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THE WAYPOINT SUR

The deadline that isn't what your checklist says

If you own Spanish property but live somewhere else, today is one of three things: a live filing deadline, the last day to preserve a refund, or a false alarm. Which one depends entirely on how you file, and much of the advice in circulation has not caught up.

Quick orientation, because this could be your first issue with us: non-residents declare Spanish property income on Modelo 210the non-resident income tax return. In our 29 June issue we covered the court ruling that opened expense deductions to non-EU-resident landlords. Haciendathe Spanish tax authority has now answered, and the answer rewrites the calendar.

What changed

Orden HAC/623/2026 landed in the state bulletin on 23 June. It moves rental income to a single annual filing each April, shifts the window for empty second homes, and from January 2027 bolts a mandatory itemised expense annex onto every filing. Confirmed July 2026 against the AEAT calendar.

The sequence is the story. In July 2025 the Audiencia Nacional, Spain's national appeals court, ruled that landlords resident outside the EU can deduct rental expenses on the same footing as EU residents. The tax office's appeal is still pending at the Supreme Court, and refund requests are being parked in the meantime. While that plays out, the same tax office redesigned the form so that from 2027, every deduction arrives itemised, invoice by invoice.

Our read: the ruling opened the deduction, and the Orden built the audit for it. Spain is moving foreign-owned property from taxed on trust to checked line by line.

Which of the three are you

You declared rental income for April to June 2022, at the old 24% on gross. That quarter's refund right expires tonight at 23:59. A solicitud de rectificaciónrequest to correct a filed return submitted electronically today preserves the claim, even though the tax office will park it until the Supreme Court rules. On €2,000 of deductible costs from that quarter, roughly €480 is at stake at the 24% rate. Illustrative numbers, not a quote for your situation. The message to your asesor fiscaltax adviser this morning is one line: file the rectificación for my Q2-2022 Modelo 210 today. The next quarter's right expires 20 October, and so on, one quarter at a time.

You still file each quarter's rent separately. Your April-to-June 2026 filing is due today. Direct debit closed on 15 July, so paying now means an NRCbank payment reference code from your Spanish bank, or a card at the AEAT's online office. If you have no adviser, online specialists such as IberianTax file a single Modelo 210 from €34.95. Worth also asking whether grouped annual filing suits you from here: grouped 2026 income files in April 2027 instead, a nine-month difference in when the money leaves your account.

You group annually, or the flat sits empty. Nothing is due today. Grouped 2026 rental income files 1 to 20 April 2027, and 2026 imputed income for empty or own-use homes cannot be filed before April 2027 either. Your 2025 imputed filing is unchanged and can still go in any time this year. But if whoever files for you runs the 210 every January, that routine quietly died with this Orden. One email settles it: which windows are you using for my 2025 and 2026 filings under Orden HAC/623/2026?

The rates, worked examples, and reclaim mechanics live in our non-resident landlord tax guide, updated this month.

The part that outlasts today

From 1 January 2027, every Modelo 210 carries a mandatory annex itemising rental expenses. What you cannot document with a proper invoice, supplier tax number included, you will not deduct.

So the folder starts now: the IBIannual property tax receipt, community-fee statements, the insurance policy, repair invoices, agency fees. The 2026 paperwork you keep this summer decides your 2027 tax bill.

One quiet consequence worth pricing in: the cash handyman stops being cheap. Once expenses deduct, a €600 invoiced repair beats a €500 cash one for a landlord in the 24% band. The dividing line on the Costa used to run between EU and non-EU owners. From 2027 it runs between invoiced and not.

If today involves a Spanish-language conversation with the tax office, or a Monday-morning hunt for an adviser who answers, that is what Navigator is for: we connect you with vetted English-speaking professionals who handle exactly this.

Spanish-lite

For this morning's messages:

¿Podemos presentar hoy la solicitud de rectificación del segundo trimestre de 2022?Can we file the correction request for Q2 2022 today?

¿Qué plazos aplican a mis declaraciones de 2025 y 2026?Which filing windows apply to my 2025 and 2026 returns?

The bottom line

Nobody sent a letter announcing that the July ritual is ending or that refund rights now expire one quarter at a time. That is rather the point. The calendar rewrite rewards the owner who reads the small print and documents everything, which from 2027 is the kind of owner the form is built for. Ten minutes and two emails today put you on the right side of it.

Not bad for a Monday — A. and the WaypointSur team, receipts stapled and filed.