French inheritance law: what US heirs need to know
Learn how French inheritance law affects US heirs, including the 2021 reform, inheritance tax, filing deadlines, property transfers and key US reporting.
Spain's wealth tax for non-residents comes as a surprise for many Americans, usually after they buy a holiday home or open a Spanish bank account.
The wealth tax in Spain is an annual tax on the net value of what you own, calculated on your position as of December 31st each year.¹
Both residents and non-residents can owe the wealth tax in Spain, but what you pay depends on where you live for tax purposes and where your assets are located.
Here's everything you need to know.
We'll also introduce the Wise account, which allows you to send, spend, and receive your money across the globe in over 40 currencies – all at the fair mid-market rate.
Yes. Spain taxes non-residents on the assets they own inside the country, even if they don't live there.
The main wealth tax is called Impuesto sobre el Patrimonio, and it's an annual tax on the net value of your Spanish assets. "Net" means the value of what you own minus certain deductible debts.
There is also a second, separate tax aimed at very large fortunes: the Solidarity Tax on Large Fortunes (Impuesto Temporal de Solidaridad de las Grandes Fortunas, often shortened to ISGF).
It applies when net wealth goes above 3 million EUR, and it works the same way across the country, so regions can't reduce or remove it.²
If you owe both taxes, any wealth tax you have already paid is credited against the solidarity tax, so you aren't taxed twice on the same wealth.
For Americans, it's important to understand that "non-resident" refers to your tax residency, not your nationality. A US citizen can be a Spanish tax resident.
You are generally treated as a Spanish tax resident if any of the following apply:³
- You spend more than 183 days in Spain during the calendar year
- Your main economic interests or business activity are based in Spain
- Your spouse and dependent minor children live in Spain, which Spain treats as a presumption of residency unless you prove otherwise
If none of these apply to you, you're likely a non-resident for tax purposes. However, make sure to confirm this with a tax professional if you're not entirely sure.
When you're a non-resident, you may still have to pay the Spanish wealth tax. However, in this case, Spain only taxes you on your Spanish assets instead of your worldwide wealth.
As a non-resident, you are taxed only on assets and rights that are located in Spain or can be exercised in Spain. Anything you own outside the country stays out of the calculation.¹
Taxable assets can include:
- Spanish real estate
- Money in Spanish bank accounts
- Shares in Spanish companies and certain investments held in Spain
- Other Spanish assets and rights, including interests you own indirectly through a company or other entity
The wealth tax applies even if you own your assets through a structure, such as a company.
Not everything you own in Spain becomes a part of your tax bill. Spain exempts several categories of assets when specific conditions are met, such as:
- Business and professional activity assets
- Household goods and personal effects (this excludes items like jewelry, art, boats, and vehicles above set values)
- Pension rights
- The main home, up to 300,000 EUR, which applies to a habitual residence, so a non-resident's Spanish vacation home usually does not qualify²³
Debts can reduce your taxable base too, but the rules are stricter for non-residents.
A debt is only deductible when it relates to an asset that is located or taxable in Spain. A mortgage used to buy your Spanish property can normally be deducted from that property's value, as long as you can show the loan was actually used for the purchase.¹
A loan taken out later against the same property but spent on something else wouldn't qualify. A debt tied to an asset that is itself exempt can't be deducted either.
Joint ownership is calculated per person. If you own a Spanish property with someone else, each owner is assessed on their share, and each can apply their own personal allowance, which can make a big difference for couples.
Your assets and deductible debts are valued based on what you own on December 31st each year.¹
The tax-free allowance is 700,000 EUR per person under the state rules, which is the amount of your net Spanish wealth that isn't taxed at all. You need to pay tax on the value above that allowance, once you've applied any exemptions and deductible debts.¹
The filing threshold is separate, because a return can be required when your gross Spanish assets top 2 million EUR even if allowances bring your final bill to zero.⁴
"Gross" means the value of your assets before you subtract any debts. For example, someone with a 2.2 million EUR Spanish property and a 1.6 million EUR mortgage may owe little or nothing after the allowance, and still has to file.
The national government sets a default scale and the 700,000 EUR allowance, but regions can raise or lower the allowance, change the rates, or apply big discounts. For example, Madrid and Andalucía reduced the regional wealth tax to essentially zero.²
Wealth tax in Spain is progressive, so higher net wealth is taxed at higher rates.
