Quick Answer: The Spain-Israel double tax treaty (signed November 30, 1999; in force December 31, 2000) caps withholding on dividends at 10% in both directions — against Israel's domestic 25% and Spain's domestic 19%. Interest is likewise capped at 10% on both sides. Royalties are capped at 5% for artistic and scientific copyrights and the use of scientific equipment, and at 7% for all other categories including industrial patents, trademarks, and software know-how. Unlike many other Israeli tax treaties, the Spain-Israel treaty applies a single flat 10% dividend rate to both individuals and companies regardless of ownership percentage. To benefit on Israeli-source payments, Spanish recipients need a *nikui memas mekorot* reduced-rate certificate from the Israel Tax Authority before any dividend or royalty is paid.

Spain and Israel are more economically entangled than most people realize. Israeli tech companies use Barcelona and Madrid as their European bases. Spanish private equity funds invest regularly in Tel Aviv startups. And since 2015, tens of thousands of Israelis have obtained Spanish citizenship through the Sephardic repatriation programs. All of those relationships generate cross-border income — dividends from Israeli subsidiaries, royalties on IP licences, interest on intercompany loans — and without the treaty, all of it would get taxed twice.

The treaty has been in place for over two decades, long enough that many practitioners treat it as routine. It is not. Israel's reduced rates are not self-executing: the Israeli company paying a dividend or royalty withholds at 25% unless it holds a valid certificate from the Israel Tax Authority. Spain similarly withholds at 19% on dividends unless the Spanish company has documentation in place to apply the lower rate at source. Getting the paperwork right before the payment — not six months after — is what separates receiving 90% of what the treaty entitles you to from spending a year filing for a refund.

1. Treaty Overview

The Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion between the State of Israel and the Kingdom of Spain was signed in Jerusalem on November 30, 1999, accompanied by a Final Protocol signed on the same date. The treaty entered into force on December 31, 2000. No comprehensive renegotiation has taken place since; modifications have come through the Multilateral Convention (MLI) rather than bilateral amendment.

The treaty covers the following Israeli taxes: income tax under the Income Tax Ordinance 5721-1961, capital gains tax within that ordinance, and *mas shevach* (land appreciation tax) on Israeli real property under the Land Appreciation Tax Law 5723-1963. On the Spanish side, it covers the *Impuesto sobre la Renta de las Personas Físicas* (IRPF, personal income tax), the *Impuesto sobre Sociedades* (IS, corporate income tax), and the *Impuesto sobre la Renta de No Residentes* (IRNR, non-resident income tax), as well as the municipal surcharges applied in Spain.

Key withholding rates at a glance:

  • Dividends (Israel to Spain): 10% — all shareholders, individuals and companies equally; Israel's domestic rate of 25% under Section 170 of the Income Tax Ordinance applies without a valid reduced-rate certificate
  • Dividends (Spain to Israel): 10% — Spain's domestic IRNR rate of 19% applies unless the Spanish company applies the treaty rate at source or the Israeli recipient claims a refund via Modelo 210
  • Interest: 10% ceiling in both directions; Israel's domestic rate varies from 15% to 25%; Spain's IRNR rate is 19%
  • Royalties (artistic/scientific copyrights, scientific equipment): 5% ceiling
  • Royalties (all other — patents, trademarks, software, know-how): 7% ceiling
  • Capital gains on Israeli real property: taxed in Israel under *mas shevach* regardless of the seller's country; the treaty does not override Israel's land appreciation tax

Both Spain and Israel signed the OECD Multilateral Convention (MLI) in June 2017. Israel ratified in September 2018 (effective January 1, 2019 for Israeli-covered treaties); Spain ratified in June 2021 (effective January 1, 2022 for Spanish-covered treaties). The MLI has introduced anti-avoidance rules and modified the permanent establishment article — both of which affect how Spanish and Israeli structures interact under this treaty.

2. Dividend Withholding Rates

The Spain-Israel treaty uses a single flat 10% ceiling on dividends, full stop. It does not matter whether the recipient is an individual or a company, and it does not matter whether the recipient holds 1% or 100% of the paying company's capital. This is worth knowing because many Israeli treaties do have a reduced corporate rate. The Switzerland treaty offers 5% to Swiss companies with a 25% stake. The Germany treaty drops to 5% for qualifying German companies with 10% or more. The Spain treaty does none of that. 10% is the floor, and it is the same for everyone.

