Live in Spain and pay only 24% income tax — legally

What is the Beckham Law?

The Regimen Especial para Trabajadores Desplazados — universally known as the Beckham Law — is one of Spain’s most powerful tax incentives for internationally mobile professionals. Enacted in 2004 under Article 93 of Spain’s Personal Income Tax Law (Ley 35/2006, de 28 de noviembre, del Impuesto sobre la Renta de las Personas Físicas) and significantly expanded by the Startups Law (Ley 28/2022, de 21 de diciembre, de fomento del ecosistema de las empresas emergentes), it allows qualifying new residents to elect to be taxed as non-residents on their Spanish income.

The regime gets its informal name from footballer David Beckham, who was one of its first high-profile beneficiaries when he joined Real Madrid in 2003 — his advisors lobbied successfully for a provision that would cap his Spanish tax liability at a competitive flat rate rather than the standard progressive scale.

Under the regime, employment income up to 600,000 euros per year is taxed at a flat 24%. Income above that threshold is taxed at 47%. For digital nomad visa holders specifically, the rate drops to 15% — one of the lowest effective rates available to legal residents anywhere in Western Europe.

The regime applies for the year of arrival in Spain plus the five subsequent years: a total of up to six fiscal years. For a high earner, the difference between 24% and the top marginal rate of 47% can be worth tens or even hundreds of thousands of euros per year.

Legal basis and recent regulatory changes (2023–2026)

The Beckham Law is codified in Article 93 of Ley 35/2006 (LIRPF) and developed in Articles 113–120 of the IRPF Regulations (Real Decreto 439/2007). The Startups Law of 2022 (in force from January 2023) amended Article 93 substantively, expanding the categories of eligible taxpayers and introducing the preferential 15% rate for digital nomads.

The Agencia Tributaria has issued interpretive guidance through binding rulings (consultas vinculantes) and the Tribunal Económico-Administrativo Central (TEAC) has addressed several contested aspects of the regime. Key TEAC resolutions confirm that:

• The 180-day clock starts from the date of first Social Security affiliation (alta en la Seguridad Social), not from the date of physical arrival or visa grant
• Directors of Spanish companies with a participation below 25% can qualify even without a separate employment contract
• The five-year non-residency requirement is calculated against the five calendar years immediately preceding the year of arrival, not five tax years

For 2026, no further legislative changes to the Beckham Law have been enacted. The AEAT has confirmed that the regime continues to apply on its existing terms, including the 15% rate for digital nomad visa holders introduced by the Startups Law.

Who qualifies: the complete eligibility checklist

To access the Beckham Law regime you must satisfy all of the following conditions:

Condition 1 — Prior non-residency. You must not have been a Spanish tax resident in any of the five tax years immediately preceding your first year of residency in Spain. If you lived in Spain, even briefly, within the relevant five-year window, you are disqualified. This is the most common disqualifying factor and must be assessed carefully for anyone who has previously studied, worked short-term, or owned property in Spain.

Condition 2 — Qualifying reason for relocation. Your move to Spain must be for one of the following reasons, as expanded by the 2023 Startups Law:

• An employment contract with a Spanish employer (the original category, still the most common)
• A secondment (desplazamiento) from a foreign employer to Spain, either to a Spanish subsidiary or branch, or to a Spanish client under a services agreement
• A director appointment in a Spanish company (provided your shareholding is below 25%, or below 25% combined with related parties, unless the company qualifies as a startup under the Startups Law)
• Holding a Digital Nomad Visa (Autorización de Residencia para Teletrabajadores de Caracter Internacional)
• Carrying out an entrepreneurial activity as defined in the Startups Law (broadly, founding or joining a startup with an innovative nature and a scalable business model)
• Being a highly qualified professional engaged in R&D, scientific, or training activities

Condition 3 — Economic substance. Your work activities must generate qualifying income. Pure passive income situations do not trigger the regime. You must have a genuine reason for being in Spain — a contract, a visa, a directorship — that generates active income taxed under the regime.

Condition 4 — Timely opt-in. You must file Modelo 149 within 180 calendar days of your first Social Security affiliation date. This deadline is absolute and has no extensions or waivers.

The 2023 Startups Law expansion in detail

The Ley de Startups was the most significant reform of the Beckham Law since its introduction. Three changes deserve particular attention.

Digital nomads — the 15% rate. For the first time, individuals who are self-employed or employed entirely by non-Spanish entities can access the Beckham Law without needing a Spanish employer. Digital nomad visa holders pay 15% flat on qualifying income up to 600,000 euros, rather than the standard 24%. This 9 percentage-point differential makes a material difference at virtually any income level.

