Modelo 210 for US citizens — what do I need to know?

US citizens pay the third-country IRNR rate of 24% — on both imputed income and rental income. 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. For rental income, current legislation (Article 24 LIRNR) denies the expense deduction: the 24% rate applies to 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. Individual advice from an Asesor Fiscal is recommended. The double taxation agreement between the United States and Spain is in force and assigns the taxing rights: Spain has the right to tax income from Spanish property. The IRNR paid in Spain is credited against US federal tax. However, US citizens are subject to worldwide taxation — all income, including Spanish property income, must be reported on the US tax return. The Spanish tax is credited via the Foreign Tax Credit (Form 1116). US persons remain subject to US taxation on their worldwide income. Spanish property income and the Spanish tax paid may be relevant for the US tax return — a tax adviser specialising in international tax law is recommended. Spanish deadlines: imputed income by 31 December of the following year (tax year 2025; from tax year 2026, changed deadlines apply per Orden HAC/623/2026), rental income by 20 January of the following year. The filing obligation exists independently of the DTA. US owners on Mallorca and the Costa del Sol should coordinate the overall tax position — Spanish IRNR, US federal tax and FATCA obligations — with an Asesor Fiscal experienced in US-Spanish cross-border matters.