What is the difference between IRPF and IRNR?

IRPF and IRNR are two distinct tax regimes for two distinct groups of people — and confusing them is one of the more common errors among foreign property owners in Spain. IRPF (Impuesto sobre la Renta de las Personas Físicas) is the Spanish income tax for residents. Anyone who is tax-resident in Spain — broadly, anyone spending more than 183 days per year there or having the centre of their economic interests in the country — falls under the IRPF and files the Modelo 100. The IRPF captures worldwide income: salary, capital gains, rental income, pensions, dividends — everything. IRNR (Impuesto sobre la Renta de No Residentes) is the income tax for non-residents. It captures only income with a Spanish nexus: rental income from a Spanish property, imputed income from property ownership, capital gains on the disposal of Spanish property. The relevant form for property owners is the Modelo 210. The practical difference that matters most is the treatment of expenses. Residents can deduct a wide range of costs and claim personal allowances. Non-residents from EU and EEA countries can, under certain conditions, also deduct directly related expenses against rental income — mortgage interest, local property tax (IBI), community charges, insurance premiums, depreciation. For third-country nationals — including British owners since Brexit, as well as US, Swiss, Canadian and Australian citizens — the position under current legislation (Article 24 LIRNR) is less favourable: no expense deduction is permitted, and the tax rate is 24% on gross income rather than 19% on net income. However, the Audiencia Nacional ruled on 28 July 2025 (SAN 3630/2025) that this exclusion violates the EU free movement of capital (Article 63 TFEU). The ruling is not yet final and the Spanish Tax Agency continues to apply current legislation pending the Supreme Court's decision. British and Swiss owners with rental income should monitor this development closely and consider consulting an Asesor Fiscal.