Expatriate Tax Guide Spain 2026 — Everything You Need to Know Before You Move

Spain is, in 2026, one of the most sought-after destinations for international professionals, startup founders, wealthy retirees and high-net-worth families looking to establish their tax residency in Europe. The combination of climate, quality of life, digital infrastructure, relative costs and, above all, a set of advantageous tax regimes for new arrivals has made the country a direct competitor to Portugal, Dubai and Malta for attracting international talent and capital.

But the Spanish tax system is also one of the most complex in the OECD for newcomers: seventeen regional variations on tax rates, four possible regimes for the expatriate, overlapping formal obligations with non-extendable deadlines and constant interaction with the double tax treaties of over ninety countries. A wrong decision before the move can cost tens or hundreds of thousands of euros over the entire stay in Spain.

This guide — one of the most comprehensive published in English on expat taxation in Spain — covers in seventeen structured sections everything you need to know: from acquiring tax residency to the monthly obligations calendar, through the four available regimes, wealth and inheritance taxes, foreign pensions, the specific situation of US, German and French citizens, and the ten most costly mistakes that repeat themselves in advisory practice.

1. Spain as a Destination in 2026: What Has Changed

The landscape of expat taxation in Spain changed significantly between 2023 and 2025. The most relevant changes for 2026 are:

Golden Visa abolished (April 2025). The real estate investment Golden Visa (Ley 14/2013, art. 63) was abolished in April 2025, eliminating the residency-by-investment route through real estate purchases above €500,000. Golden Visas already granted maintain their effects as long as renewal requirements are met.

Digital Nomad Visa established. The Digital Nomad Visa (DNV), introduced by the reformed Ley 14/2013 in 2022, is fully operational. The minimum income threshold was updated to €2,762/month (200% of the 2025 national minimum wage). (Confirm the 2026 figure against the published BOE SMI Royal Decree.)

Beckham regime extended and in force. Ley 28/2022 de Startups maintains full application. In 2025, various DGT binding rulings were published clarifying application to digital nomads with multiple clients and to startup founders with stock options.

Mbappé Madrid active. The Community of Madrid approved for the 2024 tax year a 100% regional deduction on the regional IRPF tranche for Beckham taxpayers, massively increasing the fiscal attractiveness of the capital. (Confirm application for the 2026 tax year in the current BOCM resolution.)

Solidarity Tax on Large Fortunes in force. The ISF (Ley 38/2022) continues to apply to net wealth above €3m and acts as a floor for regions with 100% IP exemptions (Madrid, Andalusia). The Constitutional Court validated its constitutionality in 2024. (Confirm the current status of any pending 2026 constitutional challenges.)

2. Tax Residency in Spain: When and How It Is Acquired (art. 9 LIRPF)

Spanish tax residency is acquired under any of the three criteria set out in article 9 of Ley 35/2006 (LIRPF):

2.1 The 183-Day Rule

The most commonly known rule: if you spend more than 183 days in Spanish territory during the calendar year (1 January to 31 December), you are a Spanish tax resident for that year. The count includes occasional absences, except when the taxpayer can evidence tax residency in another country.

The word “occasional” is key: a prolonged absence of two or three months for work or habitual travel may be treated as occasional if the taxpayer’s centre of life remains in Spain. Evidencing tax residency in another country through a tax residency certificate issued by the foreign tax authority is the only element that neutralises this presumption.

Start date: for Beckham regime purposes, the date of start of activity in Spain (first day of employment or start of business activity) is what triggers the six-month window, regardless of how many days of the calendar year have passed. A professional arriving on 1 July who starts work from that date has acquired tax residency for that year (assuming they remain for the rest of the year) and has until 1 January of the following year to file the Modelo 149.

2.2 Centre of Economic Interests

Article 9.1.b LIRPF establishes that a person is also a Spanish tax resident if they have in Spain the main hub or base of their activities or economic interests, directly or indirectly. This criterion operates independently of the 183-day rule: a taxpayer who spends only four months a year in Spain but manages investments from there, has their main company there or receives their main income there may be considered a tax resident even without reaching 183 days.

