Spain · Tax regime
Solidarity Tax on Large Fortunes (Impuesto de Solidaridad de las Grandes Fortunas)
Open
Last verified July 2026
Made permanent in 2025 after being introduced as a 'temporary' measure for 2023–2024. This is now a structural feature of Spanish wealth taxation, not a transitional one.
This tax exists specifically to defeat the regional planning that made Madrid attractive. Regional Patrimonio paid is credited against it — so when Madrid or Andalucía rebate their wealth tax to zero, the credit is zero and the state collects the whole amount. Any adviser recommending Madrid to a UHNW client for wealth-tax reasons is working from a pre-2023 playbook.
Qualifying routes
€3M
Band 1: EUR 3m to roughly EUR 5.35m
1.7%
€5.35M
Band 2: roughly EUR 5.35m to EUR 10.7m
2.1%
€10.7M
Band 3: above roughly EUR 10.7m
3.5%
The facts
- Qualifying figure
- €3M
- Total landed cost
- for a Spanish tax resident with EUR 20m of net assets, a mid-six-figure annual liability is realistic once the Patrimonio credit is exhausted
- Physical presence
- Spanish tax residents are assessed on worldwide net wealth; non-residents on Spanish-situs assets only
- Family
- assessed individually, not per household — spouses are assessed separately
- Permanent residency
- not applicable
- Citizenship
- not applicable
- Language test
- not applicable
- Dual citizenship
- Not permitted — you would have to renounce
What can go wrong
- It is permanent. The word 'temporary' in the original name (ITSGF) is still in circulation and still misleads clients into treating it as an expiring measure.
- Residents get a EUR 700k exemption, so the practical threshold is around EUR 3.7m; the primary-residence relief of EUR 300k applies to Patrimonio and its interaction here should be confirmed for the specific case.
- It is assessed individually, so a EUR 6m couple holding jointly may fall below the threshold each — one of the few structuring points that still works and is routinely missed.
- The joint Patrimonio + IRPF + Solidarity cap (límite conjunto) limits total liability to 60% of taxable income for residents — which is the main relief valve for low-yield asset holders and is worth modelling before assuming the headline rate applies.
- Non-residents are exposed on Spanish-situs assets, which for a departed Golden Visa investor means the Spanish villa is still in scope.
- Holding Spanish real estate through a foreign company does not reliably avoid the charge — Spain looks through such structures for both Patrimonio and ITSGF.