Israeli dividends paid to Spanish residents

Israel's domestic withholding rate on dividends paid to non-resident shareholders is 25% under Section 170 of the Income Tax Ordinance (rising to 30% in certain cases involving controlling shareholders or related-party transactions). The treaty reduces this to 10% for any Spanish tax resident who is the beneficial owner of the dividend.

The reduced rate is not automatic. The Israeli company must withhold at 25% unless it holds a valid *nikui memas mekorot* (reduced-rate withholding certificate) issued by the Israel Tax Authority under Section 170. Applying for the certificate requires submitting documentation to the ITA's International Tax Department, Withholding Tax Unit, at least 30 to 45 business days before the intended payment date. Without the certificate, 25% goes to the ITA and the Spanish recipient spends the next 12 to 18 months trying to get it back through an Israeli annual tax return — a process that is entirely avoidable with a little planning.

In Practice: A Spanish investment fund holds 15% of an Israeli medical-technology company listed on the Tel Aviv Stock Exchange. The Israeli company resolves to pay a NIS 400,000 dividend. At the domestic 25% rate, Israeli withholding is NIS 100,000. At the 10% treaty rate — available immediately because the Spain-Israel treaty has no minimum holding period for the reduced rate — withholding drops to NIS 40,000. The fund's Israeli representative submits a *nikui memas mekorot* application to the ITA International Tax Department in Tel Aviv at least 45 business days before the dividend payment date, attaching a Spanish fiscal residency certificate (*Certificado de Residencia Fiscal*) issued by the AEAT and apostilled, a beneficial ownership declaration, and the fund's shareholding documentation. The ITA processes routine applications within 30 to 45 business days. The certificate is valid for 12 months and must be renewed before each subsequent dividend.

Spanish dividends paid to Israeli residents

Spain's domestic IRNR rate on dividends paid to non-resident investors is 19%. The treaty reduces this to 10% for Israeli tax residents who are the beneficial owners of the dividend. Spanish companies can apply the 10% rate at source — provided they hold documentation confirming the recipient's Israeli tax residency — or withhold at the full 19% and require the Israeli recipient to claim a refund.

Israeli investors who receive Spanish dividends with 19% withheld can reclaim the excess 9% by filing a Modelo 210 (Solicitud de devolución) with Spain's Agencia Tributaria (AEAT). The form is submitted through the AEAT's *Sede Electrónica* (online portal) or in paper form, with the following attachments: an Israeli tax residency certificate from the Israel Tax Authority (obtainable under Section 105 of the Income Tax Ordinance within 10 to 15 working days), the Spanish dividend statement or bank confirmation showing the withholding, and a completed Modelo 210. Spanish law allows four years from the end of the calendar year of payment to file the claim; missing the deadline forfeits the refund.

In Practice: An Israeli high-net-worth individual holds shares in a Spanish renewable energy company through a Spanish brokerage account. A EUR 25,000 dividend is paid; the brokerage withholds EUR 4,750 (19% IRNR). Under the treaty, the Israeli resident is entitled to a maximum 10% Spanish withholding (EUR 2,500), making EUR 2,250 refundable. The Israeli investor files a Modelo 210 through the AEAT's Sede Electrónica before December 31 of the fourth year following payment, attaching an ITA-issued Israeli tax residency certificate and the dividend statement. The AEAT typically processes straightforward refund claims within three to five months. Israel then taxes the net dividend — after crediting the remaining EUR 2,500 Spanish tax — under the Israeli savings income scale at 25%.

3. Interest and Royalties

Interest is capped at 10% in both directions. Israel's domestic rate on interest to non-residents runs from 15% to 25% depending on the instrument and the parties involved; the 10% rate requires an ITA reduced-rate certificate. Spain's IRNR on interest is 19%; the treaty brings it down to 10%, applied at source or recovered through a Modelo 210 refund.

Royalties split into two tiers. Payments for copyrights of literary, artistic, or scientific works, and for the use of scientific equipment, are capped at 5%. Everything else — patents, trademarks, designs, secret formulas, industrial processes, software know-how — is capped at 7%. Israel withholds 15% to 25% domestically on royalties to non-residents; Spain charges 24% to non-EU recipients. The gap between those domestic rates and the 5%/7% treaty ceilings is wide enough that skipping the certificate paperwork is a genuinely expensive mistake.

