Non-resident owners: holiday rental tax in Spain (IRNR and Modelo 210)

If you live outside Spain and let your Marbella or Costa del Sol home to holidaymakers, you pay holiday rental tax in Spain as a non-resident owner. It's called IRNR (Impuesto sobre la Renta de No Residentes) and it's filed on Modelo 210. And even when the property isn't let, Spain taxes a notional "imputed income" for the days it sits empty or you use it yourself.

Many Costa del Sol owners live in the UK, Scandinavia or elsewhere in Europe, and every winter brings the same questions. Here are clear answers. This is general information, so always check your own situation with a tax adviser.

Who counts as a non-resident?

Broadly, you're Spanish tax resident if you spend more than 183 days a year here or if your main economic interests are here. If not, and you're tax resident in another country, Spain taxes you as a non-resident, but only on your Spanish income: in this case, your property.

Having an NIE or spending the summer in Marbella doesn't make you resident. What matters is where you're tax resident.

How much: 19% or 24%

Non-resident rental income is taxed at a flat rate that depends on where you live:

Where you're resident	Rate	Charged on
EU, Iceland, Norway or Liechtenstein	19%	Income minus deductible expenses
Everywhere else (including the UK since Brexit)	24%	Gross income, with no expenses deducted (see below)

That's the big change for British owners: since the UK left the EU, the law applies 24% to everything you receive.

What's new for non-EU owners

On 28 July 2025 Spain's Audiencia Nacional ruled that stopping non-EU residents from deducting expenses breaches the free movement of capital. In July 2026 the Supreme Court agreed to hear the appeal, so there's no final answer yet. If you live in the UK, the US or another non-EU country, ask your adviser whether to keep filing as before while also asking Spain to amend earlier returns, so you don't lose the right to a refund if the Supreme Court upholds the ruling.

Expenses an EU-resident owner can deduct

If you're resident in the EU or EEA, you can deduct the costs of letting, in proportion to the days the property was actually let. The usual ones:

• Mortgage interest on the property.
• IBI (council tax) and the rubbish collection charge.
• Community of owners fees.
• Home insurance.
• Repairs and upkeep (not improvements).
• Utilities you pay: electricity, water, internet.
• Your management company's fee, cleaning and laundry.
• Depreciation of the building and the furniture.

Keep every invoice: the Tax Agency can ask for them for four years. And from 2027 the new Modelo 210 asks you to break expenses down by type (interest, repairs, community fees, utilities, insurance, IBI, depreciation…) rather than entering one total.

Imputed income: the days you don't let

A property that isn't your main home generates imputed income for the days it isn't let, whether you're using it or it's empty. It works like this:

• 1.1% of the cadastral value if the town hall has revised it in the last ten years.
• 2% if it hasn't.
• Pro-rated by the days not let and by your share of ownership.
• Taxed at the same 19% or 24%.

A quick example: a home with a revised cadastral value of €200,000 that wasn't let for 180 days generates imputed income of about €1,085 (200,000 × 1.1% × 180/365). At 24%, that's roughly €260 of tax. These numbers are only there to show how the sum works.

Modelo 210 deadlines for this winter

The dates have changed in recent years. According to the Spanish Tax Agency:

What you file	Deadline
2025 imputed income (days not let in 2025)	By 31 December 2026
2026 rental income, filed as one annual return	1–20 April 2027
Rental income filed separately, up to September 2026	First 20 days after each quarter (Q3: by 20 October 2026)
2026 imputed income	1 April to 31 December 2027

If you pay by direct debit, the window closes a few days earlier. In practice: if your home wasn't let for the whole of 2025, check before December whether that year's imputed income is still to be filed.

New this winter: VAT. Royal Decree-law 29/2026 provides that, from 1 December 2026, holiday lets for stays of up to 30 nights will carry 10% VAT (still awaiting ratification). Living abroad doesn't exempt you: the property is in Spain, so you would need to register for Spanish VAT as well as carrying on with Modelo 210. See 10% VAT on holiday lets in Spain.

What about tax at home?

Tax paid in Spain usually isn't lost: double taxation treaties generally let you offset it against the tax in your home country, where you'll normally have to declare the income too. Each country has its own rules (in the UK, for example, it goes on your Self Assessment), so make sure your adviser at home and your adviser in Spain talk to each other.

Common mistakes

• Forgetting the empty days. Lots of owners declare the rent and miss the imputed income.
• Deducting costs without proof. No invoice, no deduction.
• Deducting the whole year's costs instead of the share for the days let.
• Confusing visits with residence. Three months a year in Marbella doesn't make you tax resident.
• Not keeping booking records. The Tax Agency receives data from the booking platforms and cross-checks it.

How ERA helps

We're not your tax adviser, but we make their job much easier. In your owner portal you see every booking, your monthly payout, every expense with its receipt and your invoices, all organised and downloadable. At year end, your adviser has everything needed for Modelo 210 in one place.

Wondering what professional management costs? We break it down in what's included in a Marbella management fee, and here's how we handle holiday rental management in Marbella.

If you're tax resident in Spain, IRPF rules apply instead: see our guide to holiday rental tax deductible expenses.

Own a home on the Costa del Sol and live abroad?

We'll put together a free study of your property: what it could earn, what it would cost to run, and how we'd manage it so all you need to do is check the portal. Request your free study here.