Entrepreneurs and startups. Founders relocating to Spain to run a startup (as certified under the Startups Law by ENISA — the national innovation agency) can now access the regime. This has created a new pathway for tech founders, particularly those participating in Spanish accelerators or raising capital from Spanish venture funds.

Family extension. Under the pre-2023 rules, the Beckham Law applied only to the primary applicant. The 2023 reform allows the spouse/civil partner and children under 25 who relocate to Spain as dependants to also benefit from the regime, provided they independently meet the non-residency requirement and their individual income is below the primary applicant’s. This is an extremely valuable extension for families relocating together.

Tax rate comparison: Beckham Law vs standard IRPF

Spain’s general progressive IRPF scale for 2026 is:

Note: Regional surtaxes apply on top of the national scale. The above are national rates only; total effective rates including the regional tranche are slightly higher in most autonomous communities.

The following table illustrates the difference between the Beckham Law and standard IRPF at various income levels. The standard IRPF figures use approximate combined national and regional rates (Madrid scale used as reference) and exclude deductions.

For digital nomad visa holders eligible for the 15% rate:

These figures are illustrative. Actual savings depend on income composition, deductible expenses, regional rates, and applicable tax treaties. BMC provides detailed personalised projections during the eligibility assessment.

Form 149: the opt-in process step by step

Modelo 149 is the official election form to join the Beckham Law regime. The process is as follows:

Step 1 — Gather your documentation. Before filing, you will need: your NIE (Numero de Identidad de Extranjero), your Social Security affiliation number and the exact date of first affiliation, a copy of your employment contract or digital nomad visa authorisation, and proof of your prior non-residency (tax certificates from your previous country of residence for the five preceding years are advisable, though not always strictly required).

Step 2 — Complete Modelo 149. The form is available through the AEAT’s online portal (Sede Electronica). It requires personal identification data, the qualifying reason for relocation (employment, secondment, digital nomad visa, entrepreneurial activity, etc.), the identity of the Spanish employer or the nature of the self-employment activity, and the date of first Social Security registration.

Step 3 — Submit electronically. Modelo 149 must be submitted electronically through the AEAT portal. You will need a valid digital certificate (certificado digital) or Cl@ve PIN to submit. Your tax advisor can file on your behalf with a granted power of attorney (autorización de representación).

Step 4 — Receive confirmation. The AEAT issues a receipt (justificante de presentación) immediately upon successful submission. Keep this document: your employer will need it to apply the correct withholding rate (24% instead of the progressive IRPF scale) from your first payroll.

Step 5 — Notify your employer. Once you have the AEAT receipt, provide a copy to your employer’s payroll department. They are required to switch to the IRNR withholding rate for all subsequent salary payments. If payroll has already been run at the wrong rate, a correction is possible but creates administrative complexity.

Critical deadline reminder. The 180-day clock starts on the date of your first Social Security affiliation — the día del alta en la Seguridad Social as shown on your Social Security document (TA.2/S or equivalent). It does not start from your arrival date, your visa approval, or your first payslip. BMC monitors this deadline from the first consultation and includes it in every engagement letter.

Treatment of different income types under the regime

The Beckham Law does not treat all income identically. Understanding the rules for each income category is essential for accurate planning.

Employment and professional income (rendimientos del trabajo y actividades económicas). This is the primary category. Income from employment with a Spanish company, or from professional activities carried out in Spain under the digital nomad visa, is taxed at the flat rate (24% standard, 15% for digital nomad visa holders). Bonuses, stock options vested during the regime period, and benefits in kind related to the employment are all subject to the same flat rate.

Investment income — dividends, interest, and savings income. Investment income (rendimientos del capital mobiliario) is taxed at the savings tax scale regardless of whether you are under the Beckham Law or the general regime. For 2026, the savings scale is: 19% on the first 6,000 euros, 21% on 6,001–50,000 euros, 23% on 50,001–200,000 euros, 27% on 200,001–300,000 euros, and 28% above 300,000 euros. There is no preferential treatment for investment income under the Beckham Law.

Capital gains. Similarly, capital gains (ganancias patrimoniales) are taxed at the savings scale (19–28%). This applies to gains on shares, funds, real estate, and other assets. The Beckham Law does not reduce the capital gains rate.

