The Spanish Tax Agency has approved several changes to tax forms that affect non-residents, foreign entities, international investors and large estates with tax obligations in Spain.
Although these changes relate to forms and filing templates, they should not be seen as a merely technical update. In practice, they may affect the information that must be reported, filing deadlines and the way certain income, real estate assets or investments in Spain must be justified.
The main updates are concentrated in two areas: Forms 210, 213 and 296 for Non-Resident Income Tax, and Form 718 for the Temporary Solidarity Tax on Large Fortunes.
Changes to Forms 210, 213 and 296 for Non-Resident Income Tax
Order HAC/623/2026 modifies different forms linked to Non-Resident Income Tax, specially Forms 210, 213 and 296.
These changes may affect non-resident taxpayers who obtain income in Spain without a permanent establishment, foreign entities with real estate assets in Spanish territory, international investors and companies required to withhold or report withholdings linked to Non-Resident Income Tax.
One of the most relevant changes affects Form 210, which is used by non-residents to report certain income obtained in Spain. Among other updates, new annexes and information fields are introduced to improve the breakdown of dividends and deductible expenses linked to leased or subleased real estate.
In practice, this means that certain taxpayers will have to provide more detailed information on real estate income, dividends, marketable securities or expenses associated with real estate assets located in Spain.
New deadlines for certain real estate income
The update also modifies the filing deadlines for Form 210 in certain cases related to real estate.
In the case of imputed income from urban real estate located in Spain, the filing and payment period will run from 1 April to 31 December of the calendar year following the accrual.
In turn, income derived from the lease or sublease of real estate with a tax payable result must be reported during the first twenty calendar days of April of the year following the accrual, whether it is reported separately or jointly.
This point is especially relevant for non-residents with rented real estate in Spain, as it may change how annual tax information is organised and how the filing of the tax is planned.
Form 296: more information on securities and withholdings
The order also introduces changes to Form 296, the annual return for withholdings and payments on account of Non-Resident Income Tax.
The changes focus on improving information related to marketable securities, trading markets, identification of issuers and registered holders. This may especially affect withholding entities, financial intermediaries or companies that manage payments to non-residents subject to withholding.
Form 718: adaptation of the Large Fortunes Tax
Together with the Non-Resident Income Tax changes, the Spanish Tax Agency has also updated Form 718 for the Temporary Solidarity Tax on Large Fortunes.
Order HAC/652/2026 changes the form used to report this tax. It will apply for the first time to the 2025 tax year return, which must be filed from 1 July 2026.
The main change relates to how the tax limit is calculated for non-resident individuals who hold assets in Spain, such as real estate or investments.
In practice, this may affect large estates, non-residents with assets in Spain and those who manage this type of structure, as it may modify the final amount payable or the way it is calculated.
What should be reviewed after the changes to Forms 210, 213, 296 and 718?
These updates show a clear trend: the tax authorities are requesting increasingly detailed information to properly verify income, real estate assets, dividends, withholdings and assets linked to non-resident taxpayers.
| Form | Who it affects | What changes in practice |
| Form 210 | Non-residents who obtain income in Spain without a permanent establishment. For example, rental income, imputed income from real estate or dividends. | The Spanish Tax Agency will request more information on real estate assets, rentals, deductible expenses and dividends. |
| Form 213 | Non-resident entities that own real estate in Spain and may be subject to the special tax on real estate assets. | The change is more formal in nature. It should be reviewed if the foreign entity owns real estate in Spain. |
| Form 296 | Companies, withholding entities or intermediaries that annually report withholdings and payments on account made to non-residents. | Information on securities, dividends, holders and trading markets is reinforced. Entities required to report payments or withholdings to non-residents will have to provide more precise data. |
| Form 718 | Large estates subject to the Temporary Solidarity Tax on Large Fortunes, including non-residents with assets or rights in Spain. | The form is adapted to better reflect the application of the tax liability limit for non-resident taxpayers. This may affect the calculation of the tax for large estates with assets located in Spain. |
New forms, more information and greater tax control
The changes to Forms 210, 213, 296 and 718 do not, by themselves, modify the taxation of all transactions. However, they may affect the way certain tax situations are reported, documented and justified.
For non-residents, foreign entities, international investors and large estates with interests in Spain, anticipating these changes can help avoid formal errors, delays or issues when filing tax returns.
In addition, at a time of year that is especially relevant for companies’ accounting and tax review, it is advisable to check whether the available information is complete, up to date and properly organised.
To facilitate this review, at LEIALTA we have prepared a Six-month accounting and tax review checklist, a practical resource designed to help companies identify pending points, necessary documentation and aspects that should be reviewed before moving forward with their tax obligations.
You can download it here: https://www.leialta.com/en/blog/accounting-tax-checklist-spain/
