Moving from France to Spain: where and how to declare your income

The situation

Spring 2026. A person moves from France to Spain.
At the time of the move, they receive a salary from France and a French pension.
Two years later, the salary stops and only two French pensions remain.

At first glance, the logic seems simple: you change country, you pay taxes where you live.
In practice, questions arise almost immediately: when does tax residency actually change, do you need to file tax returns in both countries, which income is taxed where, and where unexpected overtaxation can occur.

This case explains the logic step by step — without bureaucratic language, but with a precise understanding of the rules.

Why periods matter more than countries

Taxes are not calculated “by country in general”, but based on your tax residency status at a specific point in time.

Within the same calendar year, one person can fall under the rules of two countries, file two tax returns, and face different taxation mechanisms.

That is why such situations cannot be analysed as a whole. They must always be broken down into periods.

Three periods — three different tax logics

Period 1: January–February 2026
You still live and work in France.
All income is French, and your centre of life is in France.

Tax status: French tax resident.
Taxation is standard and straightforward. This is the simplest part of the case.

Period 2: March 2026–December 2027
You physically move to Spain, settle there, and live your normal life there.
At the same time, salary and pension income continues to come from France.

Tax status: Spanish tax resident.

The key point here is the number of days.
From March to December 2026, you spend 306 days in Spain, well above the 183-day threshold. This is why Spain considers you a tax resident for the entire year 2026, not just for the post-move period.

Period 3: From January 2028 onwards
You continue living in Spain, but the income structure changes.
There is no longer a salary — only two French pensions remain.

Tax status: Spanish tax resident.
Residency does not change, but taxation now depends on the type of pensions rather than on where you live.

When and how tax residency changes

How France looks at it
France focuses on factual circumstances, not on formal dates.
It looks at where you actually live, where your economic interests are, and where your normal life takes place.

From the moment you effectively move and settle in Spain, French tax residency ends.

How Spain looks at it
Spain applies a more formal approach.
If you spend more than 183 days in Spain during the year, or if your centre of vital interests is there, you are considered a Spanish tax resident.

In this case, the condition is already met in 2026, since you live in Spain from March onwards.

If both countries consider you resident
In such cases, the France–Spain double taxation treaty applies.

It uses tie-breaker rules that look in sequence at permanent home, centre of vital interests, habitual residence, and nationality.

In this case, from March 2026 onwards, Spain is the final tax residence.

2026 — the most complex year

The year of relocation is almost always the most complex.
Tax returns are filed in two countries, but for different parts of the same year.

France: final tax return
France requires a final tax return as a departing resident.

• When: May 2027

• What to declare: income received from January to February 2026

If tax continued to be withheld after the move, an overpayment may arise and can be reclaimed.

France may apply the effective rate method: the full annual income is used to calculate the tax rate, but the rate is applied only to the French-source income.

Spain: first tax return
Spain’s tax return covers the same year, but a different period.

• When: April–June 2027

• What to declare: worldwide income received from March to December 2026

This includes both French salary and French pension income for that period.

Where the income is taxed

Under the France–Spain tax treaty:

• Salary is taxed in the country of tax residence (Spain), provided the work is not physically performed in France.

• Private pensions are taxed in the country of residence (Spain).

• Public service pensions may remain taxable in France.

If French tax has already been withheld, Spain applies a tax credit, provided the income is correctly declared.

2027 — the first full year in Spain

From this point on, the situation becomes significantly simpler.

France
A French tax return is required only if:

• tax continues to be withheld in France, or

• there is income that remains taxable in France under the treaty.

In a typical scenario, no French return is required.

Spain
A standard Spanish resident tax return is filed for the full year 2027, usually between April and June 2028.

From 2028 onwards — pensions only

At this stage, the key issue becomes the type of pension.

Private pensions (such as régime général or AGIRC-ARRCO) are taxed in the country of residence — Spain — and no longer declared in France.

Public service pensions may remain taxable in France, with Spain granting a tax credit.

The pension type is determined by the source of payment, not by its name, and should be verified using official pension statements.

Progressive exemption — a hidden effect

Even if income is taxed in only one country, it may still affect the tax rate in the other.

This is known as the progression effect and often comes as a surprise.

For example, France may calculate the tax rate by taking Spanish income into account, but apply that rate only to the French pension. There is no double taxation, but the overall tax burden may be higher than expected.

Important to keep in mind

This case is not about “how to fill in a form”.
It is about how taxes behave when life changes.

Moving countries, earning income from one state, receiving pensions from another — each element is clear on its own. Complexity arises at the intersections: the year of relocation, the change in income structure, the transition to retirement.

In real life, there are almost always small differences: another move date, an additional income source, a specific pension type, a family situation. And it is precisely these “details” that change filing obligations and the final tax outcome.

That is why such cases are not instructions or ready-made answers.
They are a way to see where the risks usually appear, and at which point it makes sense to stop and double-check the analysis.

FAQ

When do I stop being a French tax resident?
From the moment you effectively move and settle in Spain. France looks at factual circumstances, not at the date of a declaration or deregistration.

When does Spain consider me a tax resident?
If you spend more than 183 days in Spain during the calendar year, or if your centre of vital interests is there. In the year of relocation, this often means tax residency for the entire year.

Do I need to file tax returns in both countries in the year of relocation?
Yes. In the year of relocation, tax returns are usually filed in both countries, but for different parts of the same year.

Where is French salary taxed after moving to Spain?
In most cases, in the country of tax residence — Spain — provided the work is not physically performed in France.

Where are French pensions taxed after moving to Spain?
Private pensions are taxed in the country of residence. Public service pensions may remain taxable in France, with a tax credit applied in Spain.

What is the progressive exemption and why does it matter?
It is a mechanism where income taxed in one country is taken into account to calculate the tax rate in another. There is no double taxation, but the effective tax rate can be higher than expected.

What are the most common mistakes when moving from France to Spain?
Not splitting the relocation year into periods, confusing pension types, filing in only one country, or ignoring the progression effect.