For expats seeking to maintain a second home in Spain without becoming tax residents, this criterion is the most dangerous: the AEAT can argue the centre of economic interests even if the day count is below 183 if the main economic activity is conducted from Spain.

2.3 Family Nucleus (Presumption of Art. 9.1.c)

If the non-legally-separated spouse and minor children reside in Spain, there is a presumption — rebuttable by contrary evidence — that the taxpayer also has their habitual residence in Spain. This presumption is rebutted by evidencing tax residency in another state through a certificate issued by the competent tax authority of the claimed country of residence.

2.4 Passive vs. Active Acquisition

Tax residency can be acquired passively (simply through the passage of time or family presence) or actively (through the start of an employment or business activity in Spain with the intent to relocate). The distinction is critical for the Beckham regime: this regime requires an active move motivated by the activity, not simply passive acquisition of residency.

3. The Four Available Regimes for the New Resident

3a. Standard IRPF (Ley 35/2006): Worldwide Income Taxation

The default regime. A Spanish tax resident pays IRPF on their worldwide income: all income, regardless of geographic origin, is incorporated into the Spanish tax base.

The IRPF rate for 2026 combines the state and regional tranches. In mainland Spain, marginal rates range from 19% to 47% for income above €300,000. In Catalonia, Valencia and the Basque Country, regional rates are higher, reaching 54% in Catalonia. In the Canary Islands, regional rates are somewhat below the national average.

Savings income (dividends, interest, capital gains) taxes in the savings base at rates of 19% (up to €6,000), 21% (up to €50,000), 23% (up to €200,000) and 28% (above €300,000), following the 2023 reform.

When standard IRPF is better than Beckham: when the taxpayer has exclusively Spanish-source income that is relatively modest (below €50,000-€60,000) with significant deductible family expenses (personal minimum, family minimum, maternity deductions, disability deductions, rental deductions), or when their main income streams are dividends or gains from Spanish sources that would tax at savings rates (19-28%) rather than the flat 24% under Beckham.

3b. Beckham Regime (art. 93 LIRPF): Flat 24% Federal Rate

The special regime for workers, professionals and entrepreneurs assigned to Spanish territory, regulated under article 93 of Ley 35/2006 (LIRPF) and developed in articles 113-120 of the IRPF Regulations (Real Decreto 439/2007).

Main features:

• Flat 24% rate on Spanish-source income up to €600,000. The excess taxes at 47%.
• Foreign-source income exempt: dividends, interest, capital gains and income from property located outside Spain do not tax in Spain during the six-year regime, unless they come from entities related to the taxpayer (art. 93.2 LIRPF).
• Six-year duration: the year of relocation plus the five following tax years.
• Limited Wealth Tax liability: during the regime, the taxpayer pays Wealth Tax only on assets located in Spain, not on worldwide wealth.
• No access to personal deductions: personal minimum, family minimum and regional deductions are not available.
• Annual return: Modelo 151 instead of Modelo 100.

Groups eligible in 2026: employed workers relocated to Spain (including remote work for foreign employers), startup visa entrepreneurs, highly-qualified professionals linked to startups or R&D (with more than 40% of income from that activity) and directors of non-related companies.

Common requirements: must not have been a Spanish tax resident in any of the five preceding tax years; must not receive income through a permanent establishment in Spain (except for entrepreneurs); relocation must be motivated by the activity.

Application deadline: six calendar months from the start of activity (Modelo 149). This deadline is absolutely non-extendable.

3c. Mbappé Madrid: Beckham + 100% Regional Deduction

For Beckham regime taxpayers who fix their residence in the Community of Madrid, the BOCM approved for the 2024 tax year a 100% regional deduction on the regional IRPF tranche. The colloquial name refers to footballer Kylian Mbappé’s signing by Real Madrid in the summer of 2024 and the visibility the regime gained at that time.

