Question
Does Spain recognize the tax-free status of a TFSA (Tax-Free Savings Account) for Canadian expats, or will gains be taxed as regular income?
Answers
These are the responses from Spainguru’s Facebook group members:
“They don’t recognize a TFSA. Which I think creates a real challenge. This means you have to report income from within the TFSA like realized capital gains, interest, and dividends. However, your Canadian institution doesn’t issue any T slips for TFSA activities.”
“It will be treated like a regular capital gain/loss. They don’t recognize the tax-free status. So interest, gains, sale of shares—all taxed as per regular rules for investments, shares, or savings accounts. If you only have a savings account in your TFSA, then it is not too bad, taxed on interest.
However, if you have made large capital gains in investments or shares, it is best to liquidate it before you become a Spanish tax resident. The TFSA will also be included in the modelo 720 and wealth tax calculations.”
“If you are a tax resident in Canada and have large gains in a TFSA, when you withdraw them, they are tax-free. If you don’t withdraw until you are a Spanish tax resident, you will have to pay capital gains tax on it all from inception, like a regular investment.
That’s why I suggest you liquidate the TFSA while still a Canadian tax resident enjoying the gains tax-free. That money can be reinvested in a regular investment account with a higher adjusted cost base (ACB). Alternatively, you can put that money into a more tax-efficient vehicle in Spain, such as a compliant bond or pension plan.”
“Why would I withdraw the whole amount at any point in time? Can’t I just take out incremental amounts and pay the taxes on that small amount? I will be leaving my investments in Canada, not transferring the funds to Spain.” – “Even if you leave your TFSA in Canada, it is fully taxable in Spain. This includes ALL unrealized gains made within the TFSA since its inception. Whatever you do, make sure that within the TFSA, all gains are liquidated and you only have cash when you become a Spanish tax resident.”
Conclusion
According to Spainguru’s Facebook group members, Spain does not recognize the tax-free status of a TFSA. As a result, any gains—whether realized or unrealized—are subject to Spanish capital gains tax once the account holder becomes a tax resident of Spain.
Interest, dividends, and capital gains within a TFSA will be taxed just like any other regular investment.
To avoid significant tax liabilities, some members suggest liquidating the TFSA before establishing Spanish tax residency. This allows the account holder to benefit from Canada’s tax-free withdrawal rules before moving. Others mention tax-efficient alternatives in Spain, such as compliant bonds or pension plans.
It is also important to note that the TFSA must be reported under the modelo 720 (Spain’s foreign asset declaration) and may be subject to Spain’s wealth tax.
This article is based on personal experience and is not financial advice. For Canadian expats moving to Spain, financial planning is essential to minimize unexpected tax burdens. Consulting a tax professional familiar with both Canadian and Spanish tax laws is highly recommended.
