The question arrives with some regularity at both of our Marbella offices. A Russian national — sometimes resident in Dubai, sometimes in Cyprus, occasionally still in Moscow — wants to understand what acquiring a property on the Costa del Sol actually costs, in full, once the purchase price is agreed. The tax architecture, they usually discover, has not changed dramatically. What has changed is the scaffolding around it: the banking channels, the compliance burden, the time required to move money in a way that a Spanish notary will accept without reservation.
This piece addresses that full picture as it stands entering 2026. It is not legal advice. It is an account of what we observe, what clients are navigating, and where the friction actually sits.
The Tax Framework Itself Has Not Changed
Spain does not apply differential tax treatment based on a buyer's nationality. A Russian citizen purchasing a resale property in Marbella faces the same Impuesto sobre Transmisiones Patrimoniales — the transfer tax — as a German or British buyer. On the Costa del Sol, within Andalusia, this sits at 7% of the price, or of the Catastro's reference value if that is higher. New-build purchases attract IVA at 10% instead, plus Actos Jurídicos Documentados at 1.2% of the deed value.
Notary and land-registry fees are statutory tariffs (Real Decreto 1426/1989 and Real Decreto 1427/1989), not percentages of the price. On a €2,000,000 resale the acquisition costs come to about €163,170 (8.2%) in the worked examples of our guide to Marbella property purchase costs (museselection.es/marbella-buying-costs-guide) — notary and land registry as estimated invoices, lawyer at 0.75% plus IVA. Only the tax is fixed by law; the other lines are estimates. This arithmetic is the same regardless of passport.
Once owned, the annual holding costs follow the same logic. IBI is the cadastral value multiplied by the municipal rate, which the law allows between 0.4% and 1.10% for urban property (Article 72.1 of the Haciendas Locales law). The bill for a specific house is on its last receipt — ask the seller for it.
Non-residents who do not rent the property still owe Impuesto sobre la Renta de No Residentes on a deemed income. For 2026, a non-resident individual who does not let the property is taxed on a deemed income of 1.1% or 2% of the cadastral value, depending on when that value was last revised; the rate is 19% for EU/EEA residents and 24% for others. It applies to individuals, not companies. A Russian national resident outside the EU and EEA pays the 24% rate on that base. In practice this produces a modest annual figure, but it is an obligation that requires a Spanish tax identification number and annual filing, neither of which can be deferred indefinitely.
The NIE and What It Requires Now
The Número de Identificación de Extranjero remains the entry point. Without it, no notarial deed can be signed, no property registered, no Spanish bank account opened. Russian nationals can still obtain an NIE. The process runs through the Spanish consular network or, if the buyer is present in Spain, through the Oficina de Extranjeros.
What has changed since 2022 is the documentary scrutiny applied along the way. Consular appointments in some jurisdictions have longer lead times. Proof of legal residency in a third country is increasingly requested as context. None of this is a legal barrier, but it is a procedural one that adds weeks to a transaction timeline if not anticipated.
A tax representative — a Spanish-resident individual or entity formally appointed to handle filings on behalf of the non-resident owner — is also required by law for non-EU buyers. This is a standing obligation, not a one-time appointment, and the representative assumes joint liability for tax debts, which means finding a Spanish gestoría or law firm willing to take on that role has its own due diligence component.
Banking and Fund Flows: Where the Friction Is
This is where 2026 diverges most sharply from 2021. The purchase price and acquisition costs must arrive at the notary demonstrably through the financial system — in practice, via a bank transfer to an escrow or client account, cleared before signing. Spanish notaries apply anti-money-laundering checks under Law 10/2010, and the beneficial ownership chain must be documented.
For Russian nationals holding funds in Russian banks, the direct path is effectively closed. Russian banks remain subject to SWIFT exclusions and EU asset freeze regulations for designated individuals. The practical question is where the buyer holds funds outside Russia.
