Order HAC/623/2026 of 12 June amends the filing deadlines and the form used for Modelo 210, Spain’s non-resident income tax return for property owners. This article explains what changes, for whom, and when it applies. All information has been verified against official sources from the BOE and the AEAT.
When can you file for 2026 imputed income?
If you are tax resident outside Spain and own an urban property here that you do not rent out — a holiday home or an apartment kept for personal use — Spanish law requires you to declare an annual imputed property income via Modelo 210. This obligation is not new; what changes is the timetable.
For income accruing during 2026, the ordinary window to file and pay is 1 April to 31 December 2027. Those who wish to pay by direct debit may do so between 1 April and 23 December 2027.
You are filing in 2027 for income that arose in 2026. This is not a new tax. The 2025 tax year is unaffected: imputed income for 2025 continues to be filed between 1 January and 31 December 2026, as confirmed explicitly by the AEAT’s official notice on the reform.
For detailed guidance on how imputed income is calculated and what documents you need, see the guides on Tax4Spain, our firm’s specialist portal for non-resident property tax in Spain.
The legal basis and entry into force
Order HAC/623/2026 was published in the BOE on 23 June 2026 and entered into force on 24 June. It amends Order EHA/3316/2010, which governs Modelo 210. The sole final provision sets specific application dates for each change, which do not necessarily coincide with the general entry into force.
A corrigendum published on 4 July 2026 corrects exclusively a technical field in Modelo 296 (the position of the CÓDIGO field in the type-2 register, corrected from position 13 to 135). It does not affect Modelo 210, its deadlines or its form.
Who is required to file?
Imputed urban property income, governed by Article 24.5 of the IRNR consolidated text, applies to individuals who are not tax resident in Spain and hold urban properties in Spanish territory — or real rights of use over them — that are not used in economic activities and are not rented out for the entire period. If the property is the owner’s permanent home in Spain, or if it is undeveloped land, no imputed income arises. Situations involving usufruct, bare ownership, co-ownership or mid-year changes of tax residence require individual analysis.
The new deadlines at a glance
| Income type | Tax year | Filing and payment | Direct debit |
|---|---|---|---|
| Imputed income | 2025 | 1 Jan – 31 Dec 2026 | 1 Jan – 23 Dec 2026 |
| Imputed income | 2026 | 1 Apr – 31 Dec 2027 | 1 Apr – 23 Dec 2027 |
| Rental – annual grouping | 2025 | 1–20 Jan 2026 | 1–15 Jan 2026 |
| Rental – annual grouping | 2026 | 1–20 Apr 2027 | 1–15 Apr 2027 |
| Rental – separate (Q1–Q3) | 2026 | First 20 days of Apr, Jul, Oct 2026 | 1–15 of each month |
| Rental – separate (Q4) | 2026 | 1–20 Apr 2027 | 1–15 Apr 2027 |
| Property sale | — | 3 months after the month following the transfer date | Not available |
Rental income: a different timetable
The AEAT’s notice includes an explicit warning: the deadline changes do not apply to taxpayers filing separate rental returns for income accruing between April and September 2026. Those returns keep their standard quarterly windows (July and October 2026). Only Q4 2026 income (October–December) moves to April 2027.
Those who opt for annual grouping — an option available since 2024 income, not a novelty of this reform — file all 2026 rental income together between 1 and 20 April 2027. This rule applies only to returns with a balance due. Zero-balance returns, refund claims and property sale returns have separate rules that are not affected by this reform.
Changes to the form
The new Modelo 210 form applies to all returns filed from 1 January 2027, regardless of the tax year being declared.
Number of days field. For imputed income (code 02): days the property was available to the owner. For rental income (codes 01 or 35): days the property was rented out. These are different concepts and must not be confused.
Ownership share field. The declarant’s percentage share in the property title.
New deductible expenses breakdown annex. For rented properties. The annex does not create a right to deduct expenses where none previously existed; that right depends on the IRNR rules and the applicable double-taxation treaty.
Cadastral reference key. New field: 1 (property with cadastral reference) or 2 (property without cadastral reference).
Changes to the property transfer section. The C/O field is renamed C (joint with spouse) or I (individual). This is specific to the transfer section and does not introduce joint filing for imputed income.
Documents to have ready
For the 2026 imputed income return — which can be filed from April 2027 — it is worth gathering in advance: your NIE and tax residence certificate; the cadastral reference and rateable value of the property (shown on the IBI receipt); the title deed showing your ownership percentage and acquisition date; rental contracts and income records if the property was partly let; and copies of previous returns for consistency. A full checklist is available in the Tax4Spain documents guide.
Three worked examples
Example 1. Owner with property available throughout 2026. A Swedish national tax-resident in Sweden owns 100% of an apartment in Benidorm with a revised rateable value of €120,000. Imputed income: 1.1% × €120,000 = €1,320. Tax at 19%: €250.80. Days: 365. Ownership share: 100%. Filing window: 1 April – 31 December 2027. These are illustrative figures; the exact result depends on the actual property data.
Example 2. Couple who acquire a property at 50% on 1 July 2026. Tax-resident in Norway. Each spouse files their own return. Income is proportional to 184 days (July to December). Days: 184. Ownership share: 50%. Filing window: 1 April – 31 December 2027. The AEAT includes a comparable example in its official notice.
Example 3. Property rented in summer, available to the owner the rest of the year. A Danish national rents his property in La Nucía during June, July and August (92 days) and keeps it for personal use the rest of the year (273 days). Two separate returns are needed: imputed income for the 273 days available (code 02, deadline to December 2027) and rental income for the summer months (code 01). If filing on an annual grouped basis: 1–20 April 2027. If filing separately, June–August (Q2–Q3) are due in October 2026. The two income types must always be declared separately.
Frequently asked questions
Do I need to file for 2026 imputed income in January 2027? No. The filing window opens on 1 April 2027.
Can I wait until December 2027? Yes, for ordinary filing and payment. For direct debit, the window closes on 23 December 2027.
We are two co-owners. Can we file a joint return? No. Each owner files their own return, stating their ownership share in the relevant field.
My property was partly rented. Is one Modelo 210 enough? No. Days rented and days available to the owner generate different income types that must be declared separately.
Does this change affect my rental income for July and August 2026? Not if you file separately. Rental income accruing between April and September 2026 retains its standard quarterly deadlines.
Does this change affect my 2025 imputed income? No. The 2025 tax year is filed between 1 January and 31 December 2026.
Need help with your Modelo 210?
Colás Abogados handles Modelo 210 filings for non-resident property owners on the Costa Blanca. Find guides and further information at Tax4Spain, our specialist portal, or contact us directly.