THE WAYPOINT SUR

Which pile are you in?
Tuesday update: The Mijas municipal strike we covered yesterday was resolved the same day via SERCLA mediation. After two years of stalled negotiations, workers secured the terms in a single afternoon: a 26% overtime increase, a 20% productivity bonus, a refund of insurance costs, and a hard deadline to complete job stabilization by December 31, 2026. The infrastructure held. It just took a visible break to force the repair. The 96-urbanization commitment and the question of who maintains it still stand.
The direction of travel
Last week, Spain's Ministry of Finance published a draft order changing how non-residents are taxed on Spanish wealth. The short version: a protection that only residents could use, a 60% ceiling on combined income and wealth tax, will now apply to non-residents too. The threshold is €3 million in Spanish assets (Public consultation phase, March 2026).
That is not the story. The story is that this is the seventh time in the past 18 months that Spain has done something like this.
It is the seventh change in eighteen months, and every one of them pushes in the same direction: the fiscal gap between "living in Spain" and "owning property in Spain" is closing. Quietly, by ruling after ruling, decree after decree, the special treatment that non-residents relied on is being dismantled. And the penalties that made full commitment expensive are being removed at the same time.
If your tax advisor last reviewed your Spanish structure more than a year ago, the assumptions underlying it may no longer hold.
The seven changes
Here is the sequence. None of these was framed as part of a trend. Each was reported as an isolated event. Together, they tell a clear story.
1. Golden Visa abolished (April 2025). The €500,000 property investment route to residency is gone. Organic Law 1/2025 killed the programme that brought thousands of non-EU investors to the Costa del Sol. Spain decided the housing market pressure was not worth the capital.
2. Beckham Law tightened (2024-2025). The flat 24% tax rate for relocated workers still applies, but the prior non-residency requirement was reduced from 10 years to 5. Digital nomad visa holders are now eligible. And Hacienda is actively auditing structures it considers abusive. The regime is more accessible but more scrutinised. Here is our full guide on who qualifies for the Beckham law.
3. Non-resident rental deductions equalised (July 2025). A Supreme Court ruling forced Spain to allow EU/EEA non-residents to deduct expenses from rental income, the same treatment residents had always had. Before this, a non-resident renting out a Marbella apartment paid tax on gross income, while a resident paid tax on net income. Same property, different maths. Fixed.
4. Savings tax rate increased (January 2025). Income from savings above €300,000 now taxed at 30%, up from 28%. If you sold a Spanish property last year and netted more than €300,000, you felt this in your Renta filing. The ceiling rose for everyone.
5. Payment reporting threshold eliminated (January 2026). The €3,000 floor for reporting card, POS, Bizum, and mobile payments disappeared. Every transaction is now visible to Hacienda. The informal economy, which disproportionately benefited people operating between systems, got smaller.
6. VUT enforcement wave (2025-2026). 86,275 illegal short-term rental listings blocked nationally. Modelo 170 monthly reporting is now mandatory for all hosts. Andalucía alone cancelled 13,037 registrations in a single sweep (Confirmed February 2026). Non-resident landlords running undeclared holiday lets are the primary target.
7. Wealth tax quota cap extended to non-residents (March 2026). The Supreme Court ruled the exclusion of non-residents from the 60% combined tax ceiling violated EU free movement of capital. TEAC extended the doctrine. Hacienda drafted the implementing order. Non-residents with €3 million or more in Spanish assets will finally get the same protection as residents. Understanding your tax residency status matters more than ever.
What the trend means
Read the list again. Half of these changes make non-resident life harder (the Golden Visa gone, tighter payment reporting, VUT crackdowns, savings tax up). Half make it fairer (rental deductions, wealth tax cap, Beckham access widened).
Spain is not punishing non-residents. It is eliminating the category as a meaningful fiscal distinction. The advantages of staying non-resident are shrinking. The penalties for becoming a resident are shrinking, too. The two tracks are converging toward one.
For anyone who structured their Spanish property ownership, rental income, or business around the assumption that non-resident status carried specific fiscal advantages, the assumption needs revisiting. Not because any single change is catastrophic. Because the direction is clear and it is not reversing.
Who feels this most
If you own Spanish property as a non-resident and rent it out, the deduction equalisation is a direct win. For a Marbella apartment generating €18,000 in rental income with €6,000 in deductible expenses, the difference between gross and net tax is roughly €1,140 a year. Your asesor fiscal — tax advisor — may not have flagged the July 2025 ruling yet. Ask.
If you are on the Beckham Law, the tighter scrutiny means your structure needs to be clean. The 24% rate is still available. The tolerance for creative interpretation is not. Check the current requirements here.
If you run a short-term rental without full compliance, the Modelo 170 reporting and VUT enforcement wave means the window for operating informally is closing. This is not a future risk. It is a current one.
If you are weighing whether to become a tax resident, the calculation has changed. The fiscal cost of full commitment is lower than it was 18 months ago. The fiscal benefit of keeping distance is lower, too.
Your Spanish for the week
"¿Estoy obligado a declarar esto?" — Am I required to declare this?
The answer, increasingly, is yes.
The bottom line
Seven changes in eighteen months. Golden Visa gone. Beckham tightened. Rental deductions equalised. Payment reporting expanded. VUT enforcement accelerated. Savings tax raised. Wealth tax cap extended. Each was reported as its own story. The trend line is the story: Spain is making "half in" harder and "fully in" cheaper. The gap between living here and owning here is narrowing to the point where the distinction barely matters fiscally. Talk to your tax advisor about which side of that convergence you want to be on.
Onwards — A. and the WaypointSur team, converging on our fifth coffee


