Another of the queries that we deal with the most in our office is related to the Temporary Solidarity Tax on Large Fortunes (ITSGF) in relation to non-residents in Spain. The tax on large non-resident fortunes, for short 😀. A state tax, which was designed to be temporary (in principle for the years 2023 and 2024) but is still in force.
It is a tax that complements the Wealth Tax (IP) and whose objective is none other than to tax the wealth of individuals with high net worth (net worth when this is greater than €3,000,000) in order to reinforce tax equity (the tax will be due on 31 December of each year and will affect the net worth of the taxpayer on that date).
As a team of advisors specialised in resident and non-resident foreigners that we are at JDV Asesores for Expats and foreign self-employed, we explain in detail everything related to this tax that certain non-resident taxpayers have to pay annually.
Non-resident wealth tax: Taxable persons
Individuals who are not resident in Spain are subject to the ITSGF by real obligation, i.e. only for the assets and rights they own and which are located, can be exercised or must be fulfilled in Spanish territory.
This means that the ITSGF for non-residents focuses on their wealth located in Spain, regardless of their global wealth. This is an aspect that creates confusion for foreign taxpayers and non-residents that we need to clarify very well.
When we refer to the assets taxed by the ITSGF of non-resident taxpayers, we refer, among others, to:
- Real estate located in Spain.
- Rights in rem over real estate located in Spain (usufruct, bare ownership, etc.).
- Deposits in bank accounts in Spanish entities.
- Transferable securities issued by Spanish entities or deposited in Spain.
- Shares in Spanish investment funds.
- Life insurance taken out with Spanish insurance companies.
- Works of art, antiques and jewellery located in Spain.
- Vehicles, boats and aircraft registered or recorded in Spain.
- Intellectual or industrial property rights registered in Spain.
Taxable and taxable income
The taxable base of the non-resident tax on large fortunes is determined by the net value of the assets and rights located in Spain, i.e. the market value minus the charges and debts that are directly taxable and deductible.
In order to calculate the taxable base, a state reduction of 700,000 € is applied to the taxable base. It is important to note that, unlike the Wealth Tax, the exemption of the main residence for non-residents of the ITSGF does not apply.
Tax rates
The scale of taxation of non-resident wealth tax is progressive and state-wide. For 2025, it is as follows:
Taxable Base (euros) Tax Rate (%)
Up to 3.000.000,000,00 0,00
From 3.000.000,000,01 to 5.347.998,03 1,70
From 5.347.998,04 to 10.695.996,06 2,10
More than 10,695,996.06 3.50
Tax liability
The tax liability is obtained by applying the tax rates of the scale to the taxable base.
Particularities for Non-Residents
Non-residents are obliged to file the ITSGF return (Form 714) if their tax liability is payable or if the value of their assets and rights located in Spain exceeds 3,700,000 €, even if the liability is zero. This threshold is different from the Wealth Tax threshold for non-residents (2,000,000 €).
Generally, non-residents do not benefit from the regional bonuses or exemptions from Wealth Tax in the ITSGF. This is especially relevant in communities such as the Community of Madrid, which grants 100% relief on the IP. If a non-resident has assets in Madrid in excess of 3,700,000 €, he/she will be subject to the non-resident wealth tax although he/she would not pay IP in that region.
We must carefully check whether there is a Double Taxation Agreement (DTA) between Spain and the taxpayer’s country of residence. Some DTAs may limit Spain’s power to tax certain assets or rights.
Finally, in some cases, the tax authorities may require non-residents with assets in Spain to appoint a tax representative in Spain.
Non-resident wealth tax: Relationship with wealth tax
The ITSGF and the wealth tax are different taxes, although they are levied on the same taxable base (net wealth). The ITSGF was created with the intention of taxing those taxpayers with large estates who, due to the regional bonuses of the IP, especially that of the Community of Madrid, did not pay this tax.
For non-residents, both taxes may be applicable on their assets located in Spain, although with their own rules and thresholds.
Conclusions
We know, therefore, that the tax on large fortunes for non-residents in Spain is a state tax on their net wealth located in Spanish territory that exceeds 3,700,000 €, with a progressive scale of taxation and without the application of the exemption of the main residence or, generally, the regional bonuses of the Wealth Tax.
With the help of advisors specialised in taxes for non-residents such as JDV Asesores for Expats and foreign self-employed, all non-resident taxpayers with assets in Spain will have their particular and fiscal situation well analysed. Firstly, it is necessary to understand the obligations that they have as non-residents and then to optimise their tax situation in relation to this tax for large non-resident fortunes.
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