Spanish property: what to declare in the UK and Ireland (SA106, foreign tax credit)

You have dealt with your Modelo 210 in Spain. Do you also need to tell HMRC or the Irish Revenue Commissioners anything? The answer depends on how you use the property. For a holiday home you keep for yourself, there is generally nothing to declare at home. For a property you let, the rent must be declared in both countries, with a credit mechanism that stops you paying the full tax twice — but which does not always cancel out the Spanish tax.

Fiscasa is a private service, independent of the Agencia Tributaria, HMRC and the Irish Revenue Commissioners. This guide summarises the rules published by HMRC (SA106 notes, helpsheet HS263) and by Revenue; it is not a substitute for advice from HMRC, Revenue or a tax adviser on your situation.

The framework: the double taxation conventions

UK: the UK–Spain Double Taxation Convention was signed on 14 March 2013 and applies, for UK income tax and capital gains tax, from 6 April 2015. Ireland: Ireland and Spain also have a double taxation agreement in force. For property, both follow the same logic:

1. Spain may tax the income from a property located on its territory — rent, the "direct use" of the property, and gains on a sale (articles 6 and 13 of the UK–Spain convention). That is what Modelo 210 is for.
2. Your country of residence taxes you on your worldwide income and gives a credit for the Spanish tax against its own tax on the same income (article 22 of the UK–Spain convention, "subject to the provisions of the law of the United Kingdom").

The key point: the credit can never exceed the UK (or Irish) tax on that same income. If the Spanish tax is higher, the excess is lost. If there is no UK or Irish tax on that income, there is nothing to credit it against.

Case 1: a property you don't let (holiday home)

In Spain you pay tax on a notional imputed income (see imputed income on a property you don't let).

In the UK, using your own home does not give rise to any taxable income: there is no rent, so there is no overseas property business to declare on the SA106. Because foreign tax credit relief is limited to the UK tax on the same income — here zero — the Spanish tax on imputed income does not give rise to any credit. It is a final cost. HMRC's guidance does not address Spanish imputed income by name; this conclusion follows from the general rules, so if your situation is unusual (property held through a company or trust, someone paying you to use it), check with an adviser.

In Ireland, Revenue states explicitly that tax paid abroad on deemed rental income — income assumed from a property even when it is not let — cannot be offset against your Irish tax. Again, nothing to declare in Ireland, and no credit.

Case 2: a property you let — UK residents

Where it goes: the SA106 "Foreign" pages

Rent from a Spanish property is declared on the "Foreign" supplementary pages (SA106) of your Self Assessment return, in the section "Income from land and property abroad" (pages F 4 and F 5, boxes 14 to 32). You are taxable on it even if you never bring the money into the UK (unless you qualify for the new "FIG" regime for recent arrivals).

Your overseas lettings form an overseas property business, separate from any UK lettings:

• total rents go in box 14, allowable expenses in box 17;
• residential mortgage interest is not deducted as an expense but gives a basic-rate tax reduction (box 24.1);
• a loss can only be carried forward against future overseas property profits (box 26), not against UK rental profits;
• if your total property income (UK + overseas) is £1,000 or less, the property income allowance means you don't need to declare it at all; above that, you can choose the £1,000 allowance instead of deducting actual expenses.

Claiming the credit for Spanish tax

In the summary columns: country code (ESP) in column A, profit in column B, Spanish tax paid in column C, and an "X" in column E to claim Foreign Tax Credit Relief. You don't have to calculate the relief yourself: HMRC works it out if you complete the boxes and file on time (box 2 on page F 1 is only for those who calculate it themselves, using helpsheet HS263).

HMRC's conditions: you must be UK resident, the Spanish tax must have been properly charged under Spanish law (having claimed the reliefs available in Spain), and the relief cannot exceed the UK tax on the same income.

UK rules, not Spanish rules

The profit you declare in the UK is calculated under UK rules, in pounds, for the UK tax year (6 April to 5 April) — whereas Spain works on the calendar year. You will usually need to apportion the Spanish rent and tax between two UK tax years, and convert them at the exchange rate when the income arose (HMRC publishes yearly average rates you can use).

The figures will differ. In particular, as a UK resident you pay Spain 24% on your gross rent with no expenses deducted, while the UK taxes your net profit at your marginal rate. Since 6 April 2025 the furnished holiday lettings regime no longer exists: a Spanish holiday let is taxed like any other letting.

Worked example (UK)

Rachel, a UK resident, lets her flat in Málaga long-term. For simplicity, assume the whole letting falls within one UK tax year and €1 = £0.85.

• Rent: €8,400 = £7,140
• Spain: 24% × €8,400 = €2,016 = £1,713.60 of Spanish tax (no expenses deductible for a UK resident)
• UK: allowable expenses (agent, IBI, community fees, insurance, repairs) of £2,140 → profit £5,000

If Rachel is a basic-rate taxpayer: UK tax 20% × £5,000 = £1,000. The credit is capped at £1,000, so she pays nothing more in the UK — but £713.60 of Spanish tax goes unrelieved.

