Good to know · Taxes

Dual tax filing obligations for a US citizen resident in Spain (overview)

A US citizen who becomes a Spanish tax resident faces filing obligations in BOTH countries simultaneously, and one does not replace the other. In Spain: an annual IRPF return (if a Spanish tax resident per Art. 9 Ley 35/2006) covering worldwide income, plus potentially Modelo 720 (foreign assets over EUR 50,000 per category) and, if applicable, Modelo 721 (foreign-held crypto, details unconfirmed — see ES-0133). In the United States: a US citizen must continue filing Form 1040 annually regardless of where they live or whether they owe any US tax, generally using Form 2555 (foreign earned income exclusion) and/or Form 1116 (foreign tax credit) to reduce double taxation on income also taxed by Spain; separately, FinCEN Form 114 (FBAR) is required if the aggregate value of foreign (non-US) financial accounts — which for a US citizen in Spain includes Spanish bank accounts — exceeds USD 10,000 at any point in the year, filed electronically by 15 April with an automatic extension to 15 October; and separately again, IRS Form 8938 (FATCA) is required if specified foreign financial assets exceed higher thresholds for those living abroad (USD 200,000/300,000 single, USD 400,000/600,000 married filing jointly, measured at year-end/anytime respectively), filed with the Form 1040.

Why it matters

This is the single most important 'first thing to understand' for an American relocating to Spain: moving abroad does not end US tax filing obligations, and Spain’s own residency-based worldwide-income taxation creates a second, parallel filing track. Missing either FBAR or Form 8938 (which are easy to overlook because they are not the main tax return) carries significant separate penalty exposure.

When

Any US citizen who establishes Spanish tax residency, or who holds Spanish financial accounts/assets above the FBAR/FATCA thresholds, regardless of residency status.

How long it takes

Spain: IRPF filing season is typically April-June for the prior calendar year; Modelo 720 is Jan-Mar. United States: Form 1040 is due 15 April (with automatic extensions available for those abroad), FBAR is due 15 April with an automatic extension to 15 October with no request needed.

Official page

Last checked

15 Oct 2026

Do these first

• Spanish tax residency rules (183-day rule and other tests)
• Modelo 720 - declaration of assets and rights held abroad
• Modelo 721 - declaration of virtual currencies (crypto-assets) held abroad
• US-Spain income tax treaty (1990, as amended by the 2013 Protocol)