Foreign-source income. Foreign income that is not attributable to work physically performed in Spain is generally excluded from Spanish taxation under the regime. This is one of the most powerful aspects of the regime for internationally mobile executives and entrepreneurs. Dividends from foreign companies you own, rent from foreign properties, and interest from foreign bank accounts are typically outside Spanish tax jurisdiction during the Beckham Law period. However, treaty provisions may apply, and the analysis depends on the specific income type and country of origin. BMC analyses foreign income streams for each client individually.

Crypto and digital assets. The AEAT has taken an increasingly assertive position on cryptocurrency. Under the Beckham Law, cryptocurrency holdings acquired before becoming a Spanish tax resident are generally outside the Spanish tax net during the regime period. However, gains realised from selling crypto while resident in Spain are taxable at the savings scale (19–28%). Mining income and staking rewards are treated as professional income or investment returns respectively, and may be subject to the flat employment rate or savings rate depending on the classification. This is an evolving area; BMC monitors AEAT guidance and TEAC decisions on crypto classification.

Stock options and RSUs. A common area of complexity for executives. The general rule is that options or restricted stock units (RSUs) vested during the Beckham Law period are taxed at the flat rate at the point of exercise or vesting. Options granted before Spanish residency but exercised during the regime period are taxable on the portion of the vesting period spent in Spain. Detailed analysis is required for each grant, particularly where the underlying company is listed on a foreign stock exchange.

Beckham Law and wealth tax (Impuesto sobre el Patrimonio)

One of the most significant but least-discussed advantages of the Beckham Law is its interaction with the Spanish wealth tax (IP). Under the general resident rules, a Spanish tax resident must declare worldwide net assets on their annual wealth tax return if those assets exceed approximately 700,000 euros per person (the exemption threshold, which varies by autonomous community).

Under the Beckham Law, the taxpayer is treated as a non-resident for IRPF purposes. Non-residents pay wealth tax only on Spanish-sited assets, not on worldwide assets. This means that foreign bank accounts, foreign real estate, foreign company shareholdings, foreign investment portfolios, and foreign pension funds are entirely outside the Spanish wealth tax net during the Beckham Law period.

For high-net-worth individuals with significant foreign assets, this can represent a substantial additional saving. A person with 5 million euros in foreign investments who would otherwise face an annual IP liability of 20,000–50,000 euros (depending on the autonomous community) has that liability reduced to zero on the foreign portion.

This exemption is not an oversight or grey area — it is the direct and intended consequence of the IRNR treatment under the Beckham Law regime, confirmed by the AEAT in multiple binding consultations (consultas vinculantes).

Common mistakes that disqualify the Beckham Law

Based on our experience managing hundreds of applications, these are the most frequent disqualifying factors and filing errors:

1. Prior Spanish residency within five years. Clients who studied in Spain, worked on a temporary project, or held Spanish tax residency for any reason within the five calendar years before the target year of relocation will not qualify. Note that tax residency is assessed by the general rule of 183 days or centre of vital interests — even a six-month language course programme could establish prior tax residency if it tipped the 183-day count.

2. Missing the 180-day deadline. The most common reason for losing the regime. The window is calculated from Social Security affiliation, not visa grant or arrival. We have seen clients arrive in January, begin employment in February, register with Social Security in February, and then assume the clock starts from their visa (issued in December). It does not. The clock started when the Social Security registration was processed.

3. Wrong Social Security start date on Form 149. An administrative error in entering the alta en la Seguridad Social date can trigger an AEAT review. The date must match the official Seguridad Social records exactly.

4. Incompatible shareholding structure. Directors who hold 25% or more in the Spanish company (or whose combined shareholding with related parties reaches 25%) are excluded from the regime unless the company qualifies as a startup under the Startups Law. Shareholders who acquire additional shares after joining may inadvertently cross this threshold.

5. Carrying out activities in Spain before the qualifying employment begins. If you arrive in Spain and begin working informally or as a contractor before your qualifying employment contract starts, you may not have a valid qualifying reason for relocation. The sequence matters: the qualifying reason must be the actual cause of the relocation, not something created after the fact.

6. Failing to notify the employer. Even if Form 149 is filed correctly, employers who are not notified will apply the wrong IRPF withholding. This creates over-withholding and the need for corrective filings. It does not disqualify the regime, but it creates unnecessary cash-flow and administrative complexity.

7. Applying the wrong rate. Clients with digital nomad visas who are advised that their rate is 24% rather than 15% are effectively overpaying tax. Conversely, applying the 15% rate without a valid digital nomad visa is non-compliant and will be challenged on audit. The rate must correspond to the qualifying category.

