Brussels formally challenges Spain over property tax on non-residents
On June 18, 2025, the European Commission announced it had opened a formal infringement procedure against Spain. The issue concerns a special tax applied to non-residents who own property in Spain. According to Brussels, Spain taxes these foreign owners unfairly by charging them personal income tax (under the non-resident income tax regime, IRNR) on a “theoretical rental income”, even when their properties are unused. The tax is set at 2% of the property’s cadastral value, reduced to 1.1% if the property’s value has been updated recently.