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A Spanish national, not a US citizen, who moved to the US in 2024 receives a Spanish public pension. The DGT determines that tax jurisdiction lies solely with Spain under CDI Spain-US Article 21.2.a), unless she acquires US nationality or immigrant status. As a non-resident in Spain, she is taxed under the pension-specific IRNR scale in Article 25.1.b) TRLIRNR, with no option to opt for IRPF due to non-residency in the EU or EEE.
Question raised
According to the Spain-US Convention, pensions paid by a State to a natural person for services rendered may only be taxed in that State, unless the beneficiary is a resident and national of the other State. If the inquirer is not a US national, the pension will be taxed in Spain under the Non-Resident Income Tax (IRNR). They may not opt for Personal Income Tax (IRPF) due to residing in the US, and the US authority to tax would only be activated if the person acquires nationality or immigrant status.
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