Order HAC/623/2026: new Modelo 210 deadlines for imputed income and rentals

Order HAC/623/2026 of 12 June (Official State Gazette 23 June 2026) reforms the content and filing deadlines of Modelo 210 for non-residents’ property income: imputed income (code 02) and rental or subletting income (codes 01 and 35). Below we explain why the rule changed, what you must declare differently from 2027, and how to apply it with real examples.

1. Why the Tax Agency is changing Modelo 210

The Order’s official preamble is clear: the goal is not to raise the tax rate, but to improve tax control of property income and assistance to filers.

• More detail on deductible expenses. A new annex breaks down expenses for rented or sublet properties so the AEAT can see what is deducted (IBI, community fees, insurance, repairs, etc.) and later verify whether it is allowable.
• More property data. New boxes for “No. of days” and “Ownership share”, plus a cadastral-reference key (1 = with reference, 2 = without). This improves matching with the Cadastre and stops filers treating a shared flat or partial period as 100% of a full year.
• A more coherent calendar. After rental grouping moved from quarterly to annual (accruals from 2024), deadlines align in April of the following year, supporting a single assistance campaign.

In short: the AEAT wants more structured information and concentrates property filings in spring. The tax base and rates (19% EU/EEA or 24% elsewhere) do not change.

2. What changes in the form content

Content changes apply to returns filed from 1 January 2027, regardless of the accrual date. They include:

• A new deductible-expenses breakdown annex (rentals / sublets).
• “No. of days”: days available (imputed income) or days let (rentals).
• “Ownership share”: percentage of title.
• “Cadastral reference key” (values 1 or 2).

If you deduct expenses on a rental filed in the new April 2027 window, you must complete the annex. Without a breakdown, the risk of a tax enquiry rises.

3. New deadlines: imputed income (code 02)

Before: 1 January to 31 December of the year after accrual.
Now:1 April to 31 December of the following calendar year. Direct debit: 1 April to 23 December.

The new deadline applies to imputed income for 2026 (filing from 1 April 2027). Imputed income for 2025 still falls entirely within 2026.

Example 1 — Own use (as in the AEAT note)

A German resident buys a flat in Málaga on 1 April 2026 and keeps it for personal use.

• They must declare 2026 imputed income for the proportional period (9 months).
• Deadline: 1 April – 31 December 2027.
• Use the Modelo with the new content (days, ownership share, etc.).

Why “No. of days” matters: if the property was available for only 275 days, you must not compute imputation as if it were a full year.

4. New deadlines: rental or subletting (codes 01 and 35)

For self-assessments with tax to pay, the deadline becomes the first 20 calendar days of April of the year after accrual, whether you file separately or grouped.

Direct debit: 1 to 15 April of the following year.

Remember: for rental income accruing from 2024, the grouping period is annual (no longer quarterly).

Example 2 — Annual grouping

A Norwegian resident lets a chalet in Alicante from July 2026 and chooses to tax all income for the year on a grouped basis.

• File from 1 to 20 April 2027.
• Use Modelo 210 with the Order’s updates (including the expenses annex if you deduct).

Example 3 — Separate returns (critical transition)

Same owner, but files each income separately.

• July–September 2026: old Modelo 210, usual deadlines: first 20 days of October 2026. New deadlines do not apply.
• October–December 2026: already under the new window 1–20 April 2027, with the amended form. If you deduct expenses, complete the annex.

That is why the AEAT stresses: April–September 2026 without grouping is outside the deadline change; the last natural quarter of 2026 is inside it.

5. Practical 2026–2027 transition calendar

6. Before vs after (summary)

• Imputed income: filing start moves from January to April (more time to have cadastral value / IBI for the year).
• Rental with tax due: from a quarterly logic to a single window in April of the following year (aligned with annual grouping).
• Form: more boxes and an expenses annex → tighter control, fewer opaque deductions.

7. Checklist for non-residents

1. Identify whether your property generates code 02 (own use / vacant) or 01/35 (rental).
2. If you let in 2026: decide now between grouped and separate filing; the calendar depends on that choice.
3. Keep invoices for deductible costs (IBI, community fees, insurance, repairs) for the new annex.
4. Record days of availability / letting and your ownership percentage.
5. Have the cadastral reference ready (key 1) or document why it does not exist (key 2).
6. If you direct-debit: respect 1–15 April (rentals) or until 23 December (imputed income).

Conclusion

Order HAC/623/2026 does not reinvent Non-Resident Income Tax: it reorders deadlines and demands more detail so the AEAT can assist better and check deductions. The real risk for non-residents is mixing up the transition calendar (especially ungrouped 2026 rentals) or filing in 2027 without the expenses annex.

At SpainTaxForm we help you choose the right regime, compute the base (including days and ownership share) and file Modelo 210 on time with the content the new Order requires.

Sources

• 1AEAT — Note on Modelo 210 filing deadline changes (Order HAC/623/2026)
• 2BOE-A-2026-13573 — Order HAC/623/2026 of 12 June
• 3AEAT — Modelo 210 Non-Resident Income Tax