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DAC7 in Spain 2026: What Airbnb Sends to AEAT (and HMRC, IRS)

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DAC7 in Spain 2026: What Airbnb Sends to AEAT (and HMRC, IRS)

Real Decreto 117/2024 transposes DAC7 in Spain. Airbnb reports your Spanish vacation rental income to AEAT via Modelo 179 plus the new cross-border XML feed. How to reconcile with Modelo 210, common discrepancies and audit triggers for non-residents.

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DAC7 in Spain 2026: What Airbnb Sends to AEAT (and HMRC, IRS)

Cross-border tax reporting for foreign owners running Spanish vacation rentals: how Airbnb and Booking.com transmit your earnings to AEAT (Agencia Tributaria, the Spanish tax authority), what HMRC and IRS see automatically, how to reconcile Modelo 179 platform reports with your Modelo 210 quarterly filings and your home-country return.

Since January 2024 every booking platform you use for your Spanish vacation rental sends a structured report to AEAT every January. AEAT then forwards your data to your country of tax residence under the EU Directive on Administrative Cooperation, version 7 (DAC7). If you are UK or US tax-resident, HMRC and IRS receive details of every reservation, gross receipts, payouts and counterparty information. This guide explains exactly what is reported, when, and how to make sure your Modelo 210 quarterly filings match the data your home tax office already has.

What DAC7 Is and How Spain Implemented It

DAC7 is Directive (EU) 2021/514, transposed into Spanish law by Real Decreto 117/2024 of 30 January 2024 (modifying the General Regulation of Tax Application Actions and Procedures). It forces every digital platform (Airbnb, Booking.com, Vrbo, Expedia, TripAdvisor, Hostelworld and approximately 90 other reportable platforms) to collect tax data from their hosts and send it annually to the tax authority of the country where the property is located.

Spain layered DAC7 on top of an existing pre-DAC7 reporting tool, Modelo 179. Modelo 179 was introduced in 2018 (Orden HFP/544/2018) and remains operative for STR specifically. From 2024 onwards Spain runs both: Modelo 179 quarterly for STR-only platforms, and the new DAC7 XML feed annually for all reportable activities. The result for a Spanish-located vacation rental is double reporting, with overlapping but not identical data sets.

For a UK or US owner with a Marbella villa, the chain works like this: Airbnb collects your data, sends Modelo 179 each quarter and a DAC7 XML each January (covering the previous calendar year), AEAT verifies the data against your Modelo 210 quarterly filings, then AEAT forwards a summary to HMRC or IRS via the standard Common Reporting Standard infrastructure under DAC7.

Exactly What Data Airbnb Sends to AEAT Each January

The reportable data set under DAC7 is standardised across all platforms in the EU. Each January, for each host with Spanish property, the platform sends to AEAT:

  • Host identification: full name, date of birth, address, NIE (Spanish foreigner ID), home-country tax ID (UK UTR, US SSN or EIN)
  • Property details: full address, NRUA registration code (the new national STR registry code under Real Decreto 1312/2024), CCAA licence (HUTG, VFT, VTT, ETV, VV, VUT), cadastral reference
  • Per-quarter financial data: total nights booked, gross receipts received, fees and commissions deducted, net payout to the bank account, currency
  • Bank account details: IBAN, SWIFT, account holder (the platform sees where money was sent)
  • Number of distinct reservations and aggregate guest counts

The Modelo 179 quarterly filing is narrower: it includes the property address, the host identification, the gross income paid in the quarter and the platform identification. It does not include the per-reservation breakdown or the bank account details that DAC7 collects.

The Cross-Border Information Flow to HMRC and IRS

The DAC7 framework defines three flows:

  • EU to EU: directly between member states under DAC7. AEAT to French DGFiP, German Bundeszentralamt für Steuern, Italian Agenzia delle Entrate, etc.
  • EU to UK post-Brexit: under the bilateral exchange framework that survived Brexit. AEAT to HMRC via the Common Reporting Standard infrastructure, with DAC7 data sets.
  • EU to US: through FATCA-equivalent channels and the bilateral Spain-US tax treaty exchange of information clause (art. 27 of the 1990 treaty as amended by the 2013 protocol).

The end result: by April every year, HMRC and IRS already know your Spanish vacation rental gross income before you file your home-country tax return. This is a major change from pre-2024 when only AEAT had the data and cross-border information sharing required specific requests.

Reconciling Modelo 179 Platform Reports with Your Modelo 210

The reconciliation pinch point: Modelo 179 reports gross income paid to the host (after platform commission deducted), while Modelo 210 declares the gross income as defined by Spanish IRNR rules (gross before commission for non-EU owners on the 24% gross regime, net after deductible expenses for EU/EEA owners on the 19% net regime).

Common reconciliation table for a Marbella property in Q2 2025:

LineAmount (EUR)Source
Guest payments to Airbnb14,500Airbnb dashboard, gross from guest
Airbnb host service fee (3%)(435)Airbnb commission
Cleaning fees collected and paid out1,200Pass-through to host
Net Airbnb payout to host bank account15,265Bank statement
Modelo 179 reported gross to host15,265What Airbnb tells AEAT
Modelo 210 gross income (UK non-EU owner)15,70014,500 + 1,200 = guest gross including cleaning, before service fee
Modelo 210 IRNR at 24%3,768Q2 IRNR liability

The EUR 435 reconciliation gap between Modelo 179 (15,265) and Modelo 210 (15,700) is the Airbnb service fee. AEAT recognises both views; what matters is that you can reconcile them. The audit risk is when Modelo 210 shows a figure substantially below Modelo 179 with no explanation.