The rate is applied to your taxable base, which is your net Spanish wealth after the 700,000 EUR allowance and any exemptions. The state scale, used by default and in regions without their own rates, ranges from 0.2% to 3.5%.²
| Taxable base above the allowance | Rate³ |
| Up to 167,129.45 EUR | 0.2% |
| 167,129.45 EUR to 334,252.88 EUR | 0.3% |
| EUR 334,252.88 to EUR 668,499.75 | 0.5% |
| EUR 668,499.75 to EUR 1,336,999.51 | 0.9% |
| EUR 1,336,999.51 to EUR 2,673,999.01 | 1.3% |
| EUR 2,673,999.01 to EUR 5,347,998.03 | 1.7% |
| EUR 5,347,998.03 to EUR 10,695,996.06 | 2.1% |
| Over EUR 10,695,996.06 | 3.5% |
Several regions set different rates, so confirm the scale for the region where your assets are located.
On top of this, the Solidarity Tax on Large Fortunes can apply when net wealth passes 3 million EUR. Its approximate rates are 1.7% on wealth between 3 million EUR and 5 million EUR, 2.1% between 5 million EUR and 10 million EUR, and 3.5% above 10 million EUR.²
You need to file a wealth tax return if either your calculation produces an amount to pay, or your gross Spanish assets are over 2 million EUR, whichever comes first.⁴
A return can be required even when your final liability is zero. If your Spanish assets are above 2 million EUR but debts and the 700,000 EUR allowance eliminate the bill, you still need to file. If your assets are below both the 700,000 EUR allowance and the 2 million EUR mark, you generally don't need to file.⁴
If your residency status is unclear, for example, if you split your year across countries, or if you think a tax treaty might change your position, get professional advice first.
Spanish wealth tax is filed on Modelo 714, submitted online through the Agencia Tributaria (the Spanish tax agency, or AEAT) portal.⁴
If the solidarity tax also applies to you, you need to use a separate form, Modelo 718.⁴
To file correctly, gather your asset valuations, debt documentation, and ownership records. As a non-resident, you'll need a Spanish tax identification number (an NIE) to file, and a fiscal representative is normally required if you don't have a permanent address in Spain.⁵
For the 2025 tax year, the filing window is from April 8th to June 30th, 2026, in line with the annual income tax season. Deadlines can shift by a day or two some years, so confirm the current dates before you file.⁴
You typically file and pay the Spanish wealth tax at the same time. The one exception is direct debit: if you pay that way, the deadline is earlier than the filing deadline.⁴
You can pay by direct debit from a Spanish or SEPA bank account, or by getting a payment reference from a collaborating bank and paying with that. If any of your assets or debts are in another currency, convert them to EUR using the exchange rate on December 31st, since the return is filed in EUR.
After you file, keep your return, valuations, mortgage and ownership documents, and proof of payment.
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If you're a US citizen or green card holder, you need to file US taxes on your worldwide income wherever you live. So it's fair to ask whether the US-Spain tax treaty or US rules change your Spanish wealth tax bill.
The short answer is that they mostly don't, but let's take a closer look.
Not in this case. The US-Spain tax treaty is an income tax treaty, so it covers taxes on income, not taxes on wealth. Spain's wealth tax is a tax on capital, and the treaty doesn't cover taxes on capital, so it doesn't reduce or remove what you owe on the Spanish side.
No. Paying Spanish wealth tax doesn't automatically earn you a US foreign tax credit. The US foreign tax credit is only for income taxes, or taxes paid in place of an income tax. A wealth tax is neither, so it generally doesn't qualify.⁶
No. As a general rule, foreign real estate that you own directly, in your own name, is usually not reported on its own on Form 8938 or an FBAR.
However, other assets connected to your Spanish property can be, including:
- Foreign bank accounts, such as a Spanish account you use for the property, which may be reportable on an FBAR
- Interests in foreign companies, partnerships, or trusts, which can bring their own US reporting forms
Each of these forms has its own thresholds and rules, and a US tax professional can tell you which forms, if any, apply to you.
Once you know what you owe, you still have to get the money to Spain.
Sending money abroad through a bank often costs you extra because banks tend to add a markup to the exchange rate on top of any transfer fee.
Eligible US customers may be able to use Wise to convert USD to EUR and send money for Spanish taxes or related property costs, using the mid-market exchange rate with fees shown upfront.
Before you rely on any payment method, confirm that the Spanish tax authority accepts that way of paying, and that the payment reference is entered exactly as required.
Spanish wealth tax applies to non-residents on the Spanish assets they own above the 700,000 EUR allowance, based on what you own on December 31st.¹ The state rates range from 0.2% to 3.5%, but your regional rate can be different.²
If you need to send money from the US to Spain, Wise can help you save on fees.
| Wise can help you get a better deal on currency conversion. You can convert over 40 currencies at the standard mid-market exchange rate, and we'll show you the fees upfront so you know exactly how much you're paying. |
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This publication is provided for general information purposes and does not constitute legal, tax or other professional advice from Wise Payments Limited or its subsidiaries and its affiliates, and it is not intended as a substitute for obtaining advice from a financial advisor or any other professional.
We make no representations, warranties or guarantees, whether expressed or implied, that the content in the publication is accurate, complete or up to date.
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