Mbappé vs Beckham: two different instruments, and in practice you choose one

Comparison of the Beckham regime (Art. 93 LIRPF) and the so-called Mbappé Law (Art. 17 bis of Madrid Legislative Decree 1/2010): requirements, effects and why they cannot be applied together.

Beckham regime (Art. 93 LIRPF)

Advantages

  • ✓ 24% on the taxable base up to €600,000 and 47% above (Art. 93.2 LIRPF)
  • ✓ Foreign-source income generally not taxed in Spain during the regime
  • ✓ Applies anywhere in Spain
  • ✓ Year of the move plus the following five years

Disadvantages

  • ✗ Must be requested with Form 149 within six months of starting the activity
  • ✗ No Spanish residence in the previous five tax periods
  • ✗ Some treaties exclude these taxpayers from most of their articles (for example point II of the Protocol to the treaty with Germany)
  • ✗ There is no regional share, so regional deductions such as Madrid's Art. 17 bis do not apply

Mbappé Law: Madrid deduction for investments by new residents (Art. 17 bis Legislative Decree 1/2010)

Advantages

  • ✓ 20% of the acquisition value of qualifying investments
  • ✓ Debt and equity in any entity, listed or not
  • ✓ Any amount not usable for lack of tax carries forward five years
  • ✓ Works within ordinary IRPF, with its personal and family allowances

Disadvantages

  • ✗ Only for Madrid IRPF taxpayers who were not Spanish resident in the previous five years
  • ✗ The investment must be held six years and Madrid residence kept until then
  • ✗ Applied against the regional share only: not available under the Beckham regime
  • ✗ Ordinary IRPF taxes worldwide income

Our verdict

They do not stack. The Madrid deduction is applied against the regional share of IRPF and the Beckham regime has no regional share (Art. 93.2 LIRPF). Which one is better depends on Spanish employment income, foreign income, the amount to be invested and whether you will keep the investment for six years in Madrid. It is calculated case by case.

Why they do not stack

The so-called Mbappé Law is a Madrid regional deduction: 20% of the acquisition value of certain investments by new residents, set out in Article 17 bis of Legislative Decree 1/2010 and added by Law 4/2024. Regional deductions are applied against the regional share of IRPF.

The Beckham regime has no regional share: the tax is computed under the non-resident rules with a single 24% and 47% scale (Art. 93.2 LIRPF). So while the Beckham regime applies, there is no regional share to deduct from.

How to decide

  • Beckham regime: high Spanish employment income and significant foreign income.
  • Ordinary IRPF with the Madrid deduction: taxpayers under the general regime who invest a substantial amount in securities that meet Art. 17 bis and will live in Madrid for at least six years.

The numbers depend on each case. See also our page on the Mbappé Law.

Sources: Madrid Legislative Decree 1/2010, Art. 17 bis (BOCM-m-2010-90068) · Madrid Law 4/2024 (BOE-A-2025-3302) · Law 35/2006, Art. 93 (BOE-A-2006-20764) · Law 22/2009, Art. 46 (BOE-A-2009-20375)

FAQ

Frequently asked questions

Not in the same tax year. The deduction in Art. 17 bis of Madrid's Legislative Decree 1/2010 is applied against the regional share of IRPF (Art. 46 of Law 22/2009). A Beckham taxpayer computes the tax under the non-resident rules with a single 24% and 47% scale (Art. 93.2 LIRPF), with no regional share.
No Spanish residence in the previous five years, becoming a Madrid IRPF taxpayer from 2024, investing in the year of the move or the next (for Spanish entities, also the year before), holding the investment six years and remaining resident in Madrid during that period (Art. 17 bis.2 and 17 bis.4).
Debt securities and equity in any entity, listed or not. For unlisted entities, a 40% cap together with spouse and relatives up to the second degree, no management role or employment there, and the entity cannot be in a tax haven (Art. 17 bis.1 and 17 bis.2.a).
No Spanish residence in the previous five tax periods, moving for one of the reasons in Art. 93 LIRPF (employment contract, company director, entrepreneurial activity and others) and filing Form 149 within six months of starting the activity.
It depends on your Spanish employment income, your foreign income, the amount you plan to invest and whether you will keep the investment for six years in Madrid. We calculate it in the first meeting, which is free.

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