IRNR (Impuesto sobre la Renta de no Residentes)
IRNR is Spain's income tax for non residents. If you are not a Spanish tax resident but you earn income from Spanish sources, such as rental income from a property you own in Spain, capital gains from selling Spanish assets, or employment income from work performed on Spanish territory, IRNR is the tax that applies. The acronym stands for Impuesto sobre la Renta de no Residentes, which translates to Income Tax for Non Residents.
The key difference with IRPF
IRPF and IRNR are mutually exclusive. If you are a Spanish tax resident (183 or more days per year in Spain, or your economic centre of life is here), you pay IRPF on your worldwide income at progressive rates up to 47%. If you are not a Spanish tax resident, you pay IRNR only on Spanish sourced income at flat rates. You never pay both on the same income.
The distinction matters enormously. A non resident who owns a holiday apartment in Spain and rents it out pays IRNR only on the rental income generated in Spain. A resident who owns the same apartment pays IRPF on that rental income plus all their other worldwide income.
The flat rates
IRNR applies flat rates rather than progressive brackets. The rates for 2026 are:
19% for residents of EU and EEA countries (plus Iceland and Norway). This rate also applies to Swiss residents under the bilateral agreement.
24% for residents of all other countries (UK post Brexit, US, Canada, Latin America, etc.).
Capital gains from selling Spanish property: 19% regardless of the seller's country of residence.
These rates apply to the gross income in most cases. EU and EEA residents can deduct directly related expenses (such as property maintenance costs for rental income), effectively being taxed on net income. Non EU residents are generally taxed on gross income without deductions, which makes the effective tax burden significantly higher.
What triggers IRNR
The most common situations where non residents encounter IRNR are:
Owning property in Spain. Even if you do not rent it out, Spain applies an imputed income tax (imputación de rentas inmobiliarias) on the deemed rental value of your property, calculated as 1.1% or 2% of the cadastral value depending on when it was last revised.
Renting out Spanish property. The actual rental income is taxed at 19% or 24% depending on your country of residence.
Selling Spanish property. The capital gain is taxed at 19%. The buyer is required to withhold 3% of the purchase price and pay it directly to the Agencia Tributaria as an advance payment on the seller's IRNR. The seller then files to settle any difference.
Working temporarily in Spain without becoming tax resident. Employment income for work performed on Spanish soil is subject to IRNR.
Receiving dividends, interest, or royalties from Spanish sources.
How to file
IRNR is filed via Modelo 210. For rental income or imputed income, the filing is typically annual. For property sales, filing is required within three months of the transaction. You can file through the Agencia Tributaria sede electrónica with a Certificado Digital, or through a fiscal representative in Spain. Non residents from outside the EU are technically required to appoint a fiscal representative in Spain, although enforcement of this requirement is inconsistent.
The 3% retention on property sales
When a non resident sells property in Spain, the buyer must retain 3% of the total purchase price and pay it to the Agencia Tributaria via Modelo 211. This is not an additional tax. It is an advance payment against the seller's IRNR liability on the capital gain. The seller then files Modelo 210 to declare the actual gain. If the 3% retention exceeds the tax owed, the seller can request a refund. If the gain is higher, the seller pays the difference.
This mechanism exists to prevent non residents from selling and leaving Spain without paying the capital gains tax. As a buyer, you must ensure this retention is made, otherwise you may be held jointly liable for the seller's tax.
Transitioning from IRNR to IRPF
If you move to Spain and become a tax resident, you transition from IRNR to IRPF. This happens in the calendar year you cross the 183 day threshold or establish your economic centre of life in Spain. From that year onward, you file IRPF on your worldwide income. Any pending IRNR obligations from the period before residency still need to be settled separately.
If you qualify for the Beckham Law, you are taxed under IRPF but with rules that resemble IRNR: a flat 24% on Spanish employment income and no taxation on most foreign income. Our Beckham Law Spain page explains how this works.
