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Guide

Retire in Spain: €28,800 Passive Income Bar, Zero-Copay Insurance Mandate — and Your IRA Withdrawals Are Fully Taxed

Spain is one of the most popular European retirement destinations — warm climate, affordable cost of living outside the major cities, strong healthcare, easy access to the rest of the continent. The catch: the Non-Lucrative Visa carries the highest income threshold of any major European retirement path. The private health insurance requirement is stricter than most guides explain. And the US–Spain tax treaty creates a sharp divide — your Social Security is fully exempt from Spanish tax, but your IRA and 401(k) withdrawals are taxed as ordinary Spanish income from day one of residency.

Visa figures reflect Spain's 2026 IPREM threshold (Spainguru's 2026 IPREM guide). Tax information reflects the PwC Spain individual tax summary (2026) and the US–Spain Totalization Agreement. Requirements change — verify with your nearest Spanish consulate before applying.

Kelly Milligan, founder of Expat Retire Guide

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Published

A sunlit cobblestone square in a white-walled Andalusian village with tropical greenery and terrace cafés

Is Spain the right fit?

Most workable for: retirees with €28,800+/year in passive income (SS, pension, or investment draws), willing to commit to 183+ days in-country, and whose retirement income is primarily Social Security.
Run the numbers carefully if: you have significant IRA or 401(k) income — Spain taxes those withdrawals at progressive rates (19–47%), and the exemption-with-progression rule pushes you into higher brackets than you'd expect.
Not workable if: your passive income is below €28,800/year, you want to split time between Spain and the US as a snowbird (183+ days required for the NLV), or pre-existing health conditions are a primary concern — get insurance quotes before you apply.

At a Glance

NLV income requirement

€28,800/year (~$31,300)

Convenio Especial (age 65+)

€157/month — after 1 year

NLV-compliant private insurance

~€150–350/month at 65

Path to citizenship

10 years (US citizens)

The Medicare Decision

Medicare covers nothing in Spain — not routine care, not specialist visits, not prescriptions. Before you go, you need a plan for each part. There's no bilateral healthcare agreement between the US and Spain.

Keep always
Part A Keep it — always

Free for most people. Covers you on visits back to the US. No reason to drop it.

Situation dependent
Part B Depends on your situation

At $202.90/month (standard 2026 rate), you're paying for coverage that won't work in Spain. Whether to keep it depends on how permanently you're moving.

Fully relocating: Consider dropping it — but document your Spain residency carefully to avoid the late enrollment penalty if you return.

Splitting time: Keep it. You'll use it on US visits and the penalty risk isn't worth it.

Trial run: Keep it. Don't risk a permanent penalty for a 1–2 year test.

If you carry Medigap Plan G, you already have up to $50,000 of foreign emergency coverage at 80% after a $250 deductible — useful for short visits back to Spain, not enough for full-time residency.

Action required
Part C Medicare Advantage

If you're on a Medicare Advantage plan, switch to Original Medicare before you leave — during Open Enrollment (Oct 15–Dec 7). Advantage plans can auto-disenroll you after 6 months abroad. Switch on your terms, not theirs.

Keep with caution
Part D Keep with caution

Covers nothing in Spain — you'll pay out of pocket for medications. Convenio Especial (the public pay-in scheme) doesn't cover prescriptions either. But dropping Part D triggers its own late enrollment penalty. Keep it unless you have a clear plan for prescriptions.

For a full explanation of the Medicare parts, penalties, and the Advantage trap — read the Medicare guide.

Spain's Health System — What You Can Access

Spain's Sistema Nacional de Salud (SNS) is one of Europe's better public systems. But Non-Lucrative Visa holders are not automatically enrolled, and you can't access the public pay-in pathway — the Convenio Especial — until after your first full year of legal residency. Year one is entirely on private insurance.

Convenio Especial — SNS Access After Year One

After 12 months of continuous legal residency, you can apply to pay into the SNS via the Convenio Especial — a monthly contribution scheme run by each autonomous community. It's the most cost-effective long-term healthcare option for retirees who qualify after year one, and unlike Spanish private insurers, it has no age caps and no exclusions for pre-existing conditions.

