Taxes in Spain for Americans: the 2026 guide

Moving to Spain from the US means dealing with two tax systems at once. Spain taxes you on your worldwide income once you're a resident. The IRS keeps taxing you because you're a US citizen, wherever you live. Neither side switches off because the other one exists.

The good news: there's a tax treaty between the two countries, and the US gives credit for tax you pay abroad. Most Americans in Spain don't pay twice on the same income. But you do file twice, and Spain has a few rules Americans don't see coming, like the wealth tax and the overseas assets declaration.

This guide is general information, not tax advice. Rules change every year, so confirm your own situation with a qualified adviser before you act on anything here.

When you become a Spanish tax resident

Spain's income tax law says you're a tax resident if either of two things is true in a calendar year (article 9 of the IRPF law):

• You spend more than 183 days in Spain during the calendar year. Sporadic absences still count as days in Spain, unless you can prove you're a tax resident somewhere else.
• The main centre or base of your business activities or economic interests is in Spain, directly or indirectly.

There's also a presumption: if your spouse (not legally separated) and your dependent minor children live in Spain, you're presumed to be resident too, unless you can prove otherwise.

The Spanish tax year is the calendar year. So if you land in March and stay, you'll almost certainly be a resident for that whole year. If you arrive in October, you probably won't be until the next one, unless your economic interests have already moved.

Once you're resident, you file a Spanish income tax return (the declaración de la renta) the following spring. For the 2025 tax year, the online filing window ran from 8 April to 30 June 2026. You'll need a NIE to do any of this.

You still file with the IRS

The US taxes by citizenship, not residence. As a US citizen living abroad, you're taxed on your worldwide income and still file a US return. The regular due date is 15 April. Citizens living abroad get an automatic two-month extension to 15 June, but interest runs on any tax not paid by 15 April.

Two tools stop most people from paying twice:

• Foreign Earned Income Exclusion (FEIE). If you work in Spain and pass the bona fide residence test or the physical presence test (330 full days abroad in 12 consecutive months), you can exclude earned income up to $130,000 for 2025 and $132,900 for 2026. It only covers earned income. Pensions, Social Security, dividends, interest and capital gains are not earned income, so the FEIE does little for retirees.
• Foreign Tax Credit (FTC). You can credit income tax paid to Spain against your US tax on the same income, using Form 1116. You can't claim the credit on income you've already excluded with the FEIE. When the Spanish tax on a piece of income is higher than the US tax on it, the credit can cancel the US bill on that income. Whether that happens for you depends on your numbers, so run them.

Then there's the reporting, which catches people out more than the tax does:

• FBAR. If your non-US accounts together exceed $10,000 at any point in the year, you file an FBAR with FinCEN through the BSA E-Filing System, separately from your tax return. It's due 15 April with an automatic extension to 15 October. Your Spanish bank account counts.
• FATCA (Form 8938). If you live abroad, you file Form 8938 with your return when your specified foreign financial assets are more than $200,000 at year end or $300,000 at any time (single), or $400,000 and $600,000 (married filing jointly).

What the US-Spain tax treaty does

The US and Spain signed their income tax treaty on 22 February 1990, and it was later amended by a 2013 protocol. Here's what it does for an American living in Spain, in plain terms.

It doesn't stop the US taxing you. The treaty's "saving clause" (Article 1, paragraph 3) lets the US tax its citizens as if the treaty didn't exist, with a list of exceptions that includes the double tax relief article. This is why Americans still file every year.

It breaks ties on residence. If both countries treat you as resident, Article 4 settles it in order: where you have a permanent home, then where your personal and economic ties are closer (your centre of vital interests), then where you habitually live, then your nationality. If none of that decides it, the two tax authorities agree between themselves.

It decides who credits what. Under Article 24, Spain gives you a credit for US tax on income the treaty lets the US tax, but not for US tax charged only because you're a citizen. The US then credits the Spanish tax, and the treaty treats some income as arising in Spain so the US credit can work. The order of operations matters, and it's where most DIY returns go wrong.

On retirement income, the treaty text says:

• Private pensions for past employment are taxable only in your country of residence (Article 20(1)(a)). The saving clause still lets the US tax you as a citizen, so the relief comes through Article 24.
• US Social Security paid to a Spanish resident or a US citizen may be taxed by the US (Article 20(1)(b)). How the two countries share it in practice depends on the relief rules and your situation, so confirm it with an adviser.
• US government pensions (for work for a federal, state or local government) are generally taxable only in the US, unless you're both a resident and a national of Spain (Article 21(2)).
• Growth inside a US retirement plan. The 2013 protocol added a rule that income earned inside a pension fund in the other country is taxed to you only when it's paid out to you. The protocol's definition of a US pension fund includes 401(k) plans, 403(b) plans, traditional and Roth IRAs and the Thrift Savings Fund. So Spain shouldn't tax the yearly growth in your 401(k) or IRA. How it taxes the withdrawals is a separate question.

Spanish income tax (IRPF): how the rates work

Spain's income tax is the IRPF (Impuesto sobre la Renta de las Personas Físicas). Two things make it different from the US system.

First, it's split in two. Part of the tax follows a state scale, and part follows a scale set by your autonomous community (your region). The state scale is the same everywhere. Each region approves its own, so the same salary is taxed differently in Madrid, Catalonia or Andalusia. Your combined rate depends on which region you live in.

Second, income goes into two buckets. The general base covers salary, self-employment income, pensions and rental income. The savings base covers interest, dividends and most capital gains. Each bucket has its own rates.

