A recent amendment to Form 718, published in the Official State Gazette (BOE) on 29 June 2026, introduces a significant change to the Temporary Solidarity Tax on Large Fortunes (ITSGF) which may directly affect those liable for this tax, particularly non-residents with assets in Spain.
What has changed
Until now, the limit designed to prevent excessive combined taxation under the Income Tax, Wealth Tax and Tax on Large Fortunes schemes applied only to Spanish residents. Non-residents liable for tax on their assets were excluded from this limit and, in many cases, paid a higher tax liability.
In two rulings handed down in late 2025, the Supreme Court held that this difference in treatment between residents and non-residents was discriminatory and unjustified. This ruling has been extended to the Tax on Large Fortunes, and the Tax Agency has amended the tax return form accordingly.
As a result, from the tax return for the 2025 tax year onwards, all taxpayers, regardless of whether they are resident or non-resident in Spain, may apply the combined limit which prevents the sum of the Income Tax, Wealth Tax and Tax on Large Fortunes liabilities from exceeding 60 per cent of the taxpayer’s income tax base.
Who is affected
This amendment to the ITSGF has a direct impact on:
- Taxpayers (individuals) with a net worth exceeding €3,000,000 who are subject to the Tax on Large Fortunes.
- In particular, non-resident individuals who are taxed in Spain on their assets located here (actual liability) and who, until now, were unable to benefit from this limit.
An example to illustrate this
The figures are illustrative and serve solely to show how the limit works.
A non-resident with an ITSGF liability of €60,000 and a taxable income of €50,000. The combined limit works as follows:
| Item | Before | Now |
| Large Fortunes Tax | €60,000 | €60,000 |
| Applicable limit (did not apply to non-residents) | No | Yes |
| Final amount payable | €60,000 | €20,000 |
In this scenario, the saving amounts to €40,000. The actual effect depends on the composition of each taxpayer’s assets and income, so it is advisable to analyse each case individually.
Deadlines
The ITSGF return for the 2025 tax year must be filed between 1 and 31 July 2026. If payment is set up by direct debit, the return must be filed by 26 July, with the account debited on 31 July.
And previous years
If, in previous tax years, you paid this tax without claiming the non-resident allowance, you may be able to claim a refund of any overpayment, provided the claim is not time-barred. It is worth looking into this option.
Do you think this change might affect you?
At Emede ETL Global, we analyse your specific situation, calculate the impact of the limit on this year’s tax return and assess whether you are eligible to claim a refund for previous tax years.
Contact us and we will help you determine how this affects you.
