Beckham Law Spain 2026 — pay a flat 24% tax rate in Spain for up to six years

Spain's Beckham Law (formally the special tax regime for inbound workers under Article 93 LIRPF, reformed by Law 28/2022) taxes qualifying relocated professionals at a flat 24% rate on Spanish-source income up to €600,000 per year, instead of Spain's progressive IRPF scale, whose top rate ranges from 45% to 53.85% depending on the region. The regime is available to employees relocated to Spain or working remotely (including digital nomad visa holders who are employees), entrepreneurs with an activity qualified under Art. 70 of Law 14/2013, highly qualified professionals, and company directors who have not been Spanish tax residents in the five tax periods before the year of their move. It lasts for six consecutive fiscal years and must be elected via Modelo 149 within six calendar months of starting activity in Spain: a strict deadline with no exceptions.

Spain’s Beckham Law — the popular name for the special tax regime applicable to displaced workers, company directors, entrepreneurs and highly qualified professionals under Article 93 of the Personal Income Tax Law (LIRPF) — has been one of the most powerful tools for international tax planning available in the Spanish legal system since its substantial reform by Law 28/2022 (the Startup Law).

This guide provides a comprehensive analysis of the current regulatory framework, updated 2026 eligibility requirements, quantified tax advantages, a comparison with alternative regimes including the Canary Islands Special Zone (ZEC) and non-resident status (IRNR), the step-by-step application process, and the most common errors that cost taxpayers tens of thousands of euros.

Legal framework: from Law 62/2003 to the Startup Law

The regime was introduced by Law 62/2003, of 30 December, on fiscal, administrative and social order measures (BOE-A-2003-23936), which incorporated into the IRPF law (today Article 93 LIRPF) a special tax regime for workers relocated to Spanish territory. The popular name derives from the coincidence that footballer David Beckham joined Real Madrid in the same year.

The original regime allowed those who became Spanish tax residents for employment reasons to be taxed, for the year of the move and the five following years, under the non-resident income tax rules at their flat rate on Spanish-source income (25% at the time, 24% from 2007). A 2010 reform (Law 26/2009) closed it to anyone whose expected remuneration exceeded €600,000 a year. From 2015 (Law 26/2014) professional athletes were excluded and the €600,000 became the threshold above which a higher rate applies.

Law 28/2022 of 21 December, promoting the start-up company ecosystem, effective 1 January 2023, significantly expanded the regime:

• Incorporated remote work by employees (Art. 93.1.b.1), including holders of the international teleworking visa.
• Added entrepreneurs and highly qualified professionals: an economic activity qualified as entrepreneurial under Art. 70 of Law 14/2013, or services to start-ups or R&D&I work that provides over 40% of income (Art. 93.1.b.3 and 4).
• Reduced the prior non-residency period from ten to five years, opening the regime to a much wider pool of incoming professionals.
• Extended the regime to spouses and children under 25 who relocate with the impatriate or later, within the impatriate’s first tax period under the regime.

The regulatory development was incorporated into Royal Decree 439/2007 (IRPF Regulations), Articles 113–120, governing the application procedure, formal requirements, and the Modelo 149 filing deadline.

Who qualifies for Spain’s Beckham Law in 2026

Article 93.1 LIRPF, in its current wording, establishes four grounds for accessing the regime, all conditional on meeting the common prior non-residency requirements.

Employees relocated to Spain

The original and most common scenario. The employment contract may be with a Spanish company (internal relocation) or with a foreign company relocating the employee to Spain. Since January 2023, remote work (telework) for employers established outside Spain is expressly included, meaning a professional working remotely for a US, UK, or other foreign company from Spain can access the regime.

The Modelo 149 must be backed by the employment contract or the employer’s relocation letter documenting the employment relationship. The law does not require the work to be carried out in Spanish territory: during the regime all employment income is deemed obtained in Spain (Art. 93.2.b LIRPF).

