How Foreign Pensions Are Taxed in Spain

The basic rule

Spain taxes residents on their worldwide income, including foreign pensions. You become tax resident the year you spend more than 183 days in Spain or your centre of economic interest moves here. Once resident, you file an annual Modelo 100 (the Spanish income tax return) declaring all global income.

Double-tax treaties prevent you from paying twice. The treaty between Spain and your home country decides which side has primary taxing rights for each type of pension — and Spain gives you a credit for any tax already paid abroad.

How the brackets work in 2026 (state + Valencia regional)

United Kingdom

Under the UK–Spain Double Tax Treaty (2014), the rule depends on the type of UK pension.

Netherlands & Belgium

Both treaties give Spain primary taxing rights over private pensions and AOW/Belgian state pension. Civil service pensions (ambtenarenpensioen) remain taxable at source. The Netherlands treaty was renegotiated in 2025 — large lump-sum withdrawals from a Dutch pension may now be taxed in the Netherlands rather than Spain.

Germany & France

The Germany–Spain treaty taxes private Rente in Spain and civil service Rente in Germany. France's treaty splits similarly: private pensions to Spain, civil service to France. Both countries already share tax data with Spain under the EU's DAC framework, so under-declaration is detected automatically.

United States

The US–Spain treaty assigns private pensions (401(k), IRA, private annuities) to Spain. US Social Security is taxable in Spain — but the US retains the right to tax it as well (it's exempt from the saving clause for residents who are not US citizens, but Americans remain liable under citizenship-based taxation). FATCA reporting still applies; expect to file both Modelo 720 in Spain and FBAR in the US.

Canada, Australia, Ireland & others

• ✦Canada — private pensions and CPP/OAS taxable in Spain; some government pensions remain in Canada
• ✦Australia — Spain has a treaty but no totalisation agreement; Aussie super is treated as a foreign pension and taxed in Spain on the income drawn
• ✦Ireland — private pensions and state pension taxed in Spain; civil service pensions remain in Ireland
• ✦Norway, Sweden, Denmark, Finland — pensions generally taxed in Spain, with the Nordic country giving a credit

Modelo 720 — declaring foreign assets

Every Spanish tax resident with overseas assets totalling more than €50,000 in any of three categories (bank accounts, securities/funds, property) must file Modelo 720 by 31 March each year. Foreign pension pots in defined-contribution wrappers (SIPP, 401k) historically had to be reported; the rules tightened then partly relaxed after the EU Court ruled Spain's original penalties illegal. Take advice — penalties for getting Modelo 720 wrong remain significant.