Convenio Especial costs (2026)
Under age 65 ~€60/month
Age 65 and over ~€157/month
Pre-existing conditions No exclusions
Prescription drugs Not covered — full retail
Dependent coverage Each adult enrolls separately

No exclusions for pre-existing conditions — a major advantage over private insurers

No copays once enrolled

Not available until after 1 year of continuous legal residency

Prescriptions not covered — you pay full retail at pharmacies

Specialist waits can be long for non-urgent care

Source: Ministerio de Sanidad — Convenio Especial

Your Insurance Options in Spain

The NLV requires private health insurance before you can apply — and that insurance must have zero copayments, zero deductibles, and coverage equivalent to the SNS. Standard plans with any cost-sharing don't qualify. You need to shop specifically for NLV-compliant coverage.

Local Spanish private insurance (NLV-compliant)

~€150–350/month at 65

Spanish insurers Sanitas, Adeslas, DKV, ASISA, and ASSSA all publish NLV-compliant plans with zero copayments. Consulates recognize their certificate formats on sight — which reduces the most common source of processing delay.

Certificate formats familiar to consulates — fewer delays

Can be purchased from abroad before you arrive

New enrollment age caps: typically 65–68 (Sanitas higher; Adeslas and ASISA lower)

Pre-existing conditions subject to moratorium periods (see callout below)

Spain only — if you visit France or fly home to see family, you're paying out of pocket

Heads up — pre-existing conditions work differently here

Spanish insurers use full medical underwriting, not moratoriums — they decide what's covered (or excluded) upfront when you apply, not after a waiting period. Sanitas Más Salud Complete is the main mainstream option that covers pre-existing conditions on NLV-compliant terms for ages 0–75. Policies arranged through a licensed broker can often secure coverage with waiting periods waived. Emergency care is always covered regardless of your underwriting outcome.

Get a written quote 60+ days before submitting your NLV application — coverage is decided up front, so you want to know exactly what's included before you commit. International plans (Cigna Global, IMG Global) are an alternative if local insurers decline or surcharge heavily, but they apply their own underwriting at 65 too.

The age cap is the binding constraint, not the price

Adeslas and ASISA typically cap new enrollment at age 65; Sanitas at around 68. Retirees approaching those ages should secure a plan before hitting the cutoff — even if you're not yet planning the move. Existing customers can usually renew past these ages.

International health insurance

~€200–400/month at 65

International plans from Cigna Global, IMG Global, GeoBlue, and Allianz Care are worth considering if you're above the local enrollment age cap, have pre-existing conditions Spanish insurers will exclude, or want coverage that travels with you — including back to the US.

Covers you globally, including the US

Medical evacuation included on most plans

Portable if you later move countries

English-language customer service and claims

More expensive than local Spanish coverage

Best fit: above the local enrollment age cap, pre-existing conditions Spanish insurers will exclude, or wanting global portability.

See which plans meet Spain's NLV no-copay requirement →

Getting There — The Non-Lucrative Visa

Not planning to live in Spain full-time?

Most US retirees experience Spain as tourists first — up to 90 days in any 180-day window under the Schengen tourist allowance, no visa required. No income bar, no insurance mandate, no residency commitment. That's the snowbird path. The trade-off: no access to the Spanish public health system on tourist status — you'll need travel insurance, not residency insurance, and your Medicare still covers nothing here. Snowbird guide → · Perpetual traveler guide →

The Non-Lucrative Visa below is for retirees ready to make Spain their primary base — which means committing to 183+ days per year in-country, minimum.

Spain has no dedicated retirement visa. The Non-Lucrative Visa (NLV, Visado de residencia no lucrativa) is the standard path — designed for people who can support themselves on passive income without working in Spain. The income threshold is the highest of any major European retirement visa.

Non-Lucrative Visa — at a glance
Minimum income (primary applicant) €28,800/year (2026)
Per additional dependent +€7,200/year each
Days required in Spain 183+ days/year
Initial permit duration 1 year
Renewal 2-year periods
Permanent residency After 5 years
Citizenship eligibility 10 years (US citizens)

Passive income only — and proof of retirement

Social Security, US pensions, annuities, dividends, and rental income qualify. Employment income, freelance, and remote work don't. Many consulates — including Los Angeles — now require a termination letter from your prior employer or an official retirement certificate to prove you have ceased working before applying.

The insurance requirement that gets applications denied

The NLV requires private health insurance with no copayments, no deductibles, no waiting periods, and no coverage limits. Plans with any cost-sharing — even €10 per GP visit — can get your application rejected. This is the most common reason NLV applications fail.

Verify that your certificate says "sin copago, sin franquicia" explicitly before submitting. Both Spanish local insurers (Sanitas, Adeslas, DKV, ASISA) and international insurers (Cigna Global, IMG Global) issue NLV-compliant certificates. Spanish insurer certificates are often faster to process because consulates recognize the format on sight.