Entrepreneurs with a qualified activity

Law 28/2022 added those who carry out in Spain an economic activity qualified as entrepreneurial under the procedure in Article 70 of Law 14/2013 (Art. 93.1.b.3 LIRPF). The activity must be innovative or of special economic interest for Spain and have a favourable ENISA report. In addition, before moving to Spain, an entrepreneur from outside the EU must already hold the residence authorisation for business activity of Article 69 of that law, and an EU citizen the ENISA report itself (Art. 113.2 RIRPF). Once the activity is qualified, the Modelo 149 follows the same process as for employees.

Highly qualified professionals

Professionals providing services to start-up companies (startups formally recognised under Law 28/2022) or performing training, research, development and innovation (R&D+i) activities, provided the remuneration received for those activities represents more than 40% of their total business, professional and employment income.

This category is designed for researchers, scientists, trainers and specialist technology or innovation consultants working on their own account (a startup executive on the payroll qualifies as an employee or director instead) relocating to Spain to serve the entrepreneurial ecosystem.

Company directors

Directors and board members can access the regime regardless of the amount of their remuneration. A shareholding limit applies only if the company is a wealth-holding entity (Art. 5.2 LIS): then they must not hold a stake that makes it a related entity, that is, 25% or more of capital or equity (Art. 18 LIS).

Common requirements for all categories

• Prior non-residency: Not having been a Spanish tax resident in any of the five tax periods before the year of the move to Spain (Article 93.1.a LIRPF, as amended by Law 28/2022 — the previous wording, in force from 2015 to 2022, required ten years).
• No permanent establishment: Not obtaining income through a permanent establishment located in Spain (except under the entrepreneurial and highly qualified professional routes, Art. 93.1.c LIRPF).
• Relocation nexus: The change of residence must occur as a consequence of the employment, business or professional activity that qualifies for the regime.

Quantified tax advantages

Preferential tax rate

Under the Beckham Law, employment income and other Spanish-source income are taxed at a flat rate of 24% up to €600,000 of taxable base; Spanish-source dividends, interest and capital gains are taxed instead at a savings scale starting at 19% (Art. 93.2 LIRPF). Income exceeding that threshold taxes at 47%, close to the top marginal rate under standard IRPF, which varies by region (45% to 53.85%). The 24% flat rate is generally advantageous on employment income from about €60,000 to €70,000 a year upwards, depending on the region, and remains so above €600,000 because the first €600,000 is still taxed at 24%.

In comparison, the standard IRPF progressive scale starts at 19%, and its top combined state and regional rate ranges from 45% to 53.85% depending on the region (50% in Catalonia, 53.85% in the Valencian Community); the Basque Country and Navarra apply their own foral scales.

Territorial taxation of foreign-source income

Foreign-source income — dividends from foreign-listed shares, interest on non-Spanish deposits, rental income from properties outside Spain, capital gains on assets located abroad — does not tax in Spain under Beckham Law. Article 93 has no exception for income from related entities; what is taxed wherever it arises is employment income and income from an activity qualified as entrepreneurial, all of which is deemed obtained in Spain during the regime (Art. 93.2.b LIRPF). For a professional with significant foreign capital income, this can represent the regime’s largest single saving.

Modelo 720 and overseas assets

Modelo 720 is not filed while the Beckham regime lasts, because the obligation applies to those taxed on worldwide income (DGT V0092-14), and the income from those foreign assets is not taxable in Spain. The obligation starts in the first year after leaving the regime, and may apply to a spouse or children resident in Spain from the start.

Quantified comparison: tax burden examples

Approximate estimates for a single taxpayer resident in the Community of Madrid, using the 2025 state and regional scales, about €6,000 of deductible employment expenses and foreign income taken as dividends or interest (savings scale under standard IRPF, not taxed under the regime); foreign employment income would be taxed at 24% under the regime. The tax figures exclude the Social Security contributions themselves and other taxes. Each case requires individual analysis.

