New IRNR Forms 2026: What Changes for Non-Residents with Real Estate or Dividends in Spain

Key data

Non-residents with real estate or shareholdings in Spanish companies have a new obligation from June 23, 2026: the forms of the Non-Resident Income Tax (IRNR) have changed, and the previous models are no longer valid in their previous format. The Order HAC/623/2026 modifies three previous ministerial orders—EHA/3316/2010, EHA/3290/2008 and EHA/1658/2009—and introduces new annexes and boxes in five tax models.

The Tax Authority's objective is clear: to obtain more detailed information to cross-reference data and verify refund requests, especially for dividends. For filers, this means more fields to fill and greater precision in the documentation they must provide.

What does this regulation establish?

Order HAC/623/2026 introduces specific changes in each of the affected models. Below is the complete detail by model:

The most operationally relevant change is the new breakdown annex of model 210, which is divided into two blocks according to the type of income:

• For dividends: it is required to indicate the market key, the LEI code (legal entity identifier) and the ISIN code (international securities identifier). This data allows the AEAT to cross-reference information with financial markets and verify refund requests.
• For real estate income: boxes are added for the number of days the real estate is available, the percentage of participation of the filer and the cadastral reference of the property. Additionally, a specific breakdown of deductible expenses is incorporated.

Economic and operational impact

The impact is not direct cost in the form of new fees or amounts, but rather operational and compliance. The changes generate three types of consequences for those affected:

• Greater administrative burden: tax representatives of non-residents will need to collect additional data before filing declarations—especially the LEI code and ISIN code for dividends, which require consultation with financial entities or depositaries.
• Risk of incorrect filings: using previous formats or failing to complete the new mandatory fields may result in rejected declarations or delays in refunds.
• Change in model 210 deadlines: filing deadlines are modified for two specific cases: imputed income and rentals with result to be paid. Filers must verify the new calendars to avoid late filings.

For withholding agents (Spanish companies that pay dividends to non-resident shareholders or that acquire real estate from non-residents), the update of model 216 and 296 implies reviewing the systems for generating declaration files to adapt them to the new technical records.

Who does it affect?

• Non-resident individuals with real estate in Spain (for rent or at their own disposal) who file model 210.
• Non-resident legal entities (investment funds, foreign companies) with shareholdings in Spanish companies that receive dividends.
• Tax representatives in Spain of non-residents without permanent establishment, who manage the filing of models 210, 211, 213, 216 and 296.
• Non-resident entities subject to the special levy on real estate (model 213).
• Spanish withholding companies that pay income to non-residents and file models 216 and 296 (annual declaration of withholdings).
• Tax advisors and management firms that manage portfolios of non-resident clients with assets in Spain.

Practical example

A German investment fund has shareholdings in a Spanish listed company and receives annual dividends on which withholding is applied in Spain. Until now, its tax representative filed model 210 to request a refund of excess withholding by applying the double taxation treaty.

From June 23, 2026, that same refund request must include in the new annex of model 210: the market key where the securities are listed, the LEI code of the German fund and the ISIN code of the securities on which the dividends were received. Without these three pieces of data, the declaration will be incomplete and the AEAT may reject or withhold the refund.

The tax representative will need to coordinate with the depositary or custodian of the securities to obtain this information before filing the model, which adds steps to the usual management process.

What should companies do now?

1. Identify which models you file: review whether your company or your non-resident clients are required to file any of models 210, 211, 213, 216 or 296. If so, the changes affect you from now on.
2. Update the forms: download the new models from the AEAT electronic office. Previous formats do not include the new mandatory fields.
3. Collect the new data for dividends: if you manage refund requests for withholding on dividends, obtain the LEI code of the non-resident entity, the ISIN code of the securities and the corresponding market key. Coordinate with the depositary or custodian.
4. Collect the new data for real estate: for real estate income, have ready the cadastral reference of the property, the number of days of availability during the period and the percentage of participation of the filer in the property.
5. Verify the new deadlines for model 210: the filing deadlines for imputed income and rentals with result to be paid have changed. Review the updated calendar to avoid late filings.
6. Adapt file generation systems: if you file model 216 or 296 electronically through files, update the systems to incorporate the new technical records for payees and payment certificates.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-13573