In Practice: An Israeli cybersecurity startup licences its proprietary threat-detection software to a Spanish telecommunications company under a three-year agreement at EUR 300,000 per year. Without an ITA Section 170 reduced-rate certificate, the Spanish company applies Spain's domestic 24% IRNR withholding on royalties (EUR 72,000 per year). Software know-how falls under the "other" royalty category — the 7% treaty rate applies, not the 5% rate reserved for artistic and scientific copyrights. With the treaty rate, Spanish withholding is EUR 21,000 per year. The Israeli licensor submits a Modelo 210 to reclaim the excess EUR 51,000 each year, or — more practically — supplies the Spanish company with an ITA residency certificate and a beneficial ownership declaration allowing the 7% rate to be applied at source from the next payment. The four-year statute of limitations under Spanish law means royalties withheld at 24% as recently as 2022 may still be recoverable.

4. Capital Gains and the Mas Shevach Question

The treaty follows the standard OECD position on real property: Israel keeps full taxing rights over Israeli land regardless of where the seller lives. Gains on Israeli apartments, commercial buildings, and agricultural land registered in the Land Registry (*Tabu*) are subject to *mas shevach* (land appreciation tax) under the Land Appreciation Tax Law 5723-1963. A Spanish resident selling an Israeli apartment owes *mas shevach* to Israel; the treaty does not change that. Rates run from 0% to 25% depending on acquisition date and property type.

The same logic applies to shares in Israeli companies whose assets are principally real estate. Owning an Israeli apartment block through an Israeli company and then selling the shares does not convert a property gain into a treaty-protected share sale. The ITA treats the transaction as a land disposal for *mas shevach* purposes, and has been auditing these structures more aggressively since the MLI entered force.

Ordinary Israeli company shares are a different matter. A Spanish resident selling shares in an Israeli software or tech company generally owes no Israeli capital gains tax, provided less than 50% of the Israeli company's assets are Israeli real estate. Spain taxes that gain under IRPF or IS at the savings income scale (19%–26% for individuals). Israel does not tax the exit.

In Practice: A Spanish resident invested EUR 80,000 in an Israeli agritech startup in 2020. By mid-2026 the shares are worth EUR 600,000. She is considering relocating to Israel and qualifying for the 10-year new-immigrant tax exemption before selling. If she sells while a Spanish tax resident, Spain taxes the EUR 520,000 gain under the savings scale: 19% on the first EUR 6,000, 21% on the next EUR 44,000, 23% on the next EUR 150,000, and 26% on the remainder — generating approximately EUR 128,000 in Spanish IRPF. If she establishes Israeli residency first, Israel exempts the foreign-source capital gain during the 10-year exemption period (Section 14 of the Income Tax Ordinance). The timing of departure from Spain also triggers Spain's exit tax (Article 95.bis of the IRPF Law) on unrealized gains if her total financial-asset value exceeds EUR 4 million — a threshold she should confirm with a Spanish tax advisor before booking her flight.

5. Residency, Tie-Breaker Rules, and Dual Spanish-Israeli Nationality

Treaty residence for individuals is determined by a four-step tie-breaker when both countries could claim someone as a tax resident:

  1. Permanent home: where does the individual have a permanent home available to them? If only in one country, that country is the treaty residence.
  2. Centre of vital interests: where are personal and economic ties closer — bank accounts, employment, family, habitual daily life?
  3. Habitual abode: which country does the individual spend more time in?
  4. Nationality: if still unresolved, the country of citizenship. Where the person holds both Spanish and Israeli nationality, a mutual competent authority agreement between the Israeli Tax Authority and Spain's AEAT is required.

The dual nationality question is not hypothetical. Tens of thousands of Israelis applied for Spanish citizenship through Law 12/2015 (the Sephardic law) and, after its closure in 2019, through the extended program under the Law of Democratic Memory of 2022. Many of them now hold both passports. For someone who clearly lives in Israel — no Spanish home, no Spanish bank accounts, family in Israel — the tie-breaker resolves at step one. The dual passport alone creates no Spanish tax liability.

The harder case is someone who genuinely splits time: a property owner in Barcelona, a frequent business traveler, someone with family in both countries. There the tie-breaker analysis requires real documentation. Both the ITA and the AEAT can request evidence of center of vital interests — bank statements, phone records, school enrollment, utility bills. The ITA has specifically expanded its center-of-life audits targeting Israelis claiming foreign residency since 2021.

