As an American living in Spain, taxes on your salary usually go to Spain alone, though you still file a US return.
Spain taxes its residents on worldwide income, at a state rate plus a regional one. From €60,000 to €300,000 of taxable income, the state rate is 22.5%. Where your region’s scale matches the state’s, the combined rate in that band is about 45%. The US keeps taxing you as a citizen, and Form 1116 lets you credit Spanish income tax against the US bill.
Updated · Sources
Spanish rules for Americans, 2026
- 183
- days in a calendar year, short trips abroad usually included, is the most Spain can count before you become resident.
- 24%
- is the Beckham regime’s flat rate on work income up to €600,000, for newcomers who elect it.
- €50,000
- of accounts outside Spain, at year end or as a last-quarter average, is the most an ordinary resident holds without filing Modelo 720.
What decides your taxes as an American in Spain?
You are a US citizen or green card holder
A Form 1040 is due once your gross income, counting pay you exclude, reaches the IRS filing threshold. From Spain, you have until June 15 to file. Interest on any tax still owed runs from April 15.
Spain treats you as a tax resident
Spain decides residence by your days there and by where your work, investments and family are based. Residents generally file a Spanish return each year. For 2025 income, Spain’s window ran from April 8 to June 30, 2026, ending two weeks after the June 15 US deadline.
You moved to Spain to work
You may elect the Beckham regime if you were not resident in Spain in the 5 tax years before your move. The move must come from a job, a company directorship, an entrepreneurial activity, or highly qualified startup or R&D work. An employee working remotely on Spain’s international telework visa, often called its digital nomad visa, qualifies too. You must tell Spain’s tax agency you elect within six months of the start date on your Spanish Social Security registration.
You keep accounts in both countries
Once the highest balances of your foreign accounts total more than $10,000, each one belongs on an FBAR. The FBAR is due to FinCEN on April 15, with an automatic extension to October 15. Spain’s Modelo 720 lists your accounts outside Spain, US ones included, and is due between January 1 and March 31.
You work for yourself
You can owe US self-employment tax even in a year when the credit leaves no US income tax. The exclusion does not reduce it, and the credit cannot offset it. Only the US-Spain totalization agreement, in effect since April 1, 1988, can remove it.
Form 8938, a second US report of foreign assets, goes with your tax return. For a single filer living abroad, Form 8938 is due once foreign assets top $200,000 at year end or $300,000 at any point. A joint return doubles both thresholds.
For a single filer on the Beckham regime, US tax remains only on salaries above about $335,000.
Salary of $200,000
$0
Spain collects $48,000 against $36,734 of US tax, so none of the US tax is left. The unused $11,266 of credit can be carried to other years.
Salary of $300,000
$0
Spain’s $72,000 still tops the US tax of $68,134.
Salary of $400,000
$7,134
US tax of $103,134 now tops Spain’s $96,000, and the credit covers only what Spain charged.
Salary of $500,000
$18,134
Each extra dollar costs 35% in US tax against Spain’s 24%, so the gap keeps growing.
Each value is the US income tax left after the credit for Spanish tax. The US figures apply the 2026 single brackets and the $16,100 standard deduction, from Rev. Proc. 2025-32. Spain’s tax is a flat 24% of each salary, which holds for pay under €600,000. A flat rate takes the same share in any currency, so the dollar figures need no exchange rate. Claiming the exclusion instead would leave more US tax at $300,000 and above, so only the credit is shown.
How does the Beckham regime change what Spain taxes?
An American who elects the Beckham regime is taxed under Spain’s non-resident rules while still living there. The figures are those in force for 2026.
| Ordinary resident | Beckham regime | |
|---|---|---|
| Tax on a salary | State plus regional scales The state’s top rate is 24.5% | 24% flat 47% above €600,000 |
| Income from abroad | Taxed in Spain | Generally untaxed Your salary is still taxed |
| Dividends, interest and gains | 19% to 30% On a separate savings scale | Taxed only if from Spain |
| Wealth tax | On worldwide assets Above your region’s allowance | On Spanish assets only |
| How long it lasts | While you stay resident | 6 tax years The year you move and the next 5 |
Neither column changes how the US taxes you. Your US return reports worldwide income either way, and only the Spanish tax you can credit differs.
What do Americans in Spain tend to miss?
Funds and ETFs set up in Spain
Most funds and ETFs organized in Spain count as passive foreign investment companies (PFICs) under US law. PFIC shares are taxed under their own US rules, and a Form 8621 may be due for each fund.
A Spanish pension plan
The US may tax the growth inside your Spanish plan de pensiones before you draw it. Treaty Article 20(5) defers tax only on a pension fund in the other country, which for a Spanish resident means a US plan. The saving clause would let the US ignore that rule for a citizen anyway. Funds inside the plan may also be PFICs.
Spain’s wealth tax
Spain’s wealth tax applies above an allowance your region sets, or €700,000 where the region has set none. A return is due once tax is payable or your assets are worth more than €2,000,000. It is not an income tax, so none of it can be credited against US tax.
