A flat that works four months and files for twelve
The question we are asked most from the Pyrenees is always the same: if the flat is only let in season, what happens to the rest of the year? The answer is uncomfortable, because two things are true at once and they live in the same return. The nights actually let produce rental income, with its takings and its costs. The days on which the property is simply at your disposal — empty, waiting for bookings, or held back for the family — produce imputed income, a notional figure computed on the valor catastral, the rateable value set by the cadastre, and not on anything you earned.
Out of that comes the apportionment, which is where the income tax of a snow flat is really decided. The IBI local property tax, the community charge, the insurance, the utilities and the depreciation are not deducted whole: they are deducted in the proportion of days the property was genuinely let. A flat that opens from December to Easter and closes for the rest of the year does not deduct twelve months of costs.
An owner who keeps no record of let nights ends up apportioning from memory, and memory does not survive an inspection. Bookings, invoices and platform statements, kept season by season: the Agencia Tributaria, the Spanish tax authority, has four years in which to ask, and nobody remembers by then how many nights February filled. We deal with this in holiday lets.
A building levy is not always a cost of that year
In mountain apartment blocks the special levies never stop: roofs, heating, the access lift, waterproofing. They are not all treated alike. What repairs or preserves something that already existed is deducted in the year it is paid; what enlarges, improves or lengthens the life of the building is not a running cost at all, but an addition to the acquisition value, recovered through depreciation over the years and counted again on the day you sell.
The line between repairing and improving is one of the genuinely arguable points in this field. There are clear cases on each side and a band in the middle where the classification is defended with the specification of the works and the minutes of the owners' meeting, not with an accounting label.
VAT does not depend on altitude, it depends on what you offer
Letting a dwelling is exempt under article 20.Uno.23 of the Spanish VAT Act, and today that covers the Pyrenean flat let by the ski week too; the exemption is lost when you provide services typical of the hotel trade. The decree that put every stay of up to 30 nights at 10 %, whatever you provide, did not get through Congress. What decides it is not calling the property a tourist apartment, nor holding a code in the regional register: it is whether there is cleaning and a change of linen during the stay, a reception desk or continuous attendance, or meals. Handing over keys, cleaning between one guest and the next and putting fresh sheets on the bed at check-in does not turn a let into a hotel business.
One more thing, because in the Pyrenees it comes up constantly: the rate was 10 %, not 21 %. Royal Decree-law 26/2026, published in the BOE on 30 September 2026, would have applied the hotel rate to furnished homes let for up to 30 nights from 1 December 2026, on the eve of the ski season; Congress rejected it on 2 October. Today a chalet let by the week carries on under the old rule, and the new date is an unknown with a ceiling: July 2028, under Directive (EU) 2025/516. When it arrives it will mean registering for VAT, charging 10 % and filing Modelo 303 with the VAT on your costs deducted.
Who writes to us from Huesca
| Who | What it usually involves |
|---|---|
| Owner of a flat in a ski resort | Costs apportioned by nights let, imputed income for the rest of the year, and VAT according to the services provided |
| Valley guest house open all year | An economic activity, with tax registration and full quarterly returns, not property income |
| Heir to the family house in a village | Six months for Spanish inheritance tax, and imputed income while the house is neither used nor let |
| Seasonal self-employed worker (instructor, guide, catering) | Takings squeezed into a few months and instalment payments that do not follow that rhythm |
| French owner with a flat near the border | One Modelo 210 per property and per owner, let or empty |
Our way of working in Huesca
Remotely, which in a province of long valleys and mountain passes is not a convenience but the only sensible arrangement. Through the season you leave the paperwork in your folder, we read it, we do the bookkeeping, we show you the figures before anything is filed, and then we file. If you are carrying years in which the flat was never declared, that comes first: coming forward on your own initiative has a cost fixed by article 27 of the Ley General Tributaria, the Spanish general tax act, and waiting for the letter to arrive makes it worse. It is set out in filing late.
We are lawyers, not a high-street gestoría: if there is a deadline running in your file, that goes to the top of the pile and we tell you the same day.
A ski flat in Huesca, with the sums done
Take a two-bedroom flat in a ski resort in the Huesca Pyrenees, bought for 180,000 € and with a revised cadastral value of 80,000 € (the valor catastral is the official value the land registry gives the property, and several taxes are built on it). In season it is let through a platform for 95 nights at an average of 140 €; the rest of the year the family uses it or it stays shut. The figures are round, but the skeleton is that of almost every flat that reaches us from the valley.
| Item | Amount | Where it comes from |
|---|---|---|
| Income for the season | 13,300 € | 95 nights × 140 € |
| Platform commission and cleaning between guests | −3,045 € | They are tied to each booking, so they are deducted in full |
| IBI, building fees, insurance and utilities for the year | 3,330 € | 520 + 1,400 + 310 + 1,100 |
| Depreciation | 3,240 € | 3 % on the building, which here is 60 % of the price |
| Deductible share of those last two blocks | −1,710 € | 6,570 € × 95/365 |
| Net rental income | 8,545 € | Goes into the general income tax base |
| Imputed income for the other 270 days | 651 € | 80,000 × 1.1 % × 270/365 |
That last line is the Spanish rule outsiders find strangest: a second home that is neither let nor your main residence is deemed to produce income simply by being available to you. The rate is 1.1 % because the cadastral value has been revised; if it had not, it would be 2 %. The interesting part is that the three figures move together: thirty more nights of letting raise the income, but they also raise the deductible share of the costs and lower the imputed income. So before cutting prices in February to fill weeks, it pays to run this sum with your own numbers rather than your neighbour's.
The Huesca mountain guide and the quarterly prepayments
The other profile that writes to us from the province is the seasonal self-employed worker: a guide, an instructor invoicing private clients, a photographer on the slopes. The till fills in winter and in August, but Modelo 130, the quarterly income tax prepayment, knows nothing of seasons: each quarter you pay 20 % of the net income built up since January, less what was already paid in earlier quarters. With income of 9,000, 1,000, 3,000 and 4,000 € and costs of 1,000, 600, 800 and 900 € per quarter, the year looks like this:
| When it is filed | What | What this example produces |
|---|---|---|
| 1 to 20 April | 130 and 303 for the first quarter | 1,600 € of prepayment: the strong quarter pays for almost everything |
| 1 to 20 July | 130 and 303 for the second | 80 €, because the running total barely grows |
| 1 to 20 October | 130 and 303 for the third | 440 € for the summer |
| By 30 January | 130 and 303 for the fourth | 620 € with the December start |
| January | 390, the annual VAT summary | Nothing to pay: it is for information only |
| April to June | Annual income tax return | The 2,740 € already paid in advance is subtracted |
Modelo 303 is the quarterly VAT return that runs alongside. Anyone registering for the first time also pays the flat rate for new self-employed workers, 86 € a month during the first year, which is a deductible cost of the business. If you are starting now, the walkthrough is in registering as self-employed, step by step and the form to hand it to us is at register with us.
In the Pyrenees it is customary to lend the flat to family or to charge them "just the costs". If you charge nothing, those days are not letting: they are days at your disposal, they generate imputed income and their costs are not deductible. And if you charge something to a relative up to the third degree, in-laws included, the net income from that letting cannot fall below what the imputed income rule would have produced. A friendly price does not lower the tax; it only complicates it. Mark those weeks separately in the calendar and record what they were.