6. Israeli Olim from Spain and the Beckham Law Interaction

Israelis making aliyah from Spain

Spanish nationals who make aliyah and become Israeli residents benefit from the 10-year new-immigrant exemption under Section 14 of the Income Tax Ordinance. During the exemption period, Israeli tax does not apply to foreign-sourced income: Spanish dividends, interest from Spanish bank accounts, rental income from Spanish property, and capital gains from Spanish company shares are all outside the Israeli tax net for a decade from the date of arrival.

During the exemption, a Spanish oleh does not generally need to invoke the treaty to protect Spanish-source income — Section 14 already blocks Israeli tax. Spain continues to levy its own taxes on Spanish-source income (IRNR on dividends and interest at 19%, with the treaty capping these at 10%), but those payments to Spain are not creditable against an Israeli liability that does not exist during the exemption.

From January 1, 2026, new olim must file annual Israeli tax returns disclosing worldwide income and foreign assets, even when the income is fully exempt under Section 14. This obligation covers Spanish bank accounts, investment portfolios held through Spanish brokerages, beneficial interests in Spanish companies, and any Spanish property. Failure to file carries penalties under Section 216 of the Income Tax Ordinance ranging from NIS 500 per month for a late return to NIS 9,570 for wilful non-reporting of a foreign account. The Section 14 exemption itself is unaffected; only the reporting obligation is new.

In Practice: A Spanish national of Sephardic descent makes aliyah in July 2026. She holds a Spanish portfolio generating EUR 18,000 in dividends from Spanish companies annually. Spain withholds 19% IRNR (EUR 3,420) on each dividend. Under the treaty, the Israeli resident is entitled to a 10% cap (EUR 1,800); she can reclaim EUR 1,620 per year from AEAT via Modelo 210. No Israeli income tax applies on the EUR 18,000 during the 10-year Section 14 exemption. However, she must file an Israeli annual tax return for 2026 within 90 days of becoming an Israeli resident, disclosing the Spanish portfolio and dividend income. She retains an Israeli attorney to prepare the return and files via the ITA's online portal (Shaam Online). The Modelo 210 refund application to AEAT is filed separately through the Sede Electrónica.

Israeli expats moving to Spain — the Beckham Law

Israelis who relocate to Spain for work may qualify for Spain's special impatriates regime, widely known as the Beckham Law after the footballer who first brought it to public attention (*Régimen Especial de Trabajadores Desplazados*, Article 93 of the Spanish IRPF Law). The key features:

  • Available to individuals who become Spanish tax residents for the first time, or after five or more years as non-residents
  • Employment income from Spanish sources: flat 24% IRPF rate on amounts up to EUR 600,000 per year (47% on the excess) — substantially below the top progressive rate of 47% that would otherwise apply
  • Investment income (dividends, interest, Spanish and foreign capital gains): taxed under the Spanish savings income scale at 19%–26%, not under the flat 24% employment rate
  • Foreign employment income may be excluded from Spanish tax where certain conditions are met, but this interacts with Spanish domestic rules and cannot simply be asserted without analysis
  • Duration: six tax years, including the year of arrival

The interaction between the Beckham Law and the treaty requires analysis before you move, not after. An Israeli moving to Spain under the Beckham regime becomes a Spanish tax resident for treaty purposes, so the treaty tie-breaker applies to their full position. But whether they have also ceased to be an Israeli tax resident depends on whether they have properly filed a departure notification with the ITA under Section 100A of the Income Tax Ordinance. That 90-day notification window matters: if the ITA still considers you an Israeli resident, you are looking at potential Israeli tax exposure on Spanish income alongside your Spanish IRPF, however generous the Beckham rates may be.

In Practice: An Israeli software engineer accepts a position with a Barcelona tech company in February 2026 and moves to Spain, becoming a Spanish tax resident for the first time. She qualifies for the Beckham Law. Her Spanish salary is EUR 150,000 per year; she pays flat 24% IRPF (EUR 36,000) rather than the progressive rates that would reach 43%–47%. She also retains NIS 60,000 in Israeli bank deposits earning interest. As a Spanish tax resident who has notified the ITA of her departure, she is a non-resident in Israel. Her Israeli interest income is subject to Israeli non-resident withholding at 15% under the Income Tax Ordinance; Spain does not tax it under the Beckham regime. She should file her Section 100A departure notification with the ITA (Mas Hachnasah form) within 90 days of leaving Israel to establish her non-resident status and avoid Israeli exit-tax exposure on any Israeli financial assets.