IRPF is split into two tranches: the state tranche (approximately 50% of the total rate) and the regional tranche (the other 50%). The Beckham regime sets the total rate at 24%; the Madrid 100% deduction on the regional tranche (~12%) reduces the total effective rate on Madrid-source income to approximately 12% of the state tranche.

The exact effective rate depends on the specific regulatory application approved by the BOCM for 2026; consult the current resolution before planning on this basis.

3d. Canary Islands Special Zone (ZEC): 4% Corporate Tax Rate

The ZEC is not a personal expatriate regime but a reduced corporate tax rate regime for entities established in the Canary Islands, with a 4% rate on the first four million euros of tax base (increased based on job creation). It requires incorporation of a Canary Islands entity, genuine physical establishment in the islands and at least one full-time employee under contract in the islands.

For expats with business activity, the combination of ZEC (for the corporate entity) + Beckham (for personal remuneration where applicable) is assessed on a case-by-case basis. The ZEC does not replace personal IRPF.

4. Forms You Will File as an Expat in Spain

5. Wealth Tax and Solidarity Tax on Large Fortunes 2026

5.1 The Wealth Tax (Ley 19/1991)

The Wealth Tax (IP) taxes the net wealth of individuals. The state minimum exemption is €700,000 (including the main home exemption of up to €300,000). The state rate ranges from 0.2% to 3.5% on net wealth above that exemption.

Autonomous Communities may approve their own rates and exemptions. Madrid and Andalusia apply a 100% exemption on the regional IP tranche, effectively eliminating the tax for taxpayers with personal liability (standard IRPF). However, the Solidarity Tax on Large Fortunes (see section 5.3) acts as a floor.

5.2 Limited vs. Personal Liability

• Personal liability (tax residents under standard IRPF): pay tax on the entirety of their worldwide net wealth.
• Limited liability (non-residents and Beckham taxpayers): pay tax only on assets and rights located, exercisable or enforceable in Spanish territory. This is a structural advantage for expats with predominantly foreign assets.

5.3 Solidarity Tax on Large Fortunes (Ley 38/2022)

The ISF is a state tax, not delegated to the regions, approved by Ley 38/2022, with rates of 1.7% (between €3m and €5m), 2.1% (between €5m and €10m) and 3.5% (above €10m). It is calculated as the difference between the computed ISF and the regional IP paid. For Madrid or Andalusia residents (IP = 0 due to 100% exemption), the full ISF is payable.

Interaction with Beckham: Beckham taxpayers have limited liability. Their ISF base is limited to assets and rights located in Spain. If their Spanish wealth is below €3m, they will not pay ISF. If it exceeds that threshold, they pay on the excess at the ISF rate, without the benefit of the Madrid 100% exemption (which is regional; the ISF is state-level).

Confirm whether the government has amended the €3m ISF threshold in the 2026 State Budget or by decree; the 2025 thresholds apply if no change.

6. Inheritance and Gift Tax (ISD) for Expats

The Spanish ISD taxes inheritances and gifts received. It applies both when the deceased or donor is a Spanish resident and when the inherited assets are located in Spain.

6.1 Residents and Non-Residents: Equal Treatment after the CJEU

The CJEU judgment of 3 September 2014 (Case C-127/12, Commission v Spain) obliged Spain to extend to non-residents the same ISD treatment it applies to residents. This means that a non-resident heir inheriting assets located in Spain can apply the regional rules (not just the state rules) of the Autonomous Community where the most valuable assets are located, accessing regional exemptions.

6.2 Regional Variation: Summary

6.3 Filing Deadline

The general deadline is six months from the date of death, extendable by a further six months if requested within the first five months. Late filing generates surcharges of 5% to 20% plus interest.

For international inheritances with assets in multiple countries, prior planning (separate wills by jurisdiction, trustees in low-succession-tax countries) can mean differences of hundreds of thousands of euros.

7. Capital Gains on Spanish Real Estate (Modelo 210)

The sale of Spanish real estate by a non-resident (or by a Beckham taxpayer with limited liability) generates a capital gain that taxes at 19% for EU/EEA residents, or 24% for third-country residents, via Modelo 210.