Common Discrepancies That Trigger AEAT Audits

Five recurring patterns trip up foreign owners:

  • NRUA code mismatch: the platform reports an NRUA code that AEAT cannot match to a registered property. Often happens after a CCAA licence change or an NRUA renewal. Triggers immediate verification within 30 days.
  • Multi-platform under-reporting: the host files Modelo 210 with only Airbnb income, while Booking and Vrbo also reported. AEAT cross-references all DAC7 feeds and any single missing platform creates a gap.
  • Bank account mismatch: the IBAN reported by the platform does not match any IBAN linked to the NIE in AEAT records. Usually because the host uses a UK account directly. Not illegal but flags for verification.
  • Currency conversion gaps: Airbnb reports in EUR, the bank receives GBP after conversion. Modelo 210 must be in EUR. The host's GBP figure differs from the platform's EUR figure due to FX timing.
  • Cleaning fee treatment: cleaning fees are part of the gross rental for IRNR purposes (taxable) but are sometimes excluded by hosts who treat them as pass-through. AEAT treats them as taxable.

What HMRC and IRS Do with the DAC7 Data

HMRC matches the inbound DAC7 data against the host's UK Self Assessment return (SA106 foreign income pages). Typical follow-up:

  • Income on SA106 substantially below the DAC7 figure: enquiry letter under art. 9A TMA 1970, requesting reconciliation and supporting Spanish filings.
  • No SA106 entry at all when DAC7 shows Spanish income: discovery assessment under art. 29 TMA, going back up to 6 years (20 years for deliberate non-disclosure under FA 2008 Sch. 39).
  • FX translation challenge: HMRC accepts spot rate, monthly average or annual average. Pick one and apply consistently.

IRS receives the DAC7 data via the Spain-US treaty exchange. US tax residents must report Spanish rental income on Schedule E (Form 1040), with foreign tax credit on Form 1116 for Spanish IRNR paid. The 24% non-EU rate is generally fully creditable against US tax on the same income. FBAR (FinCEN 114) is required if you maintain a Spanish bank account with USD 10,000+ aggregate at any point in the year, plus FATCA Form 8938 if total foreign assets exceed reporting thresholds.

The Direct Booking Loophole That Is Not a Loophole

Some foreign owners reduce platform exposure by taking direct bookings via their own website or by repeat guests bypassing Airbnb. This does not reduce tax exposure. Direct bookings are still taxable IRNR income filed on Modelo 210. They are absent from Modelo 179 and DAC7 because no platform is involved, but the income remains reportable. AEAT routinely cross-checks bank inflows against declared rental income and queries unexplained credits.

The practical compliance posture: assume AEAT sees roughly 70 to 90% of your STR income via DAC7 (depending on platform mix), and ensure your direct-booking declarations bring the total to 100%. Discrepancies in your favour (declaring more than DAC7 shows) are fine; discrepancies against you (declaring less) trigger audits.

Frequently Asked Questions

If I only use Airbnb, does AEAT see my Booking.com or Vrbo data?

Only platforms you actually use report. If you use only Airbnb, AEAT receives only Airbnb data for you. The cross-platform issue arises when you use multiple platforms and only declare one or some of them on Modelo 210. Each platform reports independently and AEAT aggregates.

Can I claim the platform commission as an expense?

If you are an EU/EEA tax resident on the 19% net Modelo 210 regime, yes. The Airbnb service fee, the Booking commission, the Stripe processing fee are all deductible. If you are non-EU (UK, US, Canada) on the 24% gross Modelo 210 regime, no expenses are deductible at all. This is the post-Brexit asymmetry that makes Spanish STR materially more expensive for UK owners.

What happens if the platform reports incorrect data?

You can dispute via the platform's tax team. Airbnb has a EU tax data correction portal in the host dashboard. Booking has a similar form via partner support. Corrections take 30 to 90 days. In the meantime file Modelo 210 with the correct figures and keep documentation of the dispute. AEAT will accept your figures over the platform's if you can document the discrepancy.

Is my US LLC reported separately from me personally?

If the LLC is the registered host and holds the property, the LLC is the reportable subject. Its US EIN, address and gross receipts are sent to AEAT and forwarded to IRS. If the LLC is pass-through for US tax purposes, you also report on your personal Form 1040 with foreign tax credit. The dual-filing creates reconciliation work but is not an audit trigger by itself.

Can AEAT use DAC7 data to chase me for years before 2024?

Not directly. DAC7 covers data from calendar year 2023 onwards. Pre-2023 income remains accessible only through specific information requests under the Spain-UK or Spain-US treaty exchange clauses. However, if a 2024 audit reveals undeclared 2024 income, AEAT can extend the audit backwards to 4 years (the standard limitation period in art. 66 LGT, extended to 10 years for fraud).

Do I need to file Modelo 210 if my income is below a threshold?

There is no threshold. Any rental income to a non-resident landlord triggers Modelo 210. Even EUR 200 of income for a single weekend booking requires a quarterly Modelo 210. Many foreign owners assume a de-minimis applies; it does not. Skipping a quarter at zero is also a filing default.

Need help reconciling Airbnb, Booking and direct-booking income with Modelo 179 platform reports, the four quarterly Modelo 210 filings and the annual SA106 or Schedule E in your home country? The Standard Package HostReady (Spain) includes a DAC7 reconciliation worksheet, a Modelo 179 vs Modelo 210 mapping template and a quarterly compliance calendar designed for UK and US owners with Spanish vacation rentals.

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