One thing that rules out NLV snowbirding: the visa requires 183+ days per year in Spain (RD 1155/2024, in force May 2025). If you want shorter trips without committing to residency, the Schengen 90/180 tourist path described above is the alternative — no visa, no income bar, but no public healthcare access.

Social Security & Taxes in Spain

The US and Spain have had a totalization agreement since 1988 — your Social Security benefit arrives in full and you won't pay into both countries' systems at the same time. The tax side is more nuanced. The US–Spain treaty (signed 1990, updated by the 2013 Protocol) draws sharp distinctions between income types — and where you land depends entirely on which income you're drawing.

Your SS benefit arrives in full — no reduction for living abroad

No double Social Security taxation — the totalization agreement prevents it

How the treaty divides your income

US Social Security Exempt from Spanish tax — US side only (Article 20(1)(b))
US Government / Military pensions Exempt from Spanish tax — US side only (Article 21)
Private pensions, 401(k), Traditional IRA Taxed in Spain at progressive IRPF rates (19%–47%+)
Roth IRA / Roth 401(k) Taxed in Spain as savings income — growth portion only

What This Actually Costs You

Run the numbers on a typical scenario: $2,000/month Social Security, fully relocated to Madrid, no other income.

Tax on $2,000/month SS income — Madrid, 2026

Illustration
Starting SS income $2,000/month ($24,000/year)
US federal tax (below $25k MFJ threshold) $0
Converted to euros (USD/EUR ~1.08) ≈ €22,200/year
Spain treatment of US Social Security Exempt — Article 20(1)(b)
Exemption-with-progression effect (no other taxable income) None
Spain IRPF on SS income €0
After-tax income (MFJ) $24,000/year ($2,000/month)

What you keep

Spain IRPF on Social Security €0/month
US federal tax $0 (MFJ)
Take-home $2,000/month — no tax at any level

Worth knowing: the exemption-with-progression catch

The SS exemption sounds like a clean win — but Spain still counts your Social Security when calculating which bracket applies to your other income. Add IRA withdrawals, and Spain taxes them as if all your income were taxable. The more SS you receive, the higher the bracket your IRA draws fall into. Single filers with $24,000 SS and no other income also owe approximately $540/year in US federal tax (the lower single-filer standard deduction exposes a portion of SS).

What does that look like with IRA income in the mix?

Tax on $40K SS + $40K IRA — Madrid, 2026

Illustration
Social Security income $40,000/year (≈ €37,000)
IRA / 401(k) withdrawals $40,000/year (≈ €37,000)
Spain treatment of SS Exempt — Article 20(1)(b)
Exemption-with-progression: Spain rates IRA income (as if €74,000 were all taxable) ~32% effective rate on IRA
Spain IRPF on IRA (€37,000 × ~32%) ≈ €12,000 (~$13,000)
US federal tax on IRA (Form 1116 FTC typically offsets) ~$0–$1,000 after FTC
US federal tax on SS (85% taxable at this income level) ~$5,500
Total tax bill (Spain + US combined) ~$18,500–$19,500
After-tax take-home ~$60,500–$61,500 of $80,000

This example is illustrative only. Tax treatment depends on your full income picture, residency status, and current US–Spain tax treaty interpretation. Consult a US–Spain expat CPA before making decisions. Figures use 2026 rates; sources: PwC Spain and Agencia Tributaria.

Retirement Account Treatment — IRA, 401(k), and Roth

Honestly, Spain hits US retirement accounts harder than almost any other European country — here's why. The 1990 treaty pre-dates the Roth IRA (created 1997) and doesn't address it. Spain defaults to taxing Roth growth as savings income, and there's no special pensioner regime that softens the blow — the Beckham Law requires active employment, not pension income, so retirees don't qualify.

Traditional IRA / 401(k)

Taxed in Spain at progressive IRPF rates

Distributions are taxed as ordinary income under the US–Spain treaty — at the general-base IRPF brackets starting at 19%, rising to 47%+ depending on your total income and autonomous community. Spain doesn't recognize US tax deferral; the full distribution is taxable in the year received.

One narrow exception: if you structured your IRA or 401(k) as a true lifetime annuity (not flexible draws) before beginning distributions, a portion may qualify for a lifetime-annuity exclusion. Lump sums and flexible withdrawals don't qualify.

