By Victor Gersten, EA, CFP®, MS, MPAS™
Quick answer
Spanish tax residency generally starts once you spend more than 183 days in Spain in a calendar year, and it is measured for the whole calendar year, not from your arrival date. Several of the most useful planning moves, such as Roth conversions, realizing capital gains, and cleaning up your investments, are usually easier to do before Spanish residency begins. This checklist walks through what to think about, and when.
Where are you in your move?
What best describes you?
Most of the Americans we talk to start planning too late. The moves that can save the most tax tend to have the longest lead time. Use the timeline below as a conversation starter with your own advisers, not as a substitute for advice on your situation.
YOUR MOVE TO SPAIN
12 months, five milestones
State, trusts and entities
Roth and capital gains
Accounts and funds
Money, visa and health cover
Arrival and first filings
TIMING MATTERS
Spanish residency covers the whole calendar year
If you spend more than 183 days in Spain, the full year can be treated as Spanish tax residency. That is why planning moves are usually made in the year before you arrive.
12 months before: state taxes, trusts and entities
- Leaving a US state. Some states, such as California, New York and Virginia, look closely at whether you really broke residency. Document where you live, vote, bank and keep your belongings. We do not advise on state taxes, so confirm the details with a state tax professional.
- Living trusts. A US revocable living trust may not be recognized the way you expect under Spanish civil law. Ask an estate attorney who understands both systems to review it before you move.
- Business owners. Review how your US entity (LLC, S corporation or other) will be treated in Spain, and whether a Spanish self-employed registration or a special regime could apply to you.
Read more: Leaving California for Spain, Your US estate plan and Spain, The Beckham Law in 2026, Working remotely from Spain.
9 months before: Roth conversions and capital gains
- Roth conversions. Before you become a Spanish tax resident, a conversion is generally taxed only by the US. After, Spain may tax it as well. Whether a conversion makes sense depends on your bracket, your timing and your plans.
- Unrealized gains. Look at the gains in your taxable brokerage accounts. Selling before residency can change which country taxes the gain.
- Spanish wealth tax. Your worldwide assets, including US IRAs and Roths, can count toward Spain’s wealth tax and the Modelo 720 asset declaration. Rules vary by region, so find out which region you will live in.
Read more: The Roth IRA in Spain, Which retirement account to draw first, The US Spain tax treaty explained, Modelo 720 explained.
Want to talk this through with someone who does it every day?
6 months before: accounts and investments
- Where your accounts are held. Some US brokerages restrict or close accounts when a customer’s address moves abroad. Ask each institution what its policy is, and have a plan before you change your address.
- Your funds. European funds (UCITS) are often treated as PFICs for US tax purposes and are painful to report on Form 8621. Review what you own and what you plan to buy.
Read more: Why US brokerages are closing expat accounts, The PFIC trap, Investing in retirement from Europe in 7 steps.
3 months before: visa, banking and health insurance
- Moving money. Plan how and when you will move dollars to euros, and compare exchange costs.
- Health insurance. Your visa will have specific insurance requirements. Review how Medicare Part B works if you live abroad, including the cost of dropping it versus the late enrollment penalty if you return.
- Paperwork. Gather the documents your visa and registration will need.
Read more: Should you keep Medicare while living abroad?, Five questions to answer before you move abroad, Should I buy or rent when I move abroad?, The costs of buying a home in Spain.
Arrival through the first 3 months: registrations and first filings
- Registrations. Obtain your NIE and residency card (TIE) and register at your local town hall (padrón).
- Modelo 720. If you are a Spanish tax resident and your foreign assets are worth more than €50,000 in any one category (bank accounts, securities and similar, or real estate), you file this declaration by March 31 of the following year. After the first filing, you generally refile only if a category grows by more than €20,000 or an asset is sold or closed.
- Two returns. You will generally still file a US Form 1040 and also a Spanish return (Modelo 100). Coordinate the foreign tax credit or the foreign earned income exclusion with the Spanish return so income is not taxed twice more than necessary.
AFTER YOU ARRIVE
Two countries, two returns, one plan
United States
Form 1040
Foreign tax credit or FEIE
Spain
Modelo 100 return
Modelo 720 asset declaration
Read more: FEIE or foreign tax credit, Your first year as an American in Spain, The US Spain totalization agreement and Social Security.
An example journey: arriving in Spain on July 10
Suppose you arrive on July 10 of Year 1. From July 10 through December 31 is 175 days, which is under the 183 day mark. In that case you would generally not be a Spanish tax resident in Year 1, and Year 2 would be your first year as a Spanish tax resident. Here is how the filings usually line up.
EXAMPLE: ARRIVAL ON JULY 10
Three years, three sets of deadlines
Year 1: you move
Arrive July 10 (175 days in Spain). Generally a US only tax year. Your last year of US only filing.
Year 2: first year as a Spanish resident
January 1 to December 31 counts as Spanish residency. You are now a tax resident of Spain and still a US taxpayer.
Year 3: first Spanish filings
You file the Year 2 Spanish return and the Modelo 720 for the first time.
| When | What happens |
|---|---|
| Year 1, before July 10 | The last window for moves that are easier before Spanish residency: Roth conversions, selling gains, account clean up, breaking state residency |
| Year 1, July 10 | You arrive. Register, get your NIE and TIE, and keep a record of your days in Spain |
| April 15, Year 2 | US return for Year 1 is due, with an automatic extension to June 15 for Americans living abroad. Any tax owed is still due April 15 |
| Year 2, all year | First year as a Spanish tax resident. Worldwide income is reportable in Spain, and your assets on December 31 count for wealth tax and the Modelo 720 |
| March 31, Year 3 | First Modelo 720, if your foreign assets exceed €50,000 in any category |
| April 15, Year 3 | US return for Year 2 is due, with the same automatic extension to June 15 |
| June 30, Year 3 | Spanish income tax return (Modelo 100) for Year 2 is due. The Spanish filing season opens in April |
Important points:
- You keep filing in the US. As a US citizen you file a US return every year, wherever you live. What changes after Year 1 is that you also file in Spain.
- The extra two months. Americans whose tax home is abroad on April 15 get an automatic extension to June 15 to file. Interest still runs from April 15 on any tax owed, and Form 4868 can extend the filing date further, to October 15.
- The 183 day count is close. 175 days leaves little room. Days you spend in Spain before July 10 can add to the count, and temporary trips outside Spain after you arrive generally still count as days in Spain unless you can prove you are a tax resident elsewhere. Spain can also treat you as a resident because of where your spouse and minor children live or where your main economic interests are. Have a Spanish tax professional confirm your first year.
| When | Main topic |
|---|---|
| 12 months before | State residency, trusts, entities |
| 9 months before | Roth conversions, capital gains, wealth tax |
| 6 months before | Account access, fund review |
| 3 months before | Money transfers, health insurance, visa papers |
| Arrival to month 3 | NIE, TIE, padrón, Modelo 720, two tax returns |
Where to go from here
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Results are for illustrative purposes and do not constitute legal or tax advice, or an offer of advisory services until a formal client agreement is executed. Specific regional calculations depend on individual wealth composition and deductions. Described in our Form ADV Part 2A. This page is general education only.