What happens when the Beckham Law ends: year-six planning

The Beckham Law applies for up to six fiscal years. In year seven, you become an ordinary Spanish resident subject to progressive IRPF on your worldwide income. This transition requires careful advance planning.

Reassessing income structure. Income that was excluded from Spanish tax during the Beckham Law period — foreign dividends, foreign rental income, foreign capital gains — becomes fully taxable in year seven. If you have been accumulating returns in foreign investment accounts, year seven may bring a significant new tax exposure. We recommend reviewing the investment portfolio structure in year four or five of the regime.

Timing of asset disposals. If you plan to sell foreign real estate, a significant equity stake, or a large investment portfolio, the analysis of whether to dispose of it before the end of year six or after requires careful modelling. Capital gains on assets disposed of in year six while still under the Beckham Law are taxed at the savings scale (19–28%). After year seven, they remain taxed at the savings scale, so there is no dramatic cliff-edge on capital gains specifically — but the worldwide net is wider and the interaction with Modelo 720 (foreign asset declaration) changes.

Pension and retirement planning. Pension contributions made to foreign pension schemes during the Beckham Law period may not have been deductible in Spain (as they typically are under the general regime). Year-seven planning should include a review of whether to increase Spanish pension contributions to take advantage of deductibility under the general regime.

Considering relocation again. Some clients, particularly those with substantial foreign income, find it more efficient to relocate again at the end of the Beckham Law period rather than transition to the general regime. This is a legitimate choice that merits honest modelling rather than default assumption. BMC prepares detailed year-six transition analyses comparing the cost of remaining in Spain under general IRPF with the after-tax cost of relocating to another jurisdiction.

Beckham Law and double taxation treaties

Spain has signed double taxation treaties (convenios para evitar la doble imposición) with more than 95 countries. The interaction between the Beckham Law and treaty provisions is a technically demanding area.

Under the Beckham Law, the taxpayer is classified as a resident of Spain under Spanish domestic law — you are registered in the tax rolls and hold a Spanish fiscal address. Most treaties, however, determine residency by the OECD Model Convention tiebreaker rules, which look at centre of vital interests rather than domestic classification. The result is that Beckham Law taxpayers are generally treaty residents of Spain, and they can and should use treaty provisions to avoid being taxed on the same income twice (e.g., foreign salary income that is taxed in the country of the employer).

For employment income earned from foreign employers while physically working in Spain, the analysis depends on the applicable treaty, the nature of the work, and whether the employer has a permanent establishment in Spain. Specific treaty positions that arise frequently in our practice include:

• US–Spain treaty: US citizens and residents are subject to US worldwide taxation regardless of the Beckham Law, and must file annual FBAR and FATCA disclosures in addition to Spanish returns
• UK–Spain treaty: UK source employment income where the duties are performed in Spain is generally taxable in Spain under the treaty; the Beckham Law flat rate applies to the Spanish-source portion
• Germany, Sweden, Netherlands, France: All have comprehensive treaties with Spain; the treaty analysis for executives seconded from these countries is well-developed through practice and binding AEAT rulings

Practical case: an executive relocating from London

To illustrate how the analysis works in practice, consider the following scenario. A UK-based financial services executive, 42 years old, has been offered a role as Head of European Operations at a Spanish fintech company. Her package is 280,000 euros basic salary plus a potential 60,000 euro annual bonus. She also holds 1.2 million euros in a UK ISA (individual savings account) from which she takes no withdrawals. She has never lived in Spain.

Under standard IRPF, her total annual tax on the salary and bonus alone would approach 155,000 euros (combined national and regional rates, approximate). Under the Beckham Law, it would be 81,600 euros (24% of 340,000 euros). The annual saving is approximately 73,400 euros. Over six years, assuming similar compensation, this is roughly 440,000 euros in tax savings on the salary and bonus alone.

The UK ISA: ISA interest and gains are not taxable in the UK but are also outside Spanish tax during the Beckham Law period (foreign investment income excluded). In year seven, if she retains Spanish residency, the ISA returns become taxable in Spain at the savings scale (Spain does not recognise ISA tax-free status). This is a consideration for year-six planning.

BMC would assess the treaty position on her UK-source employment income, model the year-six transition, and advise on whether any restructuring of the ISA is advisable before year seven.

Practical case: a digital nomad software engineer

A US software engineer, 34 years old, earns 95,000 euros per year from a single US technology company as a fully remote employee. He has been granted the Spanish Digital Nomad Visa. He has never been a Spanish tax resident.