Regime comparison: Beckham vs IRPF vs ZEC vs Non-Resident (IRNR)

When standard IRPF may be better than Beckham Law: when the taxpayer has exclusively Spanish-source income below approximately €60,000 to €70,000 with substantial deductible personal allowances, or when most of the income is Spanish-source savings income (dividends, interest, capital gains on Spanish real estate or shareholdings), which the Beckham regime also taxes at a savings scale starting at 19% (Art. 93.2 LIRPF), not at 24%, so the regime adds little on that income.

When ZEC may be more suitable: when the activity is entrepreneurial, physically carried out from the Canary Islands, and the 4% corporate tax rate applicable to the first €4 million of tax base outperforms the individual 24% Beckham rate. ZEC requires incorporation of a company and effective establishment in the Canary Islands (hub-zec-canary-islands).

The 2023 family extension

Law 28/2022 extended the regime to the spouse (or, if there is no marriage, the other parent of the children) and children under 25 (or any age with a disability) of the primary applicant, subject to the following cumulative conditions:

1. They must move to Spain before or after the primary applicant: if before, without becoming Spanish tax resident before the primary applicant’s first regime tax period; if after, before that period ends (Art. 93.3.a LIRPF, Art. 113.3 RIRPF). And they must acquire Spanish tax residency (Art. 93.3.b).
2. The sum of the taxable bases of the spouse or children must be lower than the taxable base of the primary applicant (to prevent abuse where a higher-earning spouse accesses the regime through the family channel).
3. They must not have been Spanish tax residents in any of the five prior fiscal years (Article 93.3.c by reference to Article 93.1.a LIRPF).

The extension is particularly valuable for dual-income families where the spouse has foreign-source capital income (dividends from international portfolios, rental income from properties in the home country) that will remain entirely outside the Spanish tax perimeter for six years. Both spouses’ applications must be carefully coordinated to ensure that relocation timelines are documented consistently.

Risks and limitations of the Beckham Law regime

No access to personal and family deductions

Because Article 93 LIRPF applies the non-resident income tax rules while the taxpayer remains a Spanish tax resident, the taxpayer loses access to the personal and family deductions under standard IRPF: personal minimum allowance, family minimum, joint taxation reduction, maternity deductions, regional deductions, and the habitual residence deduction (for contracts prior to 2013). For taxpayers with relatively low income and significant deductible family allowances, standard IRPF may be more beneficial.

Partial incompatibility with Double Tax Treaties

Taxpayers under the Beckham regime cannot fully benefit from Spain’s Double Tax Treaties as ordinary tax residents. This may create double taxation in certain structures, particularly for employment income, which Spain taxes in full during the regime (Art. 93.2.b LIRPF) and which the country of origin or of the payer may also tax; dividends and capital gains from foreign sources, by contrast, are not taxed in Spain. The Directorate-General for Taxes (DGT) has issued several binding rulings delimiting the scope of this limitation.

Risk of permanent establishment characterisation

If the taxpayer’s activity could be characterised as conducted through a permanent establishment in Spain under Article 13 of the Non-Resident Income Tax Law, the taxpayer would lose the regime, except under the entrepreneurial and highly qualified professional routes (Art. 93.1.c LIRPF). The line between individual professional activity and a permanent establishment requires prior legal analysis, and during the regime the only economic activities allowed are the entrepreneurial and highly qualified professional ones (Art. 113.2 RIRPF), so an independent consultant outside those routes cannot combine that work with the regime.

Dividends from Spanish companies

Shareholders receiving dividends from Spanish companies are taxed on them under the regime at the savings scale of Art. 93.2 LIRPF, starting at 19%; the Article 21 exemption of the Corporate Income Tax Law applies only to companies, so no individual, resident or not, can use it. This is relevant for startup founders planning to remunerate themselves through dividends.

Early termination of the regime

The regime terminates if the taxpayer loses Spanish tax resident status, obtains income classified as derived from a permanent establishment in Spain outside the entrepreneurial and highly qualified professional routes, or breaches any access condition in a way that becomes apparent after initial approval. Early termination generates tax regularisation obligations that must be anticipated and managed with specialist advice.

Step-by-step application process

Step 1: Eligibility analysis before relocation

Eligibility verification must be carried out before formalising the move and signing any contract. The tax adviser must confirm: (a) the applicant has not been a Spanish tax resident in any of the previous five fiscal years (Article 93.1.a LIRPF); (b) the planned activity fits one of the four categories under Article 93.1.b LIRPF; and (c) the applicant will not obtain income through a permanent establishment in Spain, except under the entrepreneurial and highly qualified professional routes (Art. 93.1.c LIRPF).

Step 2: NIE or NIF and supporting documents

All foreign nationals, EU/EEA citizens included, need a Número de Identificación de Extranjero (NIE), which serves as their tax identification number; EU/EEA citizens obtain it with the EU citizen registration certificate. The NIE is obtained as part of the visa or residence authorisation process for non-EU nationals. Without a NIE, Modelo 149 cannot be filed.

Step 3: Documenting the activity start date

The starting point of the six-month period is the start date of activity shown in the Spanish Social Security registration, not the first working day or the contract date. This date must be evidenced with formal documentation: the Social Security registration showing that date or, where the worker keeps the home country’s Social Security, the documentation that allows it (such as an A1 certificate); only where no registration is required does the period run from the document that justifies the start of activity (Art. 116.1.a RIRPF). The AEAT may request supporting documentation at the time of resolving the Modelo 149 application.

Step 4: Filing Modelo 149

The formal application is filed via Modelo 149 with the AEAT, accompanied by:

• Copy of the employment contract, the employer’s relocation letter, or the ENISA report qualifying the activity as entrepreneurial.
• Documentary evidence of non-residency in Spain during the previous five years (foreign tax residency certificates).
• Notification of commencement of employment or business activity in Spain.

The maximum deadline is six calendar months from the activity start date (Article 116 RIRPF). The AEAT has ten working days to resolve, though in practice this may extend to several weeks.

Step 5: Communicating to the income payer

Once the AEAT’s favourable resolution is received, the taxpayer communicates to their income payer (employer or company) that the 24% withholding rate must apply instead of the standard progressive IRPF withholding tables. This communication is made by handing the payer a copy of the document the AEAT issues accepting the option.

Step 6: Annual declaration — Modelo 151

During the years the regime applies, the taxpayer files Modelo 151 (the personal income tax return for taxpayers under the special impatriate regime) instead of the standard IRPF Modelo 100. This model has its own income attribution rules and is filed in the same period as the standard IRPF return, which ends on 30 June.

Special situations in 2026

Remote workers and freelancers with clients in several countries

An employee teleworking from Spain for a foreign employer qualifies through Art. 93.1.b.1, with or without the international teleworking visa. A freelancer billing clients in several countries does not qualify on that basis alone: they need an activity qualified as entrepreneurial (Art. 70 of Law 14/2013) or to work as a highly qualified professional for start-ups or in R&D&I with over 40% of their income from it. During the regime, all employment income and all income from an activity qualified as entrepreneurial is deemed obtained in Spain (Art. 93.2.b LIRPF) and taxed at 24% up to €600,000, whoever the client is.

Those who still need a residence authorisation can apply for the digital nomad visa. For a full analysis of the visa process, see our Digital Nomad Visa Spain 2026 complete guide.

Startup founders and stock options

The taxation of stock options under the Beckham regime is one of the areas of greatest complexity. As a general rule, the benefit derived from exercising options is employment income taxed at the 24% flat rate up to €600,000, which can be highly advantageous for large amounts. This also applies to options over shares in foreign companies: during the regime all employment income is deemed obtained in Spain (Art. 93.2.b LIRPF). How much of a gain relates to work done before the move is something we assess case by case.