3% Retention (Modelo 211): when a non-resident sells Spanish real estate, the buyer is obliged to retain 3% of the sale price and pay it to the AEAT via Modelo 211 within 30 days of the notarial deed. If the retention exceeds the tax owed (because the gain is smaller or there is a loss), the non-resident can request a refund of the excess.

Municipal capital gains tax (IIVTNU): in addition to IRNR, the sale is subject to the municipal tax on the increase in urban land value (plusvalía municipal), calculated on the cadastral value of the land. Since the Constitutional Court judgment of 26 October 2021 and the subsequent reform, the objective method can be replaced by the actual method if the latter is more favourable to the taxpayer.

8. Pensions for Retirees: UK, Germany, France

8.1 Public vs. Private Pensions: General Principle

Article 17 of the OECD Model Convention (and equivalent Spanish DTTs) distinguishes between:

• Private pensions (occupational or private pension funds): tax in the country of residence of the beneficiary. If the retiree is a Spanish resident, foreign private pensions tax in Spain.
• Government pensions (from civil service, public administration or its agencies): tax in the paying country, not in the country of residence. A retired German civil servant resident in Spain continues to pay tax on their civil service pension in Germany.

8.2 Spain-UK DTT (1975, updated 2021)

The Spain-UK DTT continues to apply post-Brexit. Government Pensions (art. 18 DTT) tax only in the UK. Private pensions (Occupational Pensions, Personal Pensions, SIPPs) tax only in Spain as the country of residence. For British State Pension (Social Security), the majority position is that it taxes in Spain as the country of residence.

QROPS: Transfer of UK pension funds to a QROPS outside the EEA may be subject to the Overseas Transfer Charge (OTC) of 25% if the holder does not reside in the same country where the QROPS is registered. Retirees moving to Spain who want to consolidate their British pensions must carefully analyse the cost of this transfer against maintaining the fund in the UK and declaring it in the Modelo 720.

8.3 Spain-Germany DTT (DBA 2011)

The Spain-Germany DTT (DBA Spanien-Deutschland, 2011) applies the same principle: German civil service pensions (Beamtenversorgung) tax in Germany; private pensions (Betriebsrenten, Riesterrente, Rüruprente) tax in Spain. The Gesetzliche Rentenversicherung (general German social security pension) taxes in Spain as the country of residence.

8.4 Spain-France DTT (1995)

The Spain-France DTT (1995) follows the same structure. French civil service pensions tax in France; French state system pensions (Sécurité Sociale) and supplementary pensions (Agirc-Arrco) tax in Spain.

Retirees with a spouse in another country: for retirees with pensions from different countries and a spouse in a third state, analysing tax residency and the applicable DTT can be complex. BMC handles these cases with correspondent advisers in the source country when necessary.

9. Specifics for US Citizens and Residents

The United States is one of the only two countries in the world (along with Eritrea) that taxes its citizens and permanent residents on their worldwide income, regardless of where they live. A US citizen or Green Card holder resident in Spain must file a US tax return with the IRS every year (Form 1040).

9.1 FBAR (FinCEN 114)

If you have foreign bank accounts (Spain or elsewhere) with an aggregate balance exceeding $10,000 at any point during the year, you must file the FBAR (FinCEN Form 114) with the Financial Crimes Enforcement Network before 15 April (extendable to 15 October). Non-compliance can incur penalties of up to $10,000 per non-wilful violation and much higher for wilful violations.

9.2 Form 8938 (FATCA)

Form 8938 (FATCA) declares foreign financial assets above the applicable thresholds ($75,000 for non-US residents at year-end, or $150,000 at any point during the year). It is additional to the FBAR: both are mandatory if their respective thresholds are exceeded.

9.3 Foreign Tax Credit (FTC) vs. Beckham

Taxes paid in Spain can be credited against the US tax return via the Foreign Tax Credit (Form 1116) to reduce double taxation. However, the Beckham 24% rate (lower than the US maximum marginal rate of 37%) does not always cover the differential with US tax, especially for high-income individuals. Case-by-case analysis is essential.

