Filing the Modelo 650: How to Declare Spanish Inheritance Tax (ISD) as a Non-Resident (2026)

A step-by-step guide to the Spanish inheritance tax self-assessment form, from the six-month deadline and the mandatory documentation to the three submission methods and the Andalusia 99 per cent bonificacion.

The Modelo 650 is the self-assessment form a non-resident heir files with the Spanish tax authority (AEAT) to declare and pay Inheritance and Gift Tax (Impuesto sobre Sucesiones y Donaciones, ISD) on acquisitions mortis causa. The deadline is six months from the date of death. The filing goes to the National Tax Management Office for Non-Residents in Madrid, not a regional office, because competence remains central when the heir or the deceased was not Spanish-tax-resident. Since January 2015, self-assessment is mandatory: the heir calculates the tax, pays any amount due, and files the form with the supporting documentation. This guide walks through every step of the process, citing the primary legal sources, so you know exactly what to file, when, and where.

What is the Modelo 650 and when must a non-resident file it?

The Modelo 650 is the ISD self-assessment form for acquisitions transferred due to death, covering inherited property, rights, bequests, and life insurance payouts where the policyholder is a person other than the beneficiary. Each heir or legatario files their own individual Modelo 650, even when multiple heirs inherit together. The legal basis is Ley 29/1987, de 18 de diciembre, del Impuesto sobre Sucesiones y Donaciones, and the procedural rules are in the Reglamento approved by Real Decreto 1629/1991. From 1 January 2015, all non-resident ISD filings must be self-assessments, meaning the heir performs the calculation and submits the result rather than waiting for the tax authority to issue an assessment.

The competence rule determines where you file. The National Tax Management Office handles the tax when it is not transferred to an autonomous community under the common regime, which occurs when the deceased was not resident in Spain on the date of death, or when the heir (taxpayer) did not have their usual place of residence in Spain on that date. This is why a non-resident inheriting a Marbella apartment files with the central AEAT office in Madrid (Paseo de la Castellana 147), not with the Junta de Andalucia tax office, even though the property sits in Andalusia and the Andalusia bonificacion still applies. The AEAT non-resident ISD page sets out the full competence delimitation.

What is the deadline and how does the extension work?

The filing deadline is six months from the date of death, or from the date the declaration of death becomes final. This is a single, unified deadline that covers the entire self-assessment process: completing the form, gathering the documentation, paying any tax due, and submitting. An extension of a further six months can be requested, but only within the first five months of the original period. If the request is submitted within the five-month window and no notification is received in the following month, the extension is deemed granted under the AEAT’s own procedural rules. Filing after the six-month deadline (or after the extended deadline) accrues late payment interest at 4.0625 per cent per annum in 2026, calculated from the end of the six-month period until the filing is made, and recorded in box 62 of the Modelo 650. The AEAT submission deadlines page confirms these rules verbatim.

Deadline stage	Timeframe	Key rule
Filing deadline	6 months from date of death	Covers form, payment, and documentation
Extension request window	First 5 months of the 6-month period	Request via AEAT Sede Electronica or written registry
Extension duration	A further 6 months	Deemed granted if no notification within 1 month
Late payment interest	From end of 6-month period to filing	4.0625% per annum in 2026, box 62

What documentation must a non-resident submit with the Modelo 650?

The AEAT documentation page lists a mandatory set and a conditional set. The mandatory documents must accompany every non-resident Modelo 650 filing. The conditional documents apply where the estate includes specific asset types or where the heir claims particular deductions.

Mandatory documents:

1. The original and a certified copy of the deed of acceptance of inheritance (escritura de aceptacion de herencia). If no deed exists, an estate and heirs inventory in duplicate, showing the deceased’s identifying details, the heirs’ details and addresses, a detailed list of assets and rights with their value at the date of death, and any charges, debts, or costs being claimed as deductions.
2. A copy of the death certificate.
3. A copy of the certificate from the General Registry of Last Will Acts (Registro General de Actos de ultima voluntad), issued by the Spanish authorities, even if the result is negative (no will registered).
4. A copy of the will or the declaration of heirs.

Tax representative appointment (non-EU and non-EEA heirs): Heirs who are not resident in an EU member state or in an EEA state with mutual-assistance agreements on tax information exchange (Iceland, Norway, Liechtenstein) must appoint a natural or legal person resident in Spain to represent them before the tax administration. EU and EEA heirs have no obligation to appoint a representative but may do so voluntarily. The representation model must be submitted with the self-assessment (not a photocopy).

Foreign documents: Any document issued by a foreign authority must carry a Hague Apostille and a sworn Spanish translation. If you hold a European succession certificate under EU Regulation 650/2012, an authentic copy can substitute for the death certificate and the will or declaration of heirs.

How does a non-resident submit the Modelo 650?

The AEAT forms of presentation page sets out three submission methods, each with different practical implications for a non-resident.

1. Electronic filing via the Internet (the standard route). The heir or their representative completes and transmits the form through the AEAT Sede Electronica, attaching the mandatory documentation as PDF files. The system issues the Article 87 bis certification electronically, so the heir does not need to attend the National Tax Management Office in person. Identification is via a digital certificate, electronic ID, or the Clave PIN system. This is the route most non-resident heirs use, typically through a Spanish lawyer or fiscal representative who holds the necessary digital credentials.

