Do I also have to declare my Spanish property in my UK or Irish tax return?

Not let: usually nothing at home

The Spanish imputed-income tax is specific to Spain. Neither HMRC nor the Irish Revenue Commissioners tax you on the notional benefit of using your own holiday home, so a property you keep for yourself does not normally appear on your return. The flip side is that the Spanish tax on imputed income cannot be credited against anything at home: it is a straight cost. Unusual structures (a company, a trust, someone paying you to use the home) can change that, so check with an adviser if they apply.

Let: declare in both countries

Rental income is taxed first in Spain, on Modelo 210, then again in your country of residence:

• United Kingdom: on the foreign property pages of Self Assessment (SA106), using UK rules on allowable expenses, with foreign tax credit relief for the Spanish tax. The credit cannot exceed the UK tax on that same income.
• Ireland: on Form 11, with a credit for the Spanish tax under the Ireland–Spain double taxation agreement, on similar principles.

Because Spain taxes UK residents at 24 % on gross rent while the UK taxes the profit, the Spanish tax can exceed the UK tax, and the excess is lost. Irish residents, who pay 19 % on net income in Spain, are less likely to face that gap. See will I be taxed twice.

Selling: also a home-country matter

A gain on a Spanish sale is taxed in Spain at 19 % and must generally be reported in the UK or Ireland too, where capital gains rules apply, with relief for the Spanish tax. Exchange rates on both purchase and sale dates matter for the home calculation.

American owners

US citizens and residents are taxed on worldwide income, so Spanish rent and gains belong on the US return, with a possible foreign tax credit. Separately, a Spanish bank account may need to be reported to the US Treasury (FBAR) above certain thresholds. Check the current US rules with a US tax preparer.

Our detailed guide on declaring Spanish property in the UK and Ireland covers SA106 and Form 11 line by line.