The Foreign Tax Credit (US Form 1116) typically offsets parallel US tax — you're generally not double-taxed. But Spain is usually the higher-rate jurisdiction for IRA withdrawals.

Roth IRA / Roth 401(k)

Growth taxed as savings income — contributions returned tax-free

Spain doesn't recognize Roth's US tax-free status. Spanish authorities classify Roth distributions as savings/investment income — taxed at the savings-base rates: 19% (first €6,000), 21% (€6,000–50,000), 23% (€50,000–200,000), up to 30% over €300,000.

The silver lining: only the growth portion is taxed. Return of your after-tax contributions isn't taxed. But the burden of proof is on you — maintain documentation of your contribution basis.

Example

A $200,000 Roth that's 50% contributions and 50% growth, withdrawn entirely in one year: roughly $100,000 (≈€92,000) is treated as Spanish savings income. Estimated tax: approximately €19,000 (~$20,500) — on what would be $0 in the US.

The planning window — convert before you move

Pre-residency Roth conversions and withdrawals completed in the calendar year before you become a Spanish tax resident are the most powerful tax lever available. Once you're a Spanish tax resident, every dollar of Roth growth you withdraw is a savings-income event. Roth balances left inside the account post-move aren't taxed annually by Spain — only when distributed. → More on Roth IRAs abroad

Wealth Tax & Modelo 720 — Two Surprises for American Retirees

Neither of these is an income tax, but both affect high-asset retirees in ways most US-focused guides don't cover.

Wealth Tax (Impuesto sobre el Patrimonio)

Annual tax on net worth above €700,000 (plus up to €300,000 for a primary residence). Madrid and Andalucía apply a 100% regional bonification — effectively zero wealth tax. But the Solidarity Tax on Large Fortunes was made permanent in late 2024 and overrides those regional bonifications entirely for net worth above €3 million. Rates: 0.2% on €3M–€5M, 0.5% on €5M–€10M, 1.5% on €10M+, up to 3.5% at the top. Madrid isn't the wealth-tax haven it used to be for high-net-worth retirees.

Net worth under €1M and settling in Madrid or Andalucía? This likely doesn't affect you. Above €3M? Consult a cross-border tax attorney before choosing your autonomous community — the Solidarity Tax makes this a meaningful financial decision.

Modelo 720 — Foreign Asset Declaration

Annual informational declaration of foreign assets exceeding €50,000 in any of three categories: bank accounts, securities/investments, or real estate. Filed January 1–March 31 for the prior year's December 31 balances. No tax is owed on the filing itself — it's informational. But failure to file carries penalties.

Your Traditional IRA, Roth IRA, 401(k), and US brokerage accounts all count toward the threshold. Most US retirees with meaningful retirement savings trigger Modelo 720 from their first year of Spanish residency.

Post-2022 EU court ruling, penalties have been normalized (~€20 per item, max €20,000 cap). Source: Spainguru's 2026 Modelo 720 guide.

Spain's tax picture — exemption-with-progression, Wealth Tax, Modelo 720, and how your IRA distributions interact with the US–Spain treaty — is one of the more complex in Europe for US retirees. A cross-border CPA can model your full scenario before you apply for the NLV.

Talk to a TFX Spain tax specialist →

Figures on this page reflect 2026 data. Always verify current visa income requirements, insurance costs, and healthcare fees before making decisions.

Sources

Your next step

Three things to do, in this order.

  1. Confirm your income clears €28,800/year

    Add up Social Security, pensions, dividends, and rental income. That passive-only total must hit the NLV threshold. If you're close, a cross-border financial planner can help restructure income sources before you apply.

  2. Lock in NLV-compliant health insurance

    Get a policy with zero copayments and zero deductibles — confirmed in writing on the certificate. If you're approaching 65–68, securing a plan now (before you hit enrollment age caps) is more urgent than the move timeline.

  3. Talk to a US–Spain cross-border CPA before you move

    Spain's tax treatment of IRAs, Roth accounts, and the exemption-with-progression rule on Social Security has real dollar consequences. Pre-residency Roth conversions and drawdowns are the highest-leverage move available — but only before you become a Spanish tax resident.

    Find a US–Spain expat CPA → (opens in new tab)

Find a plan that meets Spain's NLV no-copay, no-deductible requirement

Your Non-Lucrative Visa application depends on the right insurance — Spanish consulates reject plans with any copayment or deductible, and coverage must be active before the appointment, not after. See which international plans qualify and cover you on visits back home.

See which plans meet Spain's NLV requirement
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