Most relocation advisors still pitch Andalucía as wealth-tax-free. They're half right, and the half they're wrong about costs a €15M-net-worth founder roughly €170,000 per year. The 100% bonificación on Impuesto sobre el Patrimonio is real and remains in force in 2026 — but it does nothing to shield you from the parallel state-level surcharge that Madrid bolted on in late 2022. That surcharge has its own threshold (€3M), its own scale (1.7%-3.5%), and its own cash-out date every July. Skipping it because your Andalucía paperwork looks clean is the most expensive mistake we see in HNW Marbella intake.
Spain operates two parallel wealth taxes in 2026:
1. Impuesto sobre el Patrimonio (IP) — the traditional regional wealth tax, regulated by Ley 19/1991 and ceded to the autonomous communities. Andalucía applies a 100% bonificación under Ley 5/2021 of the Junta de Andalucía, which means the regional tax due is zero regardless of net worth.
2. Impuesto Temporal de Solidaridad de las Grandes Fortunas (ISGF, "Solidaridad") — a state-level surcharge introduced by Ley 38/2022 of 27 December 2022, originally announced as temporary (2022-2023) and then extended indefinitely by Real Decreto-ley 8/2023 and confirmed in the 2024 General Budget. It applies to net worth above €3,000,000, charges 1.7% / 2.1% / 3.5% across three bands, and explicitly credits any regional Patrimonio actually paid — meaning Andalucía's 100% bonificación produces zero credit, so the full Solidaridad bill lands on the taxpayer.
Net result for an Andalusian-resident HNW: regional Patrimonio = €0; Solidaridad = full state liability above the €3M floor. For a €15M net worth this is roughly €170,000/year that most US, UK, and German advisors still tell their clients doesn't exist.
The mechanic is deliberately layered. The Spanish Constitutional Court upheld the Solidaridad architecture in STC 149/2023 (7 November 2023) precisely because the state designed it to pick up exactly where regions had bonificado away the regional tax. The court held that Madrid had legitimate constitutional authority to impose a state-level wealth tax that complements (rather than displaces) the ceded regional tax.
The credit mechanism in Solidaridad article 3.Eight reads: "the cuota effectively paid for Impuesto sobre el Patrimonio, after applying the corresponding regional bonifications and deductions, shall be deductible from the cuota of this tax." The phrase "after applying regional bonifications" is the keystone. If Andalucía's 100% bonificación reduces Patrimonio cuota to zero, the credit against Solidaridad is also zero.
The political logic is clear: the state designed Solidaridad to neutralise the inter-regional wealth-tax race. Regions that gave away the wealth tax now see Madrid recover the same revenue from the same taxpayers. Regions that kept Patrimonio see most of their taxpayers' wealth-tax bill go to the regional treasury rather than the state.