Here's the state half of the general scale, as the Agencia Tributaria publishes it for 2025 returns (it's also in article 63 of the IRPF law). Add your region's own scale to get your real rate.

The savings base works differently. Both the state scale and the regional scale for savings income are set in the national law and are identical, so every region ends up with the same combined rates. Each half is 9.5%, 10.5%, 11.5%, 13.5% and 15% across the bands below, which adds up to:

Everyone gets a personal allowance before the scales bite. At state level it's €5,550 a year, plus €1,150 if you're over 65 and another €1,400 if you're over 75. Regions can adjust their own version of it.

These are the rates in the law today, used for 2025 returns filed in 2026. Spain changes them more often than the US does, so check the current year's figures before you budget.

Wealth tax and the solidarity tax on large fortunes

Spain taxes net wealth, not just income. Once you're resident, the wealth tax (Impuesto sobre el Patrimonio) applies to your worldwide net assets, wherever they are. That includes your US brokerage account and your house back home.

This is a regional tax, and the regional differences are big. The national law sets defaults that apply only where a region hasn't set its own rules:

• An exempt amount of €700,000 if your region hasn't approved a different one.
• Your main home is exempt up to €300,000.
• A default scale from 0.2% to 3.5%, which regions can replace with their own.
• You must file a return if you owe tax, or if your gross assets are over €2,000,000 even when you owe nothing.

Some regions have cut the wealth tax heavily through their own allowances and reliefs. Others apply it in full. Where you settle can change your bill by a lot, so check your region's rules before you choose where to live.

The solidarity tax on large fortunes (Impuesto Temporal de Solidaridad de las Grandes Fortunas) sits on top. It's a national tax that regions can't take over, which is the point: it reaches wealthy residents in regions that cut the wealth tax. It applies to net wealth above €3,000,000. After a €700,000 allowance, the first €3,000,000 of the taxable base is taxed at 0%, then the rates are 1.7%, 2.1% and 3.5%. Any wealth tax you actually paid is deducted. It was introduced as a temporary tax and has been extended until Spain reviews how wealth is taxed.

Modelo 720: the overseas assets declaration

Modelo 720 is an information return, not a tax. Spanish residents use it to tell the Agencia Tributaria what they hold abroad. It covers three separate categories: accounts at foreign banks, securities, insurance and similar investments held abroad, and real estate abroad.

For an American, almost everything you own in the US counts as abroad. You have to file when the value in a category goes over €50,000. After your first filing you only file again when a category's total rises by more than €20,000 compared with the last one you declared. The filing window is 1 January to 31 March for the previous year's assets.

You might read scary stories about Modelo 720 fines. Those were real, but the rules changed. In a ruling of 27 January 2022 (case C-788/19), the Court of Justice of the EU found parts of Spain's regime broke EU law. Spain then passed Ley 5/2022, which moved Modelo 720 penalties onto the general penalty rules of the tax code. Late or wrong filings still get penalised, so file on time.

What Non-Lucrative Visa retirees typically face

Many Americans come to Spain on the Non-Lucrative Visa and live on pensions, Social Security and savings. Once you've stayed long enough to be resident, Spain taxes that worldwide income. Here's how the main pieces usually break down.

• Private and employer pensions. In Spain they go into the general base at your region's combined rates. The treaty gives the taxing right to your country of residence, and the US still taxes you as a citizen, with credits sorting out the overlap.
• US Social Security. The treaty lets the US tax it. How much, if any, Spain also taxes and who credits whom depends on the treaty and your situation, so confirm with an adviser before you file.
• Government pensions. Generally taxed only by the US under the treaty, unless you're also a Spanish national.
• 401(k) and IRA withdrawals. Growth inside the account shouldn't be taxed by Spain each year. The withdrawals are another matter. How Spain classifies a withdrawal, and what happens with Roth distributions that are tax free in the US, depends on the treaty and your situation. Confirm it with an adviser before you take money out, not after.
• Investment income. Dividends, interest and gains on your US brokerage account fall in the savings base at 19% to 30%. You'll also need to watch the FBAR, Form 8938 and Modelo 720 thresholds on those accounts.
• Wealth tax. Retirees with a large portfolio are the people the wealth tax and the solidarity tax actually reach. Your region makes a big difference here.

The trap we see most: people plan their visa finances for the consulate, then discover in their first Spanish tax season that the treaty doesn't cover their situation the way they assumed. Get a cross-border review before your first full year as a resident.

The Beckham Law, briefly

If you're moving to Spain to work, the special tax regime for people relocating to Spain (the "Beckham Law") may let you pay tax under different rules for a limited number of years. It has strict conditions and it's built around work, so it rarely fits retirees. We cover who qualifies and the trade-offs in our Spain Beckham Law guide.

When to hire a gestor or asesor fiscal

A gestor handles admin and routine filings. An asesor fiscal is a tax adviser who plans and advises. For most Americans the answer is simple: get one before your first full tax year in Spain.

You especially want one if any of these apply:

• You're drawing US pensions, Social Security or retirement account withdrawals.
• You hold US investments big enough to trigger Modelo 720 or the wealth tax.
• You're self-employed or earning from US clients while living in Spain.
• You're thinking about the Beckham Law or selling a US home.

Look for someone who works with both sides, or a Spanish adviser who coordinates with a US preparer who knows expat returns. A Spanish gestor who has never seen a Form 1116 can get your Spanish return right and still leave you paying twice.