Double taxation Russia and Spain: how it is arranged

What is double taxation and where it comes from

The double taxation occurs when two states share the same income of one person, and the Russians in Spain are characterized by three situations. The first is that you are a tax resident of Spain and you get income from Russia (wage, rent, interest, dividends, property sales). The second is that you are a resident of both Spain and Russia, because the criteria of countries are different. The third is that you are not a resident of Spain, but you have real estate or you have real estate here. The Government has made a number of efforts to improve the quality of its services.

Spanish resident is subject to IRPF for all income wherever it arises and from whatever country the payer pays (article 2 LIRPF), and article 9 is based on the fact that the person who spent more than 183 days in Spain a year or who has the main centre of economic interests here is a family presumption. [6]Non-residents pay tax only on income received in Spain [13]The criterion of residence in Russia is different, so that at times a person may be a resident of both countries. Tax residence in Spain and Resident and non-resident taxes.

Double taxation between Russia and Spain: what the Convention says

The 1998 Convention does three things: it defines who is considered a resident, if a resident of both countries, allocates the right to tax different types of income and calls the method of eliminating double taxation [1]For dual residence, article 4 provides a chain of residence: permanent residence; where housing in both countries is the centre of life; then the usual place of residence; then nationality; if not, the authorities of the two countries agree between themselves [1].

Article 15 provides important clarification for employment: if the work is performed in another country, it is entitled to pay the labour; the exception for three conditions is that the person is not in any period of 12 months, paid by an employer who is not resident in the country and the costs are not borne by the permanent establishment. [1]As it applies to the remote work of nomads today, we have not found it.

Status of the Convention as at 2 October 2026: confirmed

The picture is double, and we don't smooth the discrepancy.

• Russia. Presidential Decree No. 585 of 8 August 2023 suspends from 8 August 2023 until Russian violations of interests are eliminated the operation of articles 5-22 and 24 of the Convention and paragraphs II-VIII of the Protocol. [2].
• Spain. AEAT page with list of treaties (updated on 10 April 2025) refers to the 1998 Convention without suspension markings [3]The AEAT Handbook for Residents with Russian Income (updated 08.04.2026) explains the application of articles 6, 10, 11, 13, 18 and 19 without reservation [4]. In the table of restrictions for non-residents (Manual AEAT, 02.10.2026) for Russia, the limits are 5, 10 and 15% for dividends and 5% for royalties [5]The Convention on the Spanish Ministry of Finance website, amended by MLI multilateral instrument, does not mention suspension [10].
• Denunciation. The Convention is in force until one of the parties denounces it (art. 29) [1]We haven't found any denunciation reports.

So two conclusions: the Convention is formally in force and is applied by Spain; the Russian Federation does not apply parts of the articles; how it affects your income depends on the type of income and the way in which the Russian tax agent and the Spanish Inspectorate will proceed; we have not found any official Spanish explanation for the suspension.

How Spain eliminates double taxation: deduction under article 80

If there is income from a resident that is earned and paid in a foreign country, a lower of two amounts is deducted from the tax [6][7]:

1. Tax actually paid abroad, based on a tax identical to or similar to IRPF or IRNR;
2. The average rate is equal to the total net tax amount divided by the tax base, while the total income and savings income are treated separately.

A case study of mechanics, not prognosis. Of the 10,000 I am the income tax imposed in both countries, at an average rate of 25% Spanish tax on this part of 2,500 I. If 1,300 I have been paid in Russia, a deduction of 1,300 I have been deducted. If 3,000 I have been paid, the deduction is limited to 2,500 I, the remaining foreign tax under Article 80 is not counted. The Convention repeats this rule in Article 23.1: the deduction of the amount of the tax actually paid in Russia but not more than part of the tax paid in Russia. Spanish tax on this income [1].

In some cases, the Convention exempts income in Spain but with progress: the amount released is taken into account in the calculation of the tax on other income (art. 23.1.c). AEAT gives an example for public pensions [1][4].

For a resident with a double taxation deduction, the obligation to file a declaration arises regardless of the amount of income (article 96.4 LIRPF) [6]The foreign tax is confirmed with the declaration. How to prepare a module 100 and IRPF rates and deductions.

Resident certificate and conciliation

AEAT issues it if your residence in Spain is based on its data [11]In order to obtain a deduction in Russia and to apply the contract on the Russian side, the requirements are defined by Russian legislation: discuss this with the Russian tax adviser.

If you believe that two States have imposed income contrary to the Convention, article 25 allows for recourse to the authority of their country of residence. The application is filed within three years of the first notification of the measure leading to such taxation. [1]As this procedure is going between Russia and Spain now, we have not found in official sources.

Beckham Mode and the Compact: What's Changing

Members of the article 93 regime Ley 35/2006 are not considered residents for the purposes of double taxation treaties, as only Spanish revenues (Manual AEAT) are subject to the regime. [8]. All wages during the regime are considered received in Spain. Instead of a deduction under Article 80, a separate international double tax deduction is applied for such income, limited to 30% of the tax attributable to the relevant income (Article 114.2.b Reglamento IRPF) [9]Conditions of the regime: Beckham Law for a Digital Nomad.

Action: from status to declaration

1. Identify the tax residence in each country for each year. [1].
2. Share income by type: wages, self-employment, rent, dividends, interest, increase in sales, pensions.
3. Find an article of the Convention for each species and check its status: whether it is suspended by Russia and how it is applied by a tax agent in Russia [2].
4. Collect evidence of taxes paid in Russia (tax agent or tax service documents).
5. You can apply for a deduction in the module 100 under article 80 LIRPF and apply if you have the right to do so. [6].
6. In cases of residence or settlement disputes contrary to the treaty, consider the procedure under article 25 [1].

Belarus, Kazakhstan and other CIS countries

This does not work automatically for other countries. The AEAT list of treaties contains separate pages for Belarus, Kazakhstan, Armenia, Azerbaijan, Georgia, Moldova, Uzbekistan and records of treaties with former republics of the USSR. [12]The terms of each treaty are treated separately, the criteria for residence and their stakes are not dealt with in this article.

Typical Errors

• Consider that Russian tax will automatically be taken into account in Spain. [6].
• Consider the deduction to pay the entire foreign tax, which is limited to the average rate in Spain. [7].
• Resign to the preferential rates of Articles 10 and 11 as guaranteed without checking how they are applied by the Russian tax agent after suspension [2].
• Consider suspension part of denunciation. Convention in force until it has been denounced [1].
• Beckham's contract and regime: Members are not considered residents for the purposes of treaties [8].
• Forget that the declaration is mandatory to deduct from the resident. [6].
• Consider that the contract defines residence as "by passport": housing, centre of interest, habitual residence and then citizenship [1].

When Individual Review Is Needed

We need to deal with almost always when there is income from Russia because the answer depends on the type of income, the status of both countries and the practice of the tax agent, especially the dividends, interest, renting Russian real estate, selling property and pensions. We do not propose tax schemes and ways to reduce the tax. We explain how the procedure works.

What can we help you with?

The NEXO team in Barcelona is helping to collect documents, compile a history of residence and a list of country income, prepare questions for the tax consultant in Spain and Russia. ConsultationIII. Service page: Digital nomad ’s residence permitorder of submission to DNV: route sheet, general relocation scheme: Residence permit in Barcelona.

Frequent issues

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The source is viewed on 02.10.2026 · NEXO · Drafting Draft · Sources do not replace individual legal advice.