Andalusia gives 100% relief on wealth tax (Article 25 bis of Ley 5/2021). While the state Temporary Solidarity Tax on Large Fortunes (ITSGF) is in force, that relief is limited to the difference between the two bills, so above the threshold the taxpayer pays what the solidarity tax would charge. The solidarity tax was created by Ley 38/2022 of 27 December 2022, first charged for 2022, and extended by Real Decreto-ley 8/2023 until wealth taxation is reviewed — temporary in name only. 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
Non-residents have the same €700,000 allowance and are assessed on their Spanish assets only (Article 28.Tres of Ley 19/1991). 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.
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
Nothing is due while net wealth after the €700,000 allowance stays within €3,000,000; above that the scale is 1.7% to €5,347,998.03, 2.1% to €10,695,996.06 and 3.5% beyond (Article 3 of Ley 38/2022). It is the upper band that produces meaningful annual numbers.
A worked case. On €5,000,000 of net Spanish assets with no debt: €5,000,000 − €700,000 = €4,300,000; the first €3,000,000 at 0% and the next €1,300,000 at 1.7% — €22,100 a year. 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 ceded to the regions, and Andalusia's 100% relief on it is real. But while the state solidarity tax is in force, that relief is limited to the difference between the two bills, so above the threshold the taxpayer pays what the solidarity tax would charge. The scale applied is therefore the solidarity tax's, after the €700,000 allowance.
The practical effect: Andalucía's bonification does not shield buyers from all annual wealth tax. Above the threshold the bill is what the solidarity tax would charge; below it, nothing is due. Buyers who structured their holdings on the assumption of a permanent zero should revisit their position.
Off-market holdings and disclosure
One aspect that sometimes surprises buyers is the filing obligation. A wealth-tax return is due if tax is payable or the assets exceed €2,000,000 (Article 37 of Ley 19/1991), so a return can be owed with nothing to pay. Modelo 720 is a different matter: it is an information return on assets held abroad, filed by Spanish tax residents; a non-resident owner does not file it.
For buyers acquiring off-market — a route carrying a large but unmeasurable share of the upper Marbella register, since Spain publishes no completions from which a share could be calculated — 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
Current asking prices by zone, each with its sample size and date, are on the Marbella Property Index (museselection.es/marbella-property-index); no rate of appreciation can be set beside them, because Spain publishes no closing prices from which one could be built. These are not markets where buyers optimise primarily around an annual wealth-tax bill. But the buyers who hold well 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 above the threshold it does not resolve 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.