Tax consultant on the Costa del Sol — IRNR, Beckham Law, property and succession for international clients
The Costa del Sol — spanning Torremolinos, Fuengirola, Marbella, Estepona, Nerja, and the inland towns of Ronda and Antequera — has one of the most complex fiscal profiles in Spain. A dense international property market, a large community of non-resident owners, a growing population of high-net-worth residents from across Europe, and the interaction of Spanish national law with Andalucía's regional rules and dozens of double tax treaties creates a landscape that most standard accounting firms cannot navigate with genuine expertise. The non-resident owner of a Fuengirola apartment renting through digital platforms needs not just the Modelo 210 filing but also an understanding of the applicable double tax treaty, Andalucía's tourist rental registration rules, and potential VAT obligations depending on the services offered. The executive relocated to Marbella working for a German company needs to evaluate the Beckham Law regime, understand how their stock options are taxed, and know what happens to their German private pension. The non-resident buyer of a villa in La Zagaleta needs pre-acquisition advice on the optimal holding structure, the Andalucía ITP rate, and the ongoing obligations as a non-resident owner. None of these profiles fit the standard catalogue of a general-purpose firm.
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Specialised advice and personal service
BMC advises businesses, professionals, and individuals with interests across the Costa del Sol from its Málaga office, with the capacity to handle everything from routine tax compliance for a local freelancer to complex multi-jurisdiction acquisition structures for international investors. BMC's team commands the Andalucía regional framework — ISD, ITP, and Patrimonio exemptions — and the double tax treaties with the main source countries of Costa del Sol residents: the UK, Germany, the Netherlands, France, Belgium, and the Nordic countries. We advise in English and Spanish, with French and German availability on request.
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The Costa del Sol has one of Spain's most complex fiscal profiles
high-value property market, dense international community, and Andalucía's specific regional rules all interact.
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Non-resident property owners on the Costa del Sol pay IRNR at 19% (EU/EEA) or 24% (non-EU/EEA), with possible treaty reductions managed by BMC through Modelo 210 filings.
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Holiday rental in Andalucía requires Junta de Andalucía registration and has different tax treatment depending on whether hotel-style services are provided.
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The Beckham Law allows international professionals relocating to the Costa del Sol to pay a flat 24% rate for up to six years — application must be made within six months.
From first contact to case completion
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The problem
The Costa del Sol — spanning Torremolinos, Fuengirola, Marbella, Estepona, Nerja, and the inland towns of Ronda and Antequera — has one of the most complex fiscal profiles in Spain. A dense international property market, a large community of non-resident owners, a growing population of high-net-worth residents from across Europe, and the interaction of Spanish national law with Andalucía's regional rules and dozens of double tax treaties creates a landscape that most standard accounting firms cannot navigate with genuine expertise. The non-resident owner of a Fuengirola apartment renting through digital platforms needs not just the Modelo 210 filing but also an understanding of the applicable double tax treaty, Andalucía's tourist rental registration rules, and potential VAT obligations depending on the services offered. The executive relocated to Marbella working for a German company needs to evaluate the Beckham Law regime, understand how their stock options are taxed, and know what happens to their German private pension. The non-resident buyer of a villa in La Zagaleta needs pre-acquisition advice on the optimal holding structure, the Andalucía ITP rate, and the ongoing obligations as a non-resident owner. None of these profiles fit the standard catalogue of a general-purpose firm.
Our solution
BMC advises businesses, professionals, and individuals with interests across the Costa del Sol from its Málaga office, with the capacity to handle everything from routine tax compliance for a local freelancer to complex multi-jurisdiction acquisition structures for international investors. BMC's team commands the Andalucía regional framework — ISD, ITP, and Patrimonio exemptions — and the double tax treaties with the main source countries of Costa del Sol residents: the UK, Germany, the Netherlands, France, Belgium, and the Nordic countries. We advise in English and Spanish, with French and German availability on request.
How we do it
Profile assessment and objective setting
We begin by understanding your situation: resident or non-resident in Spain, property owner, employee or entrepreneur, with assets in multiple countries or only in Spain. That initial conversation, at no charge, lets us confirm exactly which services you need and identify the most relevant BMC adviser for your profile.