If Rachel is a higher-rate taxpayer: UK tax 40% × £5,000 = £2,000, less a credit of £1,713.60 = £286.40 to pay in the UK.

Spanish courts have recently questioned whether denying expense deductions to non-EU residents is lawful. If this concerns you, ask a Spanish adviser whether a claim is worthwhile; Fiscasa does not handle litigation.

Case 2 bis: a property you let — Irish residents

Rent from a Spanish property is foreign rental income, taxed in Ireland under Case III of Schedule D. It goes on your annual return — Form 11 (self-assessment), or Form 12 for employees and pensioners. Revenue indicates that if your gross non-PAYE income is under €30,000 and your net non-PAYE income under €5,000, you may be able to pay the tax by having your tax credits reduced.

• The net rent is calculated under Irish rules, with Revenue's list of allowable and non-allowable expenses.
• A foreign rental loss can only be set against other foreign rental profits, not against Irish rental profits.
• Because Spain and Ireland have a double taxation agreement, the Spanish tax is given as a credit against the Irish tax on that income, up to the amount of that Irish tax.

As an EU resident, you pay Spain only 19% on net rent (expenses deductible), so the Spanish tax is usually lower than the Irish tax and the credit is fully used.

Worked example (Ireland)

Seán, an Irish resident, lets his flat in Alicante. Rent: €8,400.

• Spain: net rent after Spanish expenses and depreciation of €4,000 → 19% = €760
• Ireland: net rent under Irish rules of €5,000, taxed at 40% = €2,000 of income tax
• Credit for Spanish tax: €760 → €1,240 of income tax to pay in Ireland

USC and PRSI may also be due on this income; how the credit interacts with them should be checked with Revenue or an adviser.

Other things to declare at home

Bank interest

If you have a Spanish bank account (often opened to pay the IBI and community fees), any interest is foreign savings income to declare on the SA106 (UK) or your Irish return. Ireland also has specific disclosure rules for foreign bank accounts: check Revenue's guidance.

Selling the property

A gain on selling a Spanish property is taxable in Spain (see selling a property in Spain) and also in your country of residence, with a credit for the Spanish tax.

• UK: declare the gain on the Capital Gains Tax pages (SA108) and claim the Spanish tax on the SA106 (boxes 33 and 37 to 40). Residential property gains are taxed at 18% or 24%, after the annual exempt amount. The gain is calculated in pounds, using the exchange rates at purchase and at sale.
• Ireland: capital gains tax at 33%, with a credit for Spanish tax, and payment deadlines that depend on the date of sale.

These calculations are technical: get professional advice.

Spanish wealth tax

Non-residents whose Spanish assets exceed an exempt amount may owe Spanish wealth tax. Neither the UK nor Ireland has an equivalent tax, so there is no credit for it at home. Check your position with a Spanish adviser if your Spanish assets are substantial.

The UK–Ireland–Spain calendar

Period	Spain	UK	Ireland
1–20 April 2027	2026 rentals (Modelo 210)	—	—
April–December 2027	2026 imputed income: 1 April–31 December	—	—
31 October 2027	—	—	2026 return (Form 11), later date for online ROS filers
31 January 2028	—	2026–27 online Self Assessment	—

From 2027, the Spanish rental return (April) comes before the Irish return (October) and the UK online deadline (January): you will have the Spanish figures in hand when you fill in your home return.

What Fiscasa does

With every rental return, Fiscasa gives you a "home tax return" summary: gross rent, days let, property address and the Spanish tax paid, set out to make it easier to complete your SA106 or Irish return. This summary is an aid only: your UK or Irish return remains your responsibility, and we recommend having complex situations checked by an accountant or tax adviser. See our pricing.

FAQ

Do I need to declare the imputed income on my Spanish holiday home in the UK or Ireland?

Generally not: a home you keep for your own use produces no taxable income in the UK or Ireland. Only the Spanish tax is due.

Can I deduct the Spanish tax from my UK or Irish tax?

For rental income, yes, as a credit — but only up to the UK or Irish tax on that same income. For imputed income, no credit is available.

If the Spanish tax is higher than the UK tax, is the excess refunded?

No. The credit is limited to the UK tax on the foreign income, and the excess cannot be set against your other income or refunded by HMRC. This is common for UK residents, who pay 24% on gross rent in Spain.

What exchange rate should I use?

HMRC asks you to convert at the rate when the income arose and publishes yearly average rates you can use; be consistent from year to year. In Ireland the rent is already in euros.

I've never declared my Spanish rent at home. What should I do?

In the UK, HMRC's Worldwide Disclosure Facility is designed for disclosing undeclared foreign income; in Ireland, make an unprompted disclosure to Revenue. The credit for Spanish tax often limits what you owe, but interest and penalties may apply: get advice.

Should the rent declared at home and in Spain be the same?

The gross rent, yes (allowing for currency conversion and, in the UK, the different tax year). The net profit, no: each country applies its own rules on deductible expenses.