US investments under the Beckham regime
Under the Beckham regime, the US taxes your US dividends and gains, but Spain generally does not. That leaves no Spanish tax to credit against the US bill. Spanish tax on your pay cannot cover it either. The credit only offsets US tax on foreign income, and US dividends are US income.
Reading the Modelo 720 exemption as an FBAR exemption
Beckham regime taxpayers do not file Modelo 720. That exemption is Spanish, so the US still wants an FBAR for your accounts in Spain. A spouse or child who is resident in Spain may still have to file Modelo 720.
We file your US return and credit the income tax you paid Spain.
We prepare the US return only. Your gestor or asesor fiscal keeps filing your Spanish return, whether or not you are on the Beckham regime.
- We claim the credit on Form 1116, using the Spanish tax your gestor or asesor fiscal reports on your Spanish return.
- We file your FBAR for your Spanish accounts, and Form 8938 if your assets pass its threshold. Your quote prices each account and Spanish fund.
- We compare the credit with the exclusion for your Spanish pay and use whichever leaves less US tax.
- We work out estimated payments on dividends the Beckham regime leaves untaxed.
- We answer IRS or state letters on returns we prepared, including queries on your Spanish tax credit, within your fee.
- Individual return
- from $195
- Business return
- from $495
We quote a flat fee before work starts. We do not bill hourly.
What Americans in Spain ask about paying tax in both countries.
Do American expats pay taxes in Spain?
Yes, an American who is resident in Spain pays Spanish income tax on worldwide income. You are usually resident for the whole calendar year once you spend more than 183 days of it in Spain. A newcomer on the Beckham regime pays Spanish tax on all pay, but generally not on other income from abroad. The US taxes you too, and a credit for Spanish tax often clears the US bill on your pay. The credit usually beats the foreign earned income exclusion, because Spanish tax on excluded pay cannot be credited.
Will Spain tax my US social security?
Spain may tax US Social Security paid to a Spanish resident, since nothing in the US-Spain treaty stops it. The treaty’s Article 20(1)(b) keeps the US right to tax benefits the US pays, without making that right exclusive. Where both countries tax the same benefits, Article 24 provides the relief. France is different, since its treaty leaves US Social Security to the US alone.
How does Spain know if I’m a tax resident?
Spain applies two tests from its income tax law, and meeting either one makes you resident. The first is spending more than 183 days in Spain in a calendar year. Short trips abroad still count as days in Spain, unless you prove you are tax resident in another country. The second is having your main business or economic interests in Spain. Spain also presumes you are resident if your spouse and dependent minor children live there.
Do retired expats pay taxes in Spain?
Yes, retired Americans who are resident in Spain pay Spanish income tax on worldwide income, including most pensions. A US government pension is the exception: under Article 21, only the US taxes it, unless you are also a Spanish national. The treaty’s Article 20(1)(a) gives Spain the sole right to tax a private pension from past employment. The saving clause still lets the US tax a citizen on it, with relief for the double tax under Article 24. Spain cannot tax the growth inside a US 401(k) or IRA until you draw it. US Social Security can be taxed by both countries.
What is the tax rate in Spain for foreigners?
Foreigners who are resident in Spain pay the same income tax rates as Spaniards. The state scale runs from 9.5% to 24.5%, and each region adds its own scale on top. Dividends, interest and gains are taxed on a separate scale, from 19% to 30%. A qualifying newcomer can elect the Beckham regime instead, which taxes pay at 24% up to €600,000. Portugal’s IFICI regime sets a 20% rate on qualifying work for some new residents.
Does the US-Spain tax treaty stop double taxation?
The US-Spain tax treaty relieves most double taxation through Article 24, but it does not stop the US from taxing you. Its saving clause, Article 1(3), lets the US tax its citizens as if the treaty did not exist. Article 24 is among the rules the saving clause leaves in force. The 1990 treaty was amended by a protocol in force since November 27, 2019.
Sources
- US-Spain income tax convention (1990)
- Protocol to the US-Spain convention (2013)
- Spain, Ley 35/2006 del Impuesto sobre la Renta de las Personas Físicas (personal income tax law)
- Spain, Real Decreto 439/2007, Article 116 (electing the Beckham regime)
- Spain, Real Decreto 1065/2007, Article 42 bis (reporting of accounts abroad, Modelo 720)
- Agencia Tributaria, Modelo 720 questions: who must file
- Spain, Ley 19/1991 del Impuesto sobre el Patrimonio (wealth tax)
- Agencia Tributaria, 2025 income tax return dates (IRPF 2025 manual)
- IRS, Rev. Proc. 2025-32 (2026 inflation adjustments)
- IRS, Publication 54, Tax Guide for U.S. Citizens and Resident Aliens Abroad
- IRS, Comparison of Form 8938 and FBAR requirements
- 26 U.S.C. § 904, Limitation on credit
- 26 U.S.C. § 1297, Passive foreign investment company
- Social Security Administration, US international social security agreements
Reviewed and updated September 2026. General information, not advice for your situation.