2. Pre-declaration (help programme). The heir completes the form on the AEAT website, prints it with a cover sheet containing the reference number, pays any tax due at a collaborating bank, and submits the printed form and documentation to the AEAT. The original documentation must then be sent to the National Tax Management Office for processing. This method requires physical attendance at a registry office or the Madrid office.

3. Physical copies. The heir downloads the form, completes it manually, pays any tax due, and submits it to the National Tax Management Office, Inheritance and Donations of Non-Residents, at Paseo de la Castellana 147, ground floor, 28046 Madrid. An appointment is recommended (91 333 5 333 or via the Sede Electronica). Any person can submit on the heir’s behalf; the taxpayer does not need to appear in person.

Submission method	Filing route	Attendance at Madrid office
Electronic (Internet)	AEAT Sede Electronica with digital certificate or Clave PIN	No (Article 87 bis certification issued online)
Pre-declaration (help programme)	Print and submit to AEAT registry, then originals to Madrid	Yes (originals must be sent to Madrid)
Physical copies	Paper form submitted to Madrid office	Yes (appointment recommended)

How does the Andalusia 99 per cent bonificacion work within the Modelo 650?

For a non-resident heir in Group I or II (descendants, spouse, ascendants, registered partners), the Andalusia 99 per cent bonificacion on the ISD cuota is applied directly within the Modelo 650 self-assessment. There is no separate application form. The mechanism works as follows, per the Junta de Andalucia ATRIAN guidance:

1. The heir elects to apply the Andalusia regional legislation rather than the state default ISD tariff. The regional framework is the Decreto Legislativo 1/2018 (Texto Refundido de las disposiciones dictadas por la Comunidad Autonoma de Andalucia en materia de tributos cedidos), as amended by Decreto-Ley 1/2019 (in force from 11 April 2019) and consolidated in Ley 5/2021. This election is possible for non-residents following the CJEU’s 2014 ruling (Case C-127/12, the Welte case) and Ley 26/2014, which lets non-residents apply the regional legislation where the connection point (the location of the inherited assets) points to a particular autonomous community.
2. The EUR 1,000,000 base reduction (in force since 1 January 2022 under Ley 5/2021) is applied to the taxable base before the tariff.
3. The progressive tariff (7 per cent to 26 per cent) is applied to the resulting liquidable base.
4. The kinship multiplier (1.0 for Groups I and II) is applied.
5. The 99 per cent bonificacion is applied to the resulting cuota tributaria, reducing the liability to roughly 1 per cent of the state tariff output.

The Junta de Andalucia self-assessment guide confirms that in Andalusia a single Modelo 660 (data declaration) is filed alongside a Modelo 650 for each heir. The bonificacion is self-applied in the cuota section. For a deeper explanation of the tax calculation and the worked example, see the inheritance tax in Andalusia guide.

How is the property valued for the Modelo 650?

The property value declared in the Modelo 650 must be the valor de referencia de bienes inmuebles (the reference value published by the Catastro) at the date of death (the devengo). If the value declared by the heirs, the agreed price, or both are higher than the reference value, the higher figure must be used. When no reference value exists or it cannot be certified by the Catastro, the base is the highest of the value declared by the heirs, the agreed price, or the market value. The Catastro publishes reference values on its Sede Electronica, and the Junta de Andalucia tax agency provides a tool to calculate the minimum declared value for properties. For more on how the Catastro sets values and how they feed into transfer tax, see the Catastro and cadastral value guide.

What about the tax representative requirement?

Non-EU and non-EEA heirs must appoint a Spanish tax representative before filing the Modelo 650. EU and EEA heirs (Iceland, Norway, Liechtenstein) have no obligation to appoint one but may do so voluntarily to handle the filing. The representative holds a power of attorney, files the self-assessment, receives notifications, and liaises with the AEAT. For a full guide to the role, costs, and legal basis, see the fiscal representative guide.

How does the Modelo 650 relate to the wider inheritance process?

The Modelo 650 filing is one step in a sequence. Before it comes the acceptance of the inheritance (aceptacion de herencia) before a Spanish notary, which produces the deed of acceptance that the Modelo 650 requires. After it comes the partition of the estate (escision de herencia) and the registration of the property transfer at the Land Registry. The non-resident inheritance process guide walks through the full sequence, and the inheritance planning guide covers the forward-looking steps (Spanish will, donations, estate structuring) that reduce the eventual ISD bill. A Spanish will, registered with the General Registry of Last Will Acts, is what produces the certificate the Modelo 650 filing requires; see the Spanish will guide.

What penalties apply for late or incorrect filing?

Late filing triggers two consequences. First, late payment interest at 4.0625 per cent per annum in 2026 accrues from the end of the six-month deadline until the filing is made, recorded in box 62 of the Modelo 650. Second, surcharges for extemporaneous filing under Article 27 of the Ley General Tributaria (Ley 58/2003) may apply, depending on how late the filing is and whether the AEAT has issued a requirement first. If the AEAT discovers the filing was never made, the general sanction regime under Articles 198 and 199 LGT applies. The heir remains liable for the tax itself indefinitely if no self-assessment is filed, because the ISD prescription period (four years from the filing deadline under Article 66 LGT) does not start until the tax event is properly declared. If the heir disagrees with an AEAT assessment, the property tax appeals guide explains the challenge routes.

This guide is general information, not legal or tax advice. Rules change and individual circumstances differ. Verify current requirements with an independent lawyer (abogado) or tax advisor (gestor/asesor fiscal) before acting.