7. MLI Modifications and Substance Requirements

Both Spain and Israel have ratified the OECD Multilateral Convention. Israel's ratification took effect for this treaty from January 1, 2019; Spain's from January 1, 2022. Three MLI changes now live in the Spain-Israel treaty:

Principal Purpose Test (PPT). Treaty benefits can be denied if obtaining those benefits was one of the principal purposes of an arrangement. A Spanish holding company with no employees, no board meetings in Spain, and no genuine commercial activity — set up purely to receive Israeli dividends at 10% instead of 25% — is exactly what the PPT targets. Both the AEAT and the ITA have hardened their anti-avoidance positions since the MLI entered force. Real substance means actual Spanish-based directors with signing authority, board minutes from meetings that happened in Spain, and a Spanish bank account used for treasury activity. A registered address is not enough.

Permanent establishment risk. The MLI broadened the PE definition to catch commissionnaire arrangements and closely related enterprises. A Spanish company whose Israeli employees habitually conclude contracts on the company's behalf in Israel — or who maintain inventory there — may already have a permanent establishment in Israel. Profits attributed to that PE are taxable at 23% Israeli corporate tax, with no treaty protection. The ITA has been auditing Spanish tech companies with Israeli R&D teams since 2022 specifically for PE exposure. A carefully drafted service agreement that keeps Israeli staff out of commercial contracting authority reduces the risk, but it does not eliminate it.

Anti-fragmentation rule. Spanish companies cannot avoid PE exposure by splitting their Israeli operations across multiple related entities. Under the MLI, each entity's Israeli activities are assessed together with those of closely related enterprises.

In Practice: A Spanish media conglomerate owns 100% of an Israeli digital advertising startup through a Madrid holding company. The Madrid holding has one director, no employees, and no Spanish bank account. The ITA, reviewing the holding company's application for a reduced-rate certificate before an NIS 2,000,000 dividend, applies the PPT: the Madrid holding exists solely to own the Israeli company, and obtaining the 10% treaty rate rather than the domestic 25% was a principal purpose of the structure. The ITA denies the certificate, withholding at 25% (NIS 500,000). Had the Madrid holding employed a real director in Spain, maintained a Spanish bank account handling group treasury, and held board meetings in Madrid with documented minutes, the PPT analysis would likely have favored the applicant. Retrofitting substance after the fact does not cure a denial; ITA PPT decisions must be contested through the assessment objection process under Section 150 of the Income Tax Ordinance.

8. ITA Certificate Process and the AEAT Refund Procedure

The two parallel procedures — obtaining a reduced-rate certificate from the ITA for Israeli payments, and reclaiming excess Spanish withholding from the AEAT — operate independently and both require planning well before any payment date.

Obtaining an ITA reduced-rate certificate for Israeli dividends and royalties

  1. Prepare the documentation. You need: a *Certificado de Residencia Fiscal en España* issued by the Agencia Tributaria, apostilled by Spain's Ministry of Justice and translated into Hebrew by a certified translator; proof of ownership and the nature of the payment (shareholding extract from the Israeli Registrar of Companies or a copy of the royalty agreement); a beneficial ownership declaration confirming the Spanish entity is not a conduit for third-country residents; and, for royalties, a description of the intellectual property and the basis for the contractual rate.
  2. Submit the application. An Israeli licensed attorney or CPA submits the application to the ITA International Tax Department, Withholding Tax Unit, at the relevant assessing office (typically the Large Enterprises Assessing Office in Tel Aviv for payments by larger Israeli companies). Submissions are made in Hebrew with attached translations.
  3. Wait for the certificate. Routine applications — straightforward shareholder structures, no related-party complexity, no real-estate-rich balance sheet — take 30 to 45 business days. Applications triggering PPT review or involving trust or partnership structures take two to four months. Submit well before any planned payment.
  4. Provide the certificate to the Israeli paying company. The company retains it and withholds at the certified rate. Certificates typically run for 12 months and must be renewed annually before the next payment cycle.

