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El blog de Maria

Your daily Spanish Law reporter. Have it with a cafe con leche. www.costaluzlawyers.es

Legal tip 1268. I am not Spanish but I pay IHT in Spain
Thursday, February 26, 2015 @ 4:11 PM

 

Who are the foreigner taxpayers of Spanish Inheritance tax?
 
As you know, Inheritance tax in Spain is paid by the beneficiaries. Submission to the tax is due to either personal or real obligation.
 
If the beneficiary is a Spanish resident:
 
According to provision 6 of Act 29/1987 on Inheritance and Donation tax, you will be liable in Spain for the acquisition  of all the inherited assets regardless the country they are located. The criterion for this submission is personal obligation (personal residency). Taxes paid in a foreign country by similar concept will be deducted according to a rule established in provision 23 of the Spanish Inheritance Tax Act.
 
 
If  the beneficiary is not a Spanish resident:
 
According to provision 7 of the Act 29/1987, he will be under Spanish Inheritance tax obligation by real obligation (location of goods), and will have to pay Inheritance taxfor those goods and rights located in Spain.
 
From date of death of the deceased, there is 6 months to pay the inheritance tax return. The forms are 650 and 652.
 
If you are a resident, it is necessary to have a Tax identification number (NIF).
If you are not a resident, you will need to have a NIE number.
 
There is no agreement for the avoidance of double Inheritance taxation between Spain and the United Kingdom.
 

European Court recently declared that  Spain tax on inheritance and gift is, in part, contrary to Community legislation.

 

Luxembourg has just ruled that the tax is contrary to Community law as it forces foreign residents to pay higher taxes than Spanish residents.

 

This tribute is regulated by Regions (Communidades autónomas) and these offers tax deductions of which can only benefit the residents in that region. Thus, residents in another EU country or holders of property located outside the country are forced to pay higher taxes.

 

The Court of Justice of the European Union (ECJ) considers that there is "no objective difference that could justify this difference in treatment" between the situation of a resident and a non-resident or from a property located in Spain or in another country.

 

European justice agrees with the EU executive, who brought the case to court in 2012, and believes that this involved a "restriction" on free movement of capital, one of the pillars of the European Union.

 

The judgment, unappealable, is now mandatory for Spain.  Spain will have to modify Law 22/2009 on cession of IHT tax to regions so non residents receiving an inheritance in Spain can benefit from regional allowances.

 

 IMPORTANT NOTICE: If you are a non resident and you paid IHT tax in Spain during the last four years, a refund claim is possible now

Parque del Oeste, Malaga, South eastern Spain

 


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