Two tax systems, one move
If there's one thing I wish someone had told me before I moved to Valencia, it's this: where you live in Spain is not just a lifestyle decision. It's a financial one.
Spain is made up of 17 autonomous communities, and they don't all play by the same rules. Inheritance tax, wealth tax, some income tax deductions — these vary significantly depending on whether you're in Madrid, Catalonia, Andalusia, or the Basque Country. Two expats living in Spain can face dramatically different tax bills based solely on which region they call home.
Then there's the second layer: as an American, you don't leave the US tax system when you board the plane. The US taxes its citizens on worldwide income regardless of where they live. Moving to Spain means navigating two tax systems simultaneously — and understanding how they interact.
This page gives you the full picture. It covers Spanish taxes, US obligations, the legal structures that matter to expats, regional differences, and how to find the professionals who can help.
Tax residency vs. immigration residency
The most important concept to grasp before anything else: tax residency and immigration residency are not the same thing.
Your immigration status — the visa you hold, the TIE card in your wallet — is controlled by Spain's Ministry of the Interior. Your tax residency — which country has the right to tax your worldwide income — is determined by a separate set of rules.
Once you cross the 183-day threshold in any calendar year, Spain can tax your worldwide income— your US freelance income, your investment dividends, your retirement distributions, all of it. This is the rule that surprises Americans most. They assume that because their money comes from the US, Spain can't touch it. That assumption is wrong.
The US-Spain Tax Treaty exists to prevent double taxation, but it doesn't eliminate your obligations in either country — it determines which country gets primary taxing rights over which types of income, and provides mechanisms for crediting taxes paid in one country against obligations in the other.
Spanish income tax: IRPF
For Spanish tax residents, the primary income tax is IRPF (Impuesto sobre la Renta de las Personas Físicas). It is filed annually in spring — the declaration window typically runs April through June — via the Agencia Tributaria, Spain's tax authority.
IRPF is progressive and split between a national component and a regional component. The combined rates for general income (employment, self-employment, rental income) in 2025–2026 are roughly:
Exact rates vary slightly by autonomous community, as regions set their own portion of the scale.
Savings income (dividends, interest, capital gains) is taxed on a separate, lower scale — ranging from 19% to 28% depending on the amount.
US Citizens in Spain: A Tax Guide →The Beckham Law
Spain's Beckham Law (Régimen Especial para Trabajadores Desplazados, RETD) is a special tax regime available to people who move to Spain for the first time and meet certain conditions.
Under it, instead of paying progressive IRPF on worldwide income at rates up to 47%, you pay a flat 24% rate on Spanish-source income up to €600,000. Crucially, most foreign-source income — your US clients, foreign investments — is generally not taxed in Spain at all under this regime. It lasts for the year of arrival plus five subsequent tax years — up to six years total.
Don't miss the window: the application must be filed with the Agencia Tributaria within six months of registering with Spanish Social Security. Miss it and you cannot opt in retroactively. For a US remote worker earning €80,000 from US clients, the difference between standard IRPF and Beckham Law can be €15,000–20,000 per year or more.
Spain's Digital Nomad Visa: Everything You Need to Know →Tax for non-residents: IRNR
If you spend fewer than 183 days in Spain in a year and Spain is not your center of economic interests, you are a non-resident for Spanish tax purposes. Non-residents pay IRNR (Impuesto sobre la Renta de No Residentes) — a flat tax on Spanish-source income only.
The standard IRNR rate for US residents (covered by the US-Spain Tax Treaty) is generally 15% on dividends and interest and 24% on other income, though treaty provisions can reduce or eliminate withholding in specific cases.
Non-residents who own property in Spain owe IRNR on rental income (if they rent it out) or an imputed income tax on the property's value (if they keep it for personal use). This is a commonly overlooked obligation for Americans who own a Spanish holiday home.
US tax obligations: you don't leave the IRS behind
The US taxes its citizens and permanent residents on worldwide income, regardless of where they live. Moving to Spain does not change this. Every year, you file a US federal tax return — and potentially several additional forms.
The annual return
Filed on Form 1040 by April 15, with an automatic extension to June 15 for Americans abroad and a further extension to October 15 on request. Any tax owed is still due by April 15 — the extension is for filing, not payment.
Foreign Tax Credit
If you pay Spanish income tax, you can credit it against your US bill for the same income. This generally prevents double taxation, but the credit applies income-category by income-category, and unused credits carry forward.
Foreign Earned Income Exclusion
Excludes a portion of foreign-earned income from US tax — up to roughly $126,500 in 2024 (indexed yearly). It applies only to earned income, not investment, rental, or retirement income. FEIE and the Foreign Tax Credit can't both apply to the same income — a US expat CPA can model which is better.
