For several years, Andalucía's 100% regional bonification made Patrimonio a theoretical imposition for most Marbella buyers. You owned a €5 million villa on the Golden Mile, you filed, and the liability was zero. That position was deliberately unwound in 2022 when Madrid introduced the Impuesto Temporal de Solidaridad de las Grandes Fortunas — the solidarity surcharge — specifically to neutralise regional exemptions like Andalucía's. Temporary in name; it has since been extended. In 2026, non-resident buyers with Spanish assets above the threshold are paying something real, and the structure in which they hold property affects how much.
What Patrimonio actually taxes
Impuesto sobre el Patrimonio is an annual wealth tax on net assets. For non-residents, scope is limited to Spanish-situs assets: real estate in Spain, bank accounts held at Spanish institutions, shareholdings in Spanish companies, and certain other domestically located holdings. Assets held outside Spain — a London property, a Swiss portfolio, a Cayman structure — fall entirely outside the base. This territorial limitation is why the tax matters less to some buyers than an initial read suggests, and more to others whose principal wealth happens to be in Spain.
Real estate is valued at the highest of three figures: the cadastral value, the value used for the acquisition (escritura price), or the assessed value determined by the tax authority. In practice, for recently purchased high-value property, the acquisition price usually controls. A buyer who paid €8 million for a Sierra Blanca villa in 2024 and holds it personally will, broadly, start with €8 million as their asset value before deductions.
The allowances, and how they stack
The general personal allowance for non-residents filing Patrimonio is approximately €700,000. A further €300,000 is available against a primary residence, though non-residents — by definition — rarely qualify for that second relief unless Spain is genuinely their principal domicile. For most non-resident buyers, the effective threshold before any liability arises is €700,000 of Spanish-situs net assets.
Mortgages and liabilities secured against Spanish property reduce the taxable base, which is worth noting. A €10 million property with a €4 million mortgage outstanding produces a net taxable base of €6 million, not €10 million. Buyers who finance acquisitions partly for this reason are not doing anything exotic; it is simply how the base works.
The rate structure
The marginal rate schedule ascends in tranches, broadly from 0.2% on the first tranche above the allowance to 3.5% on assets above approximately €10.7 million of taxable base. The lower tranches — assets between roughly €700,000 and €2 million — attract rates between 0.2% and 0.5%. It is the upper band that produces meaningful annual numbers. A net taxable base of €12 million, after allowance, carries a blended effective rate that is typically below 2% but still represents a six-figure annual obligation.
For context: on a €5 million primary holding with no mortgage and no other Spanish assets, the taxable base after the general allowance is roughly €4.3 million. At blended rates across the tranches, the annual Patrimonio exposure sits in the region of €25,000–€35,000. That is not a reason to walk away from a Marbella acquisition. It is a line in the holding-cost model that should be there from the outset.
Corporate ownership: the structural question
The most common question we encounter from buyers above €3 million is whether holding through a corporate vehicle — typically a Spanish SL, a Luxembourg SOPARFI, or a UK company pre- or post-restructuring — eliminates Patrimonio exposure. The short answer is that it reframes rather than removes it.
A non-resident individual owning shares in a non-resident company that holds Spanish real estate is, under Spanish rules, treated as holding the underlying Spanish asset directly for Patrimonio purposes if the company's assets consist principally of real estate in Spain. The look-through provisions were tightened precisely to prevent straightforward corporate interposition from nullifying the tax. The solidarity surcharge further tightened the state-level position to ensure that regional exemptions and certain structural arrangements did not produce a zero outcome for large holdings.
Corporate vehicles can still serve legitimate purposes — succession planning, privacy, liability compartmentalisation, multi-owner structures — and they interact differently with inheritance and gift tax, with rental income treatment, and with future disposal gains. But a buyer who is acquiring a €10 million La Zagaleta property expecting that a Luxembourg holding company eliminates Spanish annual wealth tax will need to revisit that assumption with a cross-border specialist before completion.
We are not your tax adviser. This sets out the contour; specifics need a cross-border specialist.
The solidarity surcharge and the Andalucía position
It is worth being clear about the layering. Patrimonio is a state tax with regional administration. Andalucía retains its 100% bonification at the regional level — meaning regional Patrimonio remains zero in Andalucía. But the ITSGF solidarity surcharge operates at the state level and applies precisely where regional bonifications would otherwise produce a zero outcome. The solidarity surcharge is calculated on the same base and rate schedule as Patrimonio, and any regional relief is credited against it rather than extinguishing it.
The practical effect: Andalucía's bonification no longer shields buyers from all annual wealth tax. For holdings where the calculated Patrimonio would have been zero due to the regional exemption, the solidarity surcharge steps in and produces a broadly equivalent liability. Buyers who structured their holdings in 2019 or 2020 on the assumption of a permanent Andalucía zero-rate should revisit their position.
Off-market holdings and disclosure
One aspect that sometimes surprises buyers is the disclosure obligation. Non-residents holding Spanish real estate are required to file Patrimonio even where the calculated liability is zero — and separately, under Modelo 720, to declare foreign assets above certain thresholds. These are distinct filings with distinct deadlines. Non-compliance carries disproportionate penalties relative to the underlying tax, which is a quirk of the Spanish system worth understanding early.
For buyers acquiring off-market — and across the upper Marbella register, off-market transactions have risen from around 30% of trades in 2018 to approximately 48% in 2025 — the structure of the transaction has no bearing on the compliance obligation. An off-market acquisition at €7 million carries the same annual filing requirement as a publicly listed one. The discretion is in the transaction; the tax position is determined by ownership.
Holding costs in context
The Golden Mile currently trades at around €11,200 per square metre, up 8% year on year. La Zagaleta sits at approximately €14,800 per square metre, up 11%. These are not markets where buyers are optimising primarily around an annual 0.5–2% wealth tax. But the buyers who hold well — and on the Golden Mile, average hold tenure runs to fourteen years — are the ones who modelled the full cost of ownership before acquisition rather than after.
Patrimonio, IBI (local property tax), community fees, income tax on imputed rental income for non-residents, and eventual capital gains tax on disposal each occupy their own column. The annual wealth tax is one of them, and since 2022 it is no longer the one that resolves to zero. Understanding [how the full Spanish property tax stack works in 2026](/guides/spanish-property-tax-2026) is, in our experience, the most useful preparation a buyer can make before committing to a structure.
The buyers who encounter a surprise on this are rarely the ones who asked the question too early.