

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