Must all foreign property owners pay tax in Spain?

In principle, yes — with one important qualification. Only those who are not tax-resident in Spain fall under the non-resident income tax, the IRNR. Anyone who lives in Spain and has their tax domicile there is a tax resident and files the Modelo 100 instead. For the vast majority of foreign property owners in Spain, the position is clear: they live abroad, own a holiday home or investment property, and are taxable under the IRNR regardless of their nationality. This includes British owners who, since Brexit, are classified as third-country nationals and taxed at 24% rather than 19%. There is no exemption for low-value properties or short ownership periods. Someone who bought a property in October and owned it for only three months of the tax year must still file, with the tax calculated pro rata for the days of ownership. Genuine exceptions to the Modelo 210 obligation are narrow. First, properties in the Foral territories — the Basque provinces of Álava, Guipúzcoa and Vizcaya, and the Comunidad Foral de Navarra — are governed by separate regional tax regimes and do not fall under the national Modelo 210. Second, certain double taxation agreements can in theory limit or eliminate the Spanish tax obligation, but for property income this is rare — most DTAs, including those between Spain and the UK, the US and Switzerland, expressly assign taxation rights to the country where the property is located. For a practical test: if you own a property on Mallorca, the Costa del Sol, the Costa Blanca, the Canary Islands, or anywhere else in Spain outside the four Foral provinces, and you are not tax-resident in Spain, you are required to file the Modelo 210 annually. The property type — apartment, villa, finca, commercial unit — makes no difference. The filing obligation is universal, and it begins from the first day of ownership.