FinCEN Form 114
If your foreign financial accounts exceed $10,000 combined at any point in the year, you must file an FBAR with the US Treasury. A Spanish checking, savings, or brokerage account all count. Penalties for willful non-filing are severe — up to $100,000 or 50% of the balance per violation.
FATCA
Filed with Form 1040 if your foreign financial assets exceed $200,000 on the last day of the year (or $300,000 at any point) when living abroad and filing single — thresholds double for joint filers. Covers a broader category than FBAR, including foreign pensions and interests in foreign entities.
Modelo 720: declaring overseas assets to Spain
Spanish tax residents must declare their overseas assets annually using Modelo 720 if the aggregate value of assets in any of three categories exceeds €50,000:
For most Americans moving to Spain, this means declaring US brokerage accounts, IRAs, 401(k)s, bank accounts, and any US real estate. The declaration is informational — it does not create additional tax liability — but failure to file can trigger significant penalties. The deadline is March 31 of the year following the tax year.
Regional tax differences: where you live is a financial decision
Spain's autonomous communities have significant power to set their own tax rules — and they use it, particularly in three areas.
Inheritance tax
The variation is extreme:
Decide where to live before you sign a lease, not after. If you have US retirement accounts, real estate, or other significant assets, where in Spain you live can be worth tens or hundreds of thousands of euros to your heirs.
Wealth tax
A national wealth tax applies to net assets above approximately €700,000 (after deductions), with rates rising to 3.5% on the highest tranches. Regions modify this significantly: Madrid applies a 100% bonus that effectively eliminates it — a major reason high-net-worth individuals choose the capital — while other regions apply varying exemptions.
IRPF deductions and regional rates
Regions set their own portion of the IRPF rate scale — roughly half the total rate — and can offer additional deductions for housing, education, and family situations that vary by community.
Autónomo and self-employment taxes
If you work for yourself in Spain — whether serving Spanish or foreign clients — you will likely register as an autónomo (self-employed). This triggers:
VAT at 21%
Charged on most services, filed quarterly via Modelo 303 and annually via Modelo 390. Clients outside Spain — including all US clients — are typically exempt under reverse-charge rules.
IRPF withholding
Spanish clients withhold 15% IRPF at source (7% in your first two years). Without Spanish clients, you make quarterly advance payments via Modelo 130.
Social Security for autónomos
Monthly contributions now calculated on net income rather than a flat fee — roughly €200 to €590/month depending on your declared net income.
Property taxes
Legal structures: wills, contracts, and power of attorney
Wills and inheritance
If you own assets in Spain or are a Spanish resident, you need a Spanish will (testamento). Your US will does not automatically govern your Spanish assets. Under EU Succession Regulation 650/2012, US citizens can elect for US state succession law to govern their worldwide estate — but this must be explicitly stated in a Spanish will, and Spanish inheritance tax still applies to Spanish-situated assets regardless. A Spanish notarial will typically costs €100–200 to execute.
Power of attorney
A Poder Notarial is frequently needed in Spain — for signing property deeds, for a gestor to act on your behalf, or for managing affairs while traveling. It must be executed before a Spanish notary, or a foreign document must be apostilled and translated.
Contracts and consumer rights
Finding the right professionals
Navigating two tax systems requires at minimum two professionals — and often three.
Spanish gestor or asesor fiscal
A gestor handles routine compliance cheaply; an asesor fiscal provides broader planning — Beckham elections, Modelo 720 strategy, inheritance. For complex US situations, the asesor's expertise is worth it.
US expat CPA
A US-licensed accountant specializing in expat returns — FBAR, Form 8938, Foreign Tax Credit, FEIE, and the US-Spain treaty. Not a job for a general US tax preparer.
Cross-border Spanish lawyer
For wills, property purchases, estate planning, or situations where immigration and tax law intersect.
Ask before you engage
Ask every professional specifically about their experience with US expats. The interaction of two tax systems is where general practitioners get it wrong.
Detailed guides
Frequently asked questions
Do I have to pay taxes in Spain if I'm living here on a Non-Lucrative Visa?
Can I avoid becoming a Spanish tax resident by leaving for a few weeks each year?
What is the US-Spain Tax Treaty and what does it actually do?
What is the Modelo 720 and do I need to file it?
Does my 401(k) or IRA need to be declared on the Modelo 720?
If I live in Madrid, do I really pay zero inheritance tax?
How does Spain tax my US freelance income?
What taxes do I owe if I own Spanish property but don't live in Spain?
Do I need a Spanish will?
What's the difference between a gestor and an asesor fiscal?
When does the Spanish tax year run and when are filings due?
This page is for informational purposes only. Tax laws in both Spain and the United States change frequently, and individual circumstances vary significantly. Nothing here constitutes legal or tax advice. Always consult a qualified Spanish tax advisor and a US expat CPA for guidance specific to your situation.