Several channels remain operational in practice. UAE-based banks — Emirates NBD, Mashreq, RAKBANK — have been used by Russian-nationality buyers to route funds into Spanish transactions, provided the buyer holds verifiable UAE residency and the bank is satisfied with source-of-funds documentation. Turkish banks have similarly been used, though with varying consistency. Georgian banking has appeared in smaller transactions.
Cyprus, once the default intermediary, became significantly more complicated after 2022 as Cypriot banks applied enhanced due diligence to Russian-nationality account holders. Some accounts were closed; others remain functional under stringent ongoing monitoring. The situation is bank-specific rather than jurisdiction-wide at this point.
What Spanish notaries and their AML compliance officers are looking for is a coherent, documented trail: where the money originated, how it moved, what the beneficial owner's economic activity was that generated it. Properties in La Zagaleta, Sierra Blanca or Cascada de Camoján — where transaction values are often above €5 million — attract correspondingly more intensive scrutiny than a €1.5 million apartment in Puerto Banús, though both require the full paper trail.
Crypto-to-fiat conversion as a bridging mechanism is not a workaround that responsible Spanish practitioners will facilitate without equivalent documentation. The source-of-funds obligation follows the money regardless of what form it took at an intermediate stage.
Sanctions Status: What the Designation Lists Actually Mean
The EU sanctions regime under Regulation 269/2014, as amended repeatedly since February 2022, targets designated individuals and entities. Being Russian is not itself a sanctioned status. The list of designated persons runs to several thousand names, concentrated in political figures, senior executives of state-linked companies, defence sector individuals and their immediate family members and associates.
A Russian buyer who does not appear on EU, UK or US designation lists faces no legal prohibition on purchasing Spanish property. They face, instead, the practical consequences of a financial system that applies elevated scrutiny to Russian-nationality transactions as a matter of institutional risk policy — which is a different thing, though it produces similar friction from the buyer's perspective.
Verifying non-designation is a straightforward step that any competent Spanish solicitor performs as part of their onboarding checks. The relevant lists are public and searchable. Where complexity arises is with corporate structures: a Russian individual holding through a BVI or UAE holding company requires that each layer of ownership be traced and cleared. Structures that were assembled years ago for legitimate tax efficiency sometimes create documentation gaps that are time-consuming to resolve in current conditions.
The Wealth Tax Dimension
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. Non-residents have the same €700,000 allowance and are assessed on their Spanish assets only (Article 28.Tres of Ley 19/1991).
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). A non-resident owning a €3 million property in Marbella with no debt and no other Spanish assets has a base of €2.3 million after the allowance, and owes nothing. 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. This is not a new consideration, but it is one that is sometimes underestimated in the initial cost modelling.
The Impuesto Temporal de Solidaridad de las Grandes Fortunas (ITSGF) 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. It is the reason the Andalusian relief stops at the threshold, and it is the operative position for 2026 filings.
What the Transaction Process Looks Like in Practice
A cash purchase typically takes two to three months from reservation to deed; longer with a mortgage. A buyer whose source-of-funds documentation needs enhanced review should plan for longer than that: allow two to six weeks for the NIE and further weeks for the receiving Spanish legal firm to clear the documentation, with due diligence on the property itself running in parallel.
Residences that are not published and are shown by introduction sometimes allow a quieter process: fewer parties, more controlled information flow, more room for the buyer's legal team to work through documentation without competitive pressure. This is not a workaround for compliance; it is simply a different kind of transaction environment.
The zones where Russian-nationality buyers have historically concentrated — Nueva Andalucía, the Golden Mile corridor, Puerto Banús, and the gated communities running up toward Benahavís — remain the same zones where that transaction experience is now being navigated. The properties are still there. The tax framework is still the same. The work required to arrive at the notary cleanly has simply grown more deliberate, and in 2026, that deliberateness is probably the most honest thing to say about the process.
The buyers who complete are generally those who have taken the preparation seriously from the beginning: documentation assembled, banking relationships established in accessible jurisdictions, legal counsel retained early rather than after the property is found. The ones who struggle are those who arrive at the point of signing still expecting the transaction to resemble what it was four years ago.