Recovering excess Spanish withholding via Modelo 210

When Spain withholds at the domestic IRNR rate (19% on dividends and interest, 24% on royalties) rather than the treaty rate, Israeli recipients recover the excess by filing a Modelo 210 (*Solicitud de devolución*) with the AEAT. Key points:

  • Filing channel: the AEAT's Sede Electrónica (electronic office) allows online submission with a digital certificate; paper filing is possible at the AEAT's non-resident tax offices
  • Required attachments: ITA-issued Israeli tax residency certificate (Section 105 of the Income Tax Ordinance; obtainable in 10 to 15 working days); the Spanish dividend, interest, or royalty notice showing the gross payment and amount withheld; a completed Modelo 210 with a Spanish tax identification number (*NIE* or *NIF*) for the Israeli recipient
  • Statute of limitations: four years from the end of the calendar year in which the income was paid; this deadline is strict and non-extendable
  • Processing time: straightforward applications are typically resolved within three to six months; complex cases take longer
  • Refund method: the AEAT transfers the refund to the Spanish bank account provided in the Modelo 210; Israeli recipients with no Spanish bank account may need to open one or arrange transfer through a Spanish representative
In Practice: An Israeli technology holding company receives a EUR 120,000 dividend from its Spanish subsidiary in 2025. The Spanish subsidiary applies the domestic 19% IRNR withholding (EUR 22,800) because no treaty documentation was in place. The Israeli company is entitled to the 10% treaty rate (EUR 12,000 maximum), making EUR 10,800 refundable. The Israeli company engages a Spanish tax representative who obtains an Israeli tax residency certificate from the ITA within 12 working days, acquires a Spanish *NIF* (tax identification number) for the Israeli entity from the AEAT, and files a Modelo 210 through the Sede Electrónica before December 31, 2029 (four-year deadline from December 31, 2025). The AEAT approves the refund within approximately five months and transfers EUR 10,800 to the Spanish representative's client account. For the next dividend, the Israeli company proactively supplies the Spanish subsidiary with the ITA residency certificate and a beneficial ownership declaration, allowing the 10% rate to be applied at source and eliminating the need for a refund.

Frequently Asked Questions

Tax residence is determined by where you actually live, not by which passports you hold. If you live and work in Israel — Israeli home, Israeli employer, family in Israel — you are an Israeli tax resident even if you also hold a Spanish passport. The treaty's four-step tie-breaker applies only when both countries can genuinely claim you as a resident: you have a permanent home available in Spain, you spend significant time there, and both countries have a plausible claim. Most dual Spanish-Israeli nationals who obtained Spanish citizenship through the Sephardic programs and continue living in Israel are straightforwardly Israeli tax residents. The dual passport does not itself create Spanish tax liability.

Yes. As an Israeli tax resident, the treaty caps your Spanish withholding on dividends at 10%. The excess 9% is refundable by filing a Modelo 210 with the Agencia Tributaria. You need a Spanish NIE or NIF tax number, an Israeli tax residency certificate from the Israel Tax Authority (takes 10 to 15 working days), and the bank statement showing the withholding. The four-year statute of limitations runs from December 31 of the year in which the dividend was paid. Spanish law is strict on this deadline and there is no general discretion to extend it.

Software know-how and licensing fees fall under the "other royalties" category: 7% under the treaty, not the 5% rate reserved for artistic and scientific copyrights. Spain's domestic IRNR rate on royalties to non-EU non-residents is 24%, so the treaty saves a significant amount. The Spanish company can apply the 7% rate at source if it holds your Israeli tax residency certificate and a beneficial ownership declaration; otherwise it withholds at 24% and you reclaim the excess 17% via Modelo 210 within four years. The Israeli licensor can also apply to the ITA for a reduced-rate certificate, which matters if the structure involves royalties flowing in both directions.

Not automatically. Moving to Spain and becoming a Spanish tax resident does not by itself terminate your Israeli tax residency — the ITA determines residency based on where your center of life is. If you genuinely relocated to Spain (moved your family, closed your Israeli bank accounts, rent or sold your Israeli home), you should file a departure notification with the ITA under Section 100A of the Income Tax Ordinance within 90 days of leaving. Failure to notify can lead the ITA to treat you as continuing Israeli resident, exposing you to Israeli tax on Spanish-source income alongside your Spanish IRPF. The Beckham Law and the treaty work together to produce a favorable tax position for genuine relocation; they do not protect dual-residency arrangements.

Yes, on both sides. Israel levies *mas shevach* (land appreciation tax) on gains from Israeli real estate regardless of where the seller lives — that is what the capital gains article in the treaty preserves. Spain, as your country of tax residence, taxes your worldwide gains under Spanish IRPF, but gives credit for the *mas shevach* already paid to Israel, so you should not be taxed twice on the same profit. The credit mechanism requires documentation: you need a receipt for the *mas shevach* paid from the ITA's land taxation offices and must include the foreign tax credit on your Spanish IRPF return. Get Spanish tax advice before the sale rather than after, because the credit calculation can be more complex than it looks.

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