Compliance review and contingency audit
We audit your current tax position: outstanding model filings, any prior years' IRNR returns, Modelo 720 if applicable, and any pending notifications from the AEAT or the Junta de Andalucía. Where contingencies exist, we quantify them and define the regularisation strategy before they escalate.
Periodic tax management
We take over all periodic obligations: VAT, IRPF, IRNR, corporate tax, withholdings, and annual informative returns. For non-resident property owners, we manage the Modelo 210 quarterly or annually as required and notify you ahead of each deadline with the calculated amount for approval before submission.
Wealth and succession planning
Beyond compliance, we advise on how to hold and transfer Costa del Sol property in the most tax-efficient way — direct personal ownership, a Spanish SL, or an international structure — considering Patrimonio exposure, inheritance tax, and future capital gains. For each client, we prepare a medium-term tax roadmap covering the decisions that matter most.
The Costa del Sol: high fiscal complexity in a unique environment
The Costa del Sol stretches over 160 kilometres of coastline between Nerja and Manilva, encompassing municipalities as varied as Torremolinos, Fuengirola, Marbella, Benahavís, Estepona, and Sotogrande. What unites them from a tax perspective is the high concentration of international property owners and investors, a permanently active real estate market, and the presence of high-income international profiles who need sophisticated advice, not standard compliance.
The Costa del Sol does not attract only European retirees. Marbella and the Golden Triangle have built a stable resident population of asset managers, second- and third-generation entrepreneurs, tech founders, and multinational executives over the last decade. That profile has tax needs that go far beyond filing Modelo 210: it requires wealth planning, holding structure analysis, double tax treaty management, and coordination with advisers in other countries.
Non-resident tax on the Costa del Sol: what you need to know
The most common obligation among non-residents with property on the Costa del Sol is filing the Modelo 210 IRNR return. If the property is rented, the filing is quarterly; if it is not rented and used as a second home, the filing is annual for deemed rental income (1.1% or 2% of the rateable value depending on whether that value has been recently revised).
The applicable rate depends on the owner’s country of residence: 19% for EU or EEA residents — who can also deduct directly connected expenses — and 24% for others, with no expense deduction available unless a double tax treaty with the country of residence provides otherwise. BMC applies the most favourable treaty position in each case and manages the Modelo 210 filings with the AEAT.
The Costa del Sol property market and conveyancing tax
The Costa del Sol is one of the most active markets for international buyers in Western Europe. That activity generates significant tax obligations for both buyer and seller.
For the non-resident buyer, the choice of holding structure — individual purchase, Spanish SL, or foreign vehicle — has long-term tax implications that need to be analysed before contracts are signed. The Andalucía ITP applies on a sliding scale based on property value, with reduced rates available in certain circumstances. For the non-resident seller, a 3% retention is required from the sale price as a withholding against the IRNR due on the capital gain — and a refund is available if the actual tax liability is lower. BMC advises both buyers and sellers and manages the 3% retention refund process where applicable.
Succession planning for Costa del Sol property owners
A significant proportion of international property owners on the Costa del Sol have not planned what will happen to their property when they die. The typical scenario — heirs resident in another country, property in Andalucía, ISD filing with the Junta de Andalucía — can be managed very efficiently with adequate planning in advance.
Andalucía applies significant bonuses in ISD for transfers between close relatives, which in many cases eliminate or drastically reduce the liability. Planning the holding structure in advance — which may include incorporation, a lifetime gift, or use of a life interest — can reduce the succession tax burden substantially. BMC advises on these options with the time needed for considered decisions, not under the pressure that comes with a bereavement.
BMC has an office in Málaga. See our Málaga office for in-person appointments serving the entire Costa del Sol.
What comes next
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Comprehensive tax planning
Optimise your tax burden with a complete tax strategy: personal income tax, corporate tax, international taxation, and special territories.
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Corporate advisory
From incorporation to sale: we accompany entrepreneurs at every stage of the business lifecycle.
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Comprehensive legal advisory
Commercial law, employment law, compliance, and data protection: a multidisciplinary legal team to cover all your business needs.
Frequently asked questions
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