What tax rate applies for EU citizens under the Modelo 210?

The rule is straightforward: all EU member states and EEA countries pay 19%. Everyone else pays 24%. What matters is tax residency, not nationality. A German national tax-resident in Switzerland is treated as a third-country national; a British national tax-resident in Germany is treated as an EU resident. These rates apply to ongoing income — self-use and rental. Capital gains on property sales are subject to different rules. The 19% rate applies to: Germany, Austria, France, the Netherlands, Belgium, Italy, Sweden, Denmark, Finland, Ireland, Portugal, Greece, Poland, the Czech Republic, Hungary, Romania, Bulgaria, Croatia, the Baltic states and all other EU member states. Norway, Iceland and Liechtenstein, as EEA members, are treated equivalently and also pay 19%. The 24% rate applies to: the United Kingdom (since Brexit on 1 January 2021), Switzerland, the United States, Canada, Australia, Mexico, Argentina, Colombia, Venezuela, Brazil, Chile and all other third countries. The difference extends beyond the rate to the treatment of expenses on rental income. EU and EEA citizens can deduct directly related costs — mortgage interest, IBI, community charges, insurance, depreciation — and pay 19% on the net amount. Third-country nationals, under current legislation (Article 24 LIRNR), cannot deduct any costs and pay 24% on gross rental receipts. 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. For imputed income (self-use or vacancy), no expense deduction is available to either group — the difference lies solely in the rate: 19% versus 24% on the same imputed amount. For property owners on Mallorca, the Costa del Sol and the Canary Islands, this distinction is particularly relevant, as all the nationalities listed above are represented among buyers in these regions.