Startup founders simultaneously benefiting from the reduced 15% corporate tax rate (new rate for emerging companies under Law 28/2022) and the Beckham regime for their personal remuneration achieve one of the most tax-efficient combinations available in the Spanish legal system.

Employees relocated by multinational companies

For companies with frequent international mobility programmes, the Beckham Law onboarding process must be integrated into the standard fiscal onboarding protocol from the first moment of the selection or relocation process. The most frequent errors are: starting the employment contract before eligibility has been verified; not correctly documenting the activity start date in Spain (confusing it with the contract signature date or the date of physical arrival in the country); and not coordinating the spouse’s application when both partners want to access the regime.

Critical mistakes to avoid

1. Not verifying eligibility before relocation. If the applicant has been a Spanish tax resident in any of the previous five years (residence is assessed per calendar year, for example after more than 183 days in Spain in a year of study or work), the regime is not accessible and there is no subsequent remedy.

2. Missing the six-month deadline. This is the costliest error. There is no remedy once the Article 116 RIRPF deadline has passed. Several clients who came to BMC after missing this deadline (because their accountant was not familiar with the regime) had to tax at standard rates for the remainder of their time in Spain.

3. Not coordinating withholdings with the employer. If the employer does not receive a copy of the AEAT document accepting the option and continues applying standard IRPF withholding tables, the taxpayer must claim a refund of the excess withheld in their annual return, incurring unnecessary financing costs.

4. Forgetting the family extension. Each family member files their own Modelo 149 within six months of entering Spain, or within the primary applicant’s window if that is longer (Art. 116.1.b RIRPF). A family member who files late loses access to the regime.

5. Not planning the exit from the regime. At the end of six years, the taxpayer automatically transitions to standard IRPF. If they hold foreign assets or structures that have benefited from non-taxation in Spain, the transition must be planned well in advance.

Company-employee coordination for international relocations

For employer-sponsored relocations, coordination between the company’s HR and tax departments and the employee’s personal tax adviser is critical. At BMC we establish a Beckham onboarding protocol for multinational companies that covers:

• Eligibility verification during the recruitment process, before the final offer.
• Documentation timeline: relocation letter, Spanish employment contract, prior non-residency certificates.
• Modelo 149 filing protocol coordinated with the start date of activity shown in the Social Security registration (or in the A1 certificate), not with the contract date.
• Payroll system adjustment to apply 24% withholding once the employee hands over the AEAT document accepting the option.
• Annual Modelo 151 filing calendar with advance reminders.

About BMC and the Beckham Law

BMC manages the Beckham Law application process for profiles ranging from employees relocated by multinational technology companies to entrepreneurs with a qualified activity, remote employees, and directors of international family groups.

BMC’s international tax team, led by Ana García, combines experience at the AEAT and international tax advisory firms. We coordinate with tax advisers in the client’s home country to manage the bilateral picture of the relocation, avoiding double taxation and optimising the overall tax structure during and after the regime application period.

For the full technical analysis, download our definitive Beckham Law guide or contact our team for a confidential eligibility assessment.

Legal resources:

• BOE-A-2003-23936, Law 62/2003 — Law that introduced the Beckham regime
• BOE-A-2022-21739 — Law 28/2022 (Startup Law) — Reform that expanded the regime
• Modelo 149 — AEAT — Special regime application form
• Modelo 151 — AEAT — Annual regime declaration
• Spain Ministry of Foreign Affairs — Digital Nomad Visa — Digital nomad visa requirements

Related articles:

• Digital Nomad Visa Spain 2026: Complete Guide
• Beckham Law vs Standard IRPF comparison
• Beckham Law in Marbella
• Digital Nomad Tax Package Spain
• Tax Advisor Marbella for Expats

Guides by country of origin

If you are moving to Spain from one of these countries, there is a guide covering its tax treaty, pensions and exit tax:

• Moving from Germany to Spain
• Moving from France to Spain
• Moving from the Netherlands to Spain
• Moving from Switzerland to Spain