9.4 FEIE vs. Beckham: An Unresolved Area

The Foreign Earned Income Exclusion (§ 911 IRC) allows exclusion of up to $126,500 (2024, indexed annually) of foreign earned income from the IRS base. The IRS position on whether Beckham taxpayers can apply the FEIE — given that Beckham technically classifies them as “non-residents” in Spain for Spanish tax purposes — has not been definitively resolved by ruling or instruction. Consult a dual US-Spain tax attorney before planning on this basis.

9.5 Spain-US DTT (1990)

The Spain-US DTT (BOE-A-1991-25462) contains a saving clause that allows the US to tax its citizens as if the treaty did not exist, with limited exceptions. This significantly reduces the DTT’s usefulness for US citizens (though not for foreign nationals resident in the US who are not citizens).

10. Specifics for DACH Citizens (Germany, Austria, Switzerland)

10.1 German Wegzugsteuer (§ 6 AStG)

The Wegzugsteuer taxes unrealised capital gains on company shareholdings (GmbH, AG) of 1% or more when the taxpayer ceases to be a German tax resident. The tax is calculated as if the shareholdings had been sold at market value on the date of departure.

Deferral within the EU/EEA: for relocations to Spain (an EU country), the Wegzugsteuer can be deferred interest-free and without security as long as the shareholdings are not sold and the taxpayer does not leave the EU/EEA. The deferral ends automatically if (i) the taxpayer returns to Germany, (ii) sells the shareholdings, (iii) moves to a country outside the EU/EEA, or (iv) the shareholdings are transferred to an entity that leaves the EU/EEA.

Coordination with Beckham: unrealised gains deferred under the Wegzugsteuer and realised during the Spanish stay may be foreign-source income (shares of a German GmbH) and not tax in Spain under Beckham. Fiscal coordination between Germany and Spain is critical to minimise the combined tax burden.

10.2 Spain-Germany DTT (DBA 2011) — Article 13

The DBA sets out in article 13 the rules for taxing capital gains. Capital gains from the sale of shareholdings primarily derived from real estate tax in the country where the real estate is located. Capital gains from other assets (GmbH shareholdings, listed securities) tax in the state of residence of the seller.

10.3 Austria and Switzerland

Austria has a DTT with Spain dating from 1966 (updated by protocol). Switzerland is not an EU member, so the Swiss exit tax (§ 98 EStG-CH for cantons that apply it) does not benefit from the automatic EU deferral. For Swiss citizens relocating to Spain, the cantonal exit tax must be analysed jurisdiction by jurisdiction.

11. Specifics for French Citizens

The Spain-France DTT (1995, BOE-A-1995-28063) is one of the most comprehensive in Spain’s treaty network. The most relevant points for French expats are:

Radiation fiscale: to be considered a non-French-tax resident, the expat must deregister fiscally in France (radiation fiscale), which requires evidencing Spanish tax residency. The French tax authority (DGFiP) is particularly rigorous about relocations to countries with lower taxation and may challenge the residency until habitual domicile in Spain is evidenced.

Impôt sur la fortune immobilière (IFI): the French IFI continues to be due for French tax residents on real estate worldwide exceeding €1.3m. For non-French-tax-resident expats (relocated to Spain), the IFI only applies to real estate located in France above €1.3m. Selling the French property before relocating or transferring it to a company can significantly reduce the IFI base.

Convention fiscale et résidence habituelle: article 4 of the Spain-France DTT sets out tiebreaker rules when both countries claim residency. The order of priority is: (1) permanent home, (2) closest personal and economic ties (centre of vital interests), (3) habitual place of residence, and (4) nationality. Most disputes are resolved under criteria (1) or (2).

12. Visa and Beckham Regime: Interaction

Not all visas or residency permits give access to the Beckham regime. The table below summarises the position in 2026:

The DGT’s position on the compatibility of NLV post-2023 with Beckham has not been subject to a definitive binding ruling; this table reflects the majority interpretation of international tax advisers in Spain as of May 2026. Confirm the current administrative position with a qualified specialist.

13. Sector Notes: Crypto, Founders and Real Estate

13.1 Cryptocurrencies and Digital Assets

Since the 2023 tax year, Modelo 721 (information on virtual currencies held abroad) is mandatory for taxpayers with crypto assets on foreign exchanges or wallets exceeding €50,000 valued at 31 December. Non-compliance can incur penalties of €5,000 per missing data item (article 38 ter of the LGT).

Capital gains from the sale, exchange or use of cryptocurrencies tax in Spain as capital gains in the savings base (19-28%). For Beckham taxpayers, classification of the gains as Spanish or foreign source depends on where the assets are held and the nature of the transaction; the AEAT has not issued a definitive criterion and the most conservative advisory position is to treat all crypto gains as savings income without distinguishing source.

13.2 Startup Founders: Carried Interest, Equity and Exit

For startup founders relocating to Spain, the main analytical points are:

• Stock options in foreign company: if the option vested before the relocation to Spain, the exercise after relocation may be foreign-source income under Beckham. If the plan was granted during activity in Spain, it is Spanish-source income taxed at 24%.
• 50% reduction for startup plans: Ley 28/2022 introduced a special 50% reduction on employment income derived from the delivery of startup shares or interests to employees (article 14.bis LIRPF), with a €50,000/year limit and no minimum holding period. This reduction is compatible with the Beckham regime (applied on top of the 24%).
• Carried interest: venture capital managers who receive carried interest may benefit from a 50% IRPF reduction (Fifty-Third Additional Provision LIRPF) if the fund meets certain requirements. The interaction with the Beckham regime requires specific analysis.
• Sale of foreign company shareholdings during Beckham: capital gains from the sale of a non-Spanish company are foreign-source income that does not tax in Spain under Beckham, unless the company holds Spanish real estate.

13.3 Real Estate Investors in Spain

Expats acquiring real estate in Spain (as a residence or investment) should consider:

• ITP/AJD on purchase: the Transfer Tax varies from 6% to 11% depending on the Autonomous Community. VAT (10%) applies to new-build properties on first transfer.
• IRNR on rentals: if the property is rented and the owner is not a tax resident or is under Beckham, rental income taxes at 19% (EU/EEA residents) via quarterly Modelo 210.
• 3% retention on sale (Modelo 211): the buyer retains it and the non-resident seller can request a refund if the retention exceeds the calculated tax.

14. The Ten Most Costly Mistakes

1. Not verifying eligibility before the move. If in any of the five preceding tax years you have been a tax resident in Spain, the Beckham regime is not accessible. There is no remedy.

2. Missing the six-month Modelo 149 deadline. The window closes permanently. Taxpayers who file the 149 in month seven have lost the regime for good during that stay.

3. Confusing the start of activity date with the arrival date. The deadline runs from the actual start of employment or business activity, not from arrival. A poorly documented activity start date can shorten the real available window.

4. Not coordinating withholdings with the employer (Modelo 150). If the employer continues to withhold at the standard IRPF rate, the excess is only recovered in the annual return, with a financial cost.

5. Forgetting the spouse’s Beckham application. The spouse’s application has its own six-month window from the start of their activity or relocation. A late filing loses the regime for them.

6. Not filing the Modelo 720 in the year of arrival. The Modelo 720 filing window (January-March) and the date of arrival in Spain may not coincide. If you arrive in October with foreign assets above €50,000, you must file the 720 before 31 March of the following year, even if you were a Spanish tax resident for only three months of the first year.

7. Ignoring the Modelo 721 for crypto assets. The penalties for non-filing are €5,000 per missing data item (article 38 ter LGT). Many expats are unaware of this obligation, which has been in force since 2023.

8. Assuming the Madrid 100% exemption eliminates all wealth taxes. The Madrid exemption on the IP does not apply to the Solidarity Tax on Large Fortunes, which is a state tax. For wealth above €3m, the ISF is paid in full even if the IP was fully exempted.

9. Not planning the exit from the regime. At the end of year six, the taxpayer automatically moves to standard IRPF, which taxes worldwide income. If during those six years unrealised gains have accumulated in foreign assets (investment funds, shares, cryptocurrencies), no Spanish tax will have been paid on them. But from year seven onwards, any realisation of those gains will tax at savings rates of 19-28%.

10. Trusting generalist advisers without international tax experience. The Beckham regime, the Modelo 720, the Wegzugsteuer, the specific DTTs and the interaction with the home country’s tax system require a team with specific expat tax experience. Mistakes made by advisers without that specialisation are usually irreversible.

15. Tax Calendar for Expats in Spain 2026

16. Additional FAQs

Can I choose the Beckham regime if I am already self-employed in Spain?

No. The Beckham regime requires that the relocation be the reason for starting activity in Spain. If you were already a Spanish tax resident or already had self-employment activity in Spain, you cannot access the regime. The only exception is if you have been resident outside Spain for the five preceding tax years and are now starting a new (different) activity.

Is the Beckham regime compatible with the flat-rate (modules) system or simplified direct assessment?

No. The Beckham regime is incompatible with the simplified direct assessment (módulos). Self-employed persons under Beckham must use standard direct assessment.

Can I defer payment of the IRPF or the ISF?

The AEAT allows deferrals and instalment payments via application, with interest accruing at the late payment rate. The deferral requires evidencing temporary financial difficulties and staying within certain thresholds. For ISF and IP, deferrals are less common than for IRPF, but technically possible.

What prior non-residency documentation must I provide?

The AEAT accepts tax residency certificates issued by the tax authority of the country where you previously resided, as well as supporting documentation (employment contracts, utility bills from the foreign home, children’s school records). The burden of proof rests with the taxpayer.

How does the Beckham regime affect joint tax filing?

Under the Beckham regime, it is not possible to file jointly with a spouse under the ordinary IRPF rules. If the spouse is also under the Beckham regime, each files their own Modelo 151 individually.

17. Sources and Legal References

This guide is based on legislation in force as of the publication date (May 2026) and DGT binding rulings available at that time. The main sources are:

Spanish legislation:

• Ley 35/2006, de 28 de noviembre, del IRPF (LIRPF) — art. 9 (residency), art. 93 (Beckham), art. 17 (employment income)
• Real Decreto 439/2007, IRPF Regulations (RIRPF) — arts. 113-120 (Beckham special regime)
• Ley 28/2022, de 21 de diciembre, de Startups (BOE-A-2022-21739) — Beckham reform
• Ley 19/1991, de 6 de junio, del Impuesto sobre el Patrimonio
• Ley 38/2022, de 27 de diciembre, Solidarity Tax on Large Fortunes (BOE-A-2022-22685)
• Ley 29/1987, de 18 de diciembre, del Impuesto sobre Sucesiones y Donaciones (LISD)
• Ley General Tributaria (LGT), art. 38 ter — Modelo 721 and crypto reporting
• Real Decreto 249/2023 — Modelo 721
• Ley 14/2013, de 27 de septiembre, de apoyo a emprendedores — entrepreneur and digital nomad visas

Double Tax Treaties:

• Spain-UK DTT (1975, updated 2021)
• Spain-Germany DTT (DBA 2011, BOE-A-2012-9094)
• Spain-France DTT (1995, BOE-A-1995-28063)
• Spain-US DTT (1990, BOE-A-1991-25462)

Rulings and case law:

• DGT Binding Ruling V1207-25 and V1209-25 (Beckham regime and digital nomads)
• CJEU, judgment of 3 September 2014, Case C-127/12 (ISD for non-residents)
• STC 182/2021, of 26 October (municipal capital gains tax)
• Modelo 149 — AEAT
• Modelo 151 — AEAT
• Modelo 720 — AEAT
• Modelo 721 — AEAT

For a personalised consultation on your situation as an expat in Spain, contact the BMC international tax team, led by Javier Moreno. Each situation is different and this article does not substitute individual professional advice.