Germans Moving to Spain 2026 — DTT, Wegzugsteuer §6 AStG and Beckham Law

Germans are Spain’s third-largest EU community, after Romanians and Italians. About 132,000 German nationals live in Spain, and about 180,000 residents were born in Germany (INE, Estadística Continua de Población, 1 January 2025). The INE Padrón counted a peak of about 197,000 German nationals in 2012; the figure fell to about 110,000 between 2017 and 2021 and has risen since. At 1 January 2022 the INE Padrón counted about 19,000 German nationals in the Balearic Islands and about 10,500 in the province of Málaga, which includes the Costa del Sol and Marbella; the Costa Blanca (Alicante, Dénia, Jávea) and the Canary Islands (Tenerife, Gran Canaria) add tens of thousands more.

Behind this figure are very different profiles: retirees who prefer the Mediterranean climate to the German winter; professionals seconded to Madrid or Barcelona by multinationals; freelancers and remote workers who want to leverage the Ley 28/2022 Startups Act and the Beckham regime; and entrepreneurs and high-net-worth families looking for an optimally structured tax environment.

This guide is the practical reference for the German national or family considering a move to Spain in 2026. It covers the Spain-Germany DTT in its current form, the Wegzugsteuer §6 AStG and its payment in instalments, the Beckham Law, DRV pension taxation, the interaction with German inheritance tax (Erbschaftsteuer), and the Modelo 720.

Why Germans choose Spain in 2026

Climate and lifestyle. The contrast between the central European winter and the Spanish Mediterranean is the oldest and most resilient driver. For German retirees, relocating to Mallorca, the Costa del Sol or the Canary Islands has been a time-honoured life decision. For younger professionals, the combination of dynamic cities like Madrid and Barcelona with relatively moderate living costs (compared to Munich, Hamburg or Frankfurt) adds economic appeal.

Tax efficiency for professionals and entrepreneurs. The combination of the Beckham regime (24% flat tax for 6 years on Spanish income, exemption on foreign income) and the option to pay the §6 AStG exit tax in seven annual instalments creates a window of high fiscal efficiency for GmbH shareholders, independent professionals and executives with international income streams.

EU single market access. As an EU citizen, a German resident in Spain retains all single-market rights: freedom of establishment, access to the Spanish health system after joining the Seguridad Social, and — after 10 years of residence — the right to apply for Spanish citizenship.

Registration as an EU citizen in Spain

As EU citizens, Germans exercise freedom of movement without a visa. The formal steps are:

Empadronamiento: Registration at the local town hall (Padrón Municipal). The essential starting point — without it, virtually no Spanish administrative process can proceed.

EU Citizen Registration Certificate (Certificado de Registro de Ciudadano de la UE): For stays over 3 months, EU citizens register with the Central Foreigners Register and receive a certificate containing the NIE (Número de Identificación de Extranjero). Without a NIE, no bank account can be opened, no contract signed, and no tax return filed.

Tax residency: Arises automatically under Art. 9 LIRPF when the taxpayer spends more than 183 days in Spain during the tax year, or has their principal economic activity or interests in Spain. Tax residency is independent of administrative registration.

Spain-Germany DTT (BOE-A-2012-10212) — Income allocation by type

The Spain-Germany DTT in force is the Convention of 3 February 2011 with its Protocol (BOE-A-2012-10212), in force since 18 October 2012 and applicable from 2013; it replaced the 1966 convention. Under the 1966 convention, pensions were taxed only in the state of residence (Art. 19). The 2011 Convention gives Germany a limited source taxing right on statutory pensions first paid from 2015 (Art. 17(2)).

Wegzugsteuer §6 AStG — The critical planning step

The Wegzugsteuer under §6 AStG is the principal tax risk for German entrepreneurs and GmbH shareholders emigrating to Spain. It must be planned before the move — solutions post-border crossing are almost always too late.

What is taxed

§6 Abs. 1 AStG taxes unrealised gains (deemed disposal gain) embedded in Kapitalgesellschaft shareholdings (GmbH, AG, UG, SE) when the shareholder moves from Germany. Conditions:

• Shareholding of 1% or more in any German or foreign Kapitalgesellschaft
• The shareholding of at least 1% must have existed at any time within the last five years (§17(1) EStG)
• Unlimited German tax liability for at least 7 of the last 12 years before departure (§6 Abs. 2 AStG)

Instalments instead of the unlimited EU deferral since 2022

The ATAD Implementation Act of 25 June 2021 (BGBl. I p. 2035) abolished the former unlimited deferral for moves to EU/EEA states. For exits from 1 January 2022, the Wegzugsteuer can be paid, on application, in seven equal, interest-free annual instalments, and the application is as a rule granted only against security (§6 Abs. 4 AStG). The old deferral applies only to exits before 2022 (§21 Abs. 3 AStG).

Practical consequence: The German GmbH shareholder moving to Spain must budget for the exit tax: the first instalment is due one month after the assessment notice and the others on 31 July of each following year. The outstanding tax falls due early if an instalment is missed, the shares are sold, or distributions exceed a quarter of the value of the shares. If the absence is only temporary and the taxpayer becomes German tax resident again within seven years (extendable to twelve), the tax claim can lapse (§6 Abs. 3 AStG).

Beckham Law for German nationals

The Beckham Law (Art. 93 LIRPF, reformed by Ley 28/2022 de Startups) is the most powerful tax optimisation tool available to German professionals during their first 6 years in Spain.

Key features:

• 24% flat rate on Spanish-source income up to €600,000 (above €600,000: 47%)
• Full exemption from Spanish tax on foreign-source income (German dividends, interest, rental income, capital gains)
• Duration: 6 years (year of arrival + 5 more)
• Application deadline: Modelo 149 must be filed within 6 months of first day of activity in Spain — this deadline is absolute and irrevocable

Eligible categories under Art. