Spain has significantly intensified tax oversight of foreigners earning income in the country in recent years. The result: record revenues from the Non-Resident Income Tax (IRNR), fuelled by capital income, property investment and stricter checks on actual tax residency.
Spa.in Press
Between January and October 2025, the Spanish Tax Agency collected more than €4.2 billion through the IRNR — around 30% more than in the same period last year and nearly 71% more than in 2022, when revenues began to recover after the pandemic-related slump.
What is the Non-Resident Income Tax (IRNR)?
The IRNR (Impuesto sobre la Renta de No Residentes) applies to income generated in Spain by individuals or entities that are not considered tax residents in the country. It affects, among others:
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Foreigners renting out property in Spain
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Investors receiving dividends or interest
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Artists, professional athletes and international specialists
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Foreign companies without a permanent establishment in Spain
IRNR Tax Rates
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24% for taxpayers resident outside the EU or EEA
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19% for taxpayers resident within the EU or EEA
Unlike resident income tax (IRPF), the IRNR allows far fewer deductions, which can significantly increase the effective tax burden.
Why Spain Is Increasing Checks on Foreign Taxpayers
The surge in revenue is mainly linked to:
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The surge in revenue is mainly linked to:
Higher capital income (dividends, interest, rental income) -
Increased foreign investment in Spanish property
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More stringent annual tax inspection plans
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Enhanced international exchange of tax information
Tax authorities are paying particular attention to:
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Correct withholding taxes on payments to non-residents
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Corporate structures used for dividend distributions
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Direct and indirect property ownership
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Unjustified refund claims
Tax Residency in Spain: A Common Misunderstanding
Many foreigners wrongly assume they are not tax residents, even though they may qualify as such under Spanish rules. In practice, anyone spending more than 183 days per year in Spain may be deemed tax resident. In that case, worldwide income — not only income generated in Spain — must generally be declared.
To determine actual residency, the Tax Agency analyses data relating to housing, economic activity and other relevant personal and financial ties.
Digital Nomads, Investors and High-Net-Worth Individuals Under the Spotlight
The rise of remote work has brought new profiles into focus: foreigners living in Spain while continuing to declare themselves as non-residents, despite substantial income, property ownership or complex financial structures.
Also under closer scrutiny are:
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Income earned by artists and professional athletes
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Profits and returns from real estate
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Dividend-related tax refund claims