As a US citizen, he remains subject to US federal income tax on his worldwide income regardless of where he lives. However, the Foreign Earned Income Exclusion (FEIE) allows him to exclude up to approximately 130,000 USD of foreign earned income in 2026, substantially reducing or eliminating his US liability.

In Spain under the Beckham Law at 15%, his Spanish income tax on 95,000 euros is 14,250 euros. Under the standard IRPF progressive scale, it would be approximately 35,000 euros. The annual saving in Spain alone is approximately 20,750 euros, or approximately 124,500 euros over six years.

BMC coordinates with US-qualified CPAs on the FEIE and FBAR filings to ensure the combined US-Spanish tax position is properly managed and compliant with both jurisdictions.

BMC’s approach to Beckham Law engagements

Our Beckham Law practice covers five distinct phases:

Phase 1 — Pre-relocation assessment. We review your prior tax residency history, income structure, employment arrangements, and any assets that might require structuring before you become a Spanish resident. This phase is ideally completed three to six months before the planned move.

Phase 2 — Relocation date optimisation. The year of arrival is the first year of the regime. For most clients, arriving in Spain before January 1 of a given year means the first full calendar year counts as year one. However, the interaction between the 183-day residency rule, the Social Security affiliation date, and the Form 149 deadline creates complexity that is worth planning in detail.

Phase 3 — Form 149 filing. We prepare and submit the opt-in election, coordinate with your employer on withholding adjustments, and obtain AEAT confirmation. We set a tracked deadline alert from the date of Social Security affiliation.

Phase 4 — Annual compliance. Each year we file your Modelo 151 (the Beckham Law IRNR return), review whether any new income sources have arisen that require separate treatment, and confirm your eligibility status. We also file any required declarations of foreign assets (Modelo 720 if applicable) and advise on the interaction with the Spanish solidarity tax on large fortunes (Impuesto Temporal de Solidaridad de las Grandes Fortunas, ITSGF) where relevant.

Phase 5 — Year-six transition planning. We begin this process no later than month 18 before the regime ends. The transition analysis covers income structure, investment portfolio review, pension planning, and — for some clients — relocation modelling.

Useful tools and further reading

Use our free Beckham Law Calculator to compare your tax liability under the flat 24% rate versus Spain’s standard IRPF progressive scale. The tool helps you estimate annual savings at different income levels.

For a broader view of how Spanish personal income tax (IRPF) works and what has changed in 2026, see our guide: IRPF 2026: Why Spain’s Income Tax Is Trending and What Changed.

Frequently asked questions

Can I lose the Beckham Law once I have been granted it? Yes. The regime can be revoked if you cease to meet the qualifying conditions — for example, if your employment ends and you take on Spanish-source freelance work that no longer qualifies, or if you acquire a shareholding above 25% in a Spanish company. The revocation applies from the year in which you ceased to meet the conditions. BMC monitors qualifying conditions throughout the six-year period.

Do I still have to file a tax return in my home country? This depends entirely on your nationality and home country rules. US citizens must file regardless of residence. UK residents who ceased UK tax residency must file a partial-year return in the year of departure. Most EU nationals cease home-country filing obligations once they establish Spanish residency, but specific treaty positions may require continued home-country disclosures. BMC works with correspondent advisors in key jurisdictions.

What about the Modelo 720 foreign assets declaration? Modelo 720 requires Spanish tax residents to disclose foreign assets above 50,000 euros per asset category (bank accounts, securities, real estate). The requirement applies to Beckham Law taxpayers. Despite the regime’s treatment of foreign income, you are still a Spanish resident required to file the disclosure. Failure to file carries severe penalties, though the EU Court of Justice has ruled that the penalty regime as previously applied was disproportionate.

Can I rent out my home country property while under the Beckham Law? Rental income from foreign real estate is foreign-source income and is generally excluded from Spanish taxation during the Beckham Law period, subject to the applicable double taxation treaty. In some treaty configurations, the source country has exclusive taxing rights over foreign real estate income; in others, Spain can tax it but must provide a credit. BMC analyses each property location individually.

What if my employer wants to stop my employment before year six ends? The Beckham Law is attached to the qualifying employment or visa — it is not portable to a different employer without reassessment. If your employment ends in, say, year three and you take new employment with a Spanish company, you may re-qualify under the employment category. If you set up as a freelancer and do not hold a digital nomad visa, you may not re-qualify. Each transition requires careful assessment.