The practical decision: which date belongs in your calendar?
If you are a non-resident owner, do not replace every reminder with one date. Order HAC/623/2026, published on 23 June, changes Modelo 210 and certain deadlines. Commencement and the application of each change are different matters: transitional provisions leave some 2026 obligations under the previous timetable.
Before acting, identify four facts: income year, private use or letting, rental reporting method and the assessment result. Payment method also matters because direct debit closes before the filing window. This article concerns non-resident property income without a permanent establishment within the regime addressed by AEAT.
Sources and scope: Order HAC/623/2026 — official legislation · AEAT — 2026 transitional filing dates
Private use: 2025 retains its filing window during 2026
Imputed income for 2025 is reported from 1 January to 31 December 2026. Do not wait until April 2027 to report that year. The later opening date affects 2026 imputed income, to be reported from 1 April to 31 December 2027.
Check days and ownership share alongside relevant cadastral figures and rules. Buying midway through the year or owning only a share changes the data required. If the home was let for part of the period, reconcile that with rental reporting rather than treating the whole year as private use.
Sources and scope: AEAT — 2026 transitional filing dates · Order HAC/623/2026 — official legislation
Annually grouped rent: April 2027 for 2026 income
For rental income accrued in 2026 and reported as an annual group with tax payable, the window becomes 1–20 April 2027. Direct debit runs from 1–15 April. Annual grouping has conditions: it does not mean freely combining taxpayers, properties or income that fails those conditions.
The new filing window is distinct from the grouping option, which became annual for rental income accrued from 2024. Records should allow income, days, participation and expenses to be reconstructed. Establish the appropriate reporting method with the person preparing the return.
Sources and scope: AEAT — 2026 transitional filing dates · Order HAC/623/2026 — official legislation
Separate rental reporting: the October 2026 deadline remains
Separately reported income accrued in the first three quarters of 2026 retains the previous regime. In particular, tax-payable returns for July, August and September fall within the first twenty calendar days of October 2026. Moving all of them to April would apply the reform prematurely.
For separately reported income from the final quarter of 2026, the new window is 1–20 April 2027. AEAT expressly explains this distinction in its transition note. If your adviser was handling quarterly filings, reconcile the periods already reported and those still outstanding.
Sources and scope: AEAT — 2026 transitional filing dates · Order HAC/623/2026 — official legislation
The form also changes: days, participation and expenses
Content changes apply to assessments submitted from 1 January 2027 regardless of accrual date. They include days and ownership-participation fields and a breakdown of deductible expenses for rented or sublet properties. The order contains other changes relevant when selecting the form.
Preparing records now helps with the transition. Keep invoices and payment evidence, distinguish repairs from improvements and retain the basis used for periods and shares. The existence of an expense box does not automatically make an expense deductible.
Sources and scope: Order HAC/623/2026 — official legislation · AEAT — 2026 transitional filing dates
Hypothetical example: a property with two uses
Consider an owner tax-resident outside Spain whose home is used personally for some months of 2026 and let for others. First document both periods, ownership share and income. If eligible and choosing annual grouping for tax-payable rental income, the window will be April 2027. Any imputation for other days has its own calculation and April–December 2027 window.
If she instead reports rental income separately, months before the final quarter do not automatically move to April. This example illustrates timing rather than calculating tax or assuming deductions: actual residence and figures remain necessary.
Sources and scope: AEAT — 2026 transitional filing dates · AEAT — Modelo 210 instructions
What falls outside this timetable?
The rental window described concerns returns with tax payable. The order retains specific rules for zero liability and refunds. Property disposals use a different timetable and require coordination with buyer withholding where applicable. IBI, local charges, wealth taxes or residence-country obligations do not disappear.
In foral territories, confirm the competent administration and applicable procedure. Permanent establishments, corporate structures or residence changes require individual analysis rather than relying solely on this explanation.
Sources and scope: Order HAC/623/2026 — official legislation · Non-Resident Income Tax Act
Three steps before your next filing
First, reconcile income and returns for 2025 and 2026 to avoid omissions and duplication. Second, confirm reporting method, expense records and days with your tax professional. Third, record filing and direct-debit dates separately, checking the applicable calendar when the date approaches.
Consult the general Modelo 210 guide and request assistance through Tax4Spain. Service scope is agreed with documentation and an advance quotation; neither this article nor the calculator submits a return for you.
Sources and scope: Tax4Spain — non-resident tax assistance · AEAT — 2026 transitional filing dates
Calendar at a glance
| Income category | Filing |
|---|---|
| 2025 imputed income | 1 Jan–31 Dec 2026 |
| 2026 imputed income | 1 Apr–31 Dec 2027 |
| Annually grouped 2026 rent, tax payable | 1–20 Apr 2027 |
| Separate July–September 2026 rent, tax payable | 1–20 Oct 2026 |
| Separate October–December 2026 rent, tax payable | 1–20 Apr 2027 |
Sources and scope: AEAT — 2026 transitional filing dates · Order HAC/623/2026 — official legislation
Read the full Modelo 210 guide
Prepared with AI assistance and editorially checked against the cited sources. It does not establish individual human review by Hugo or replace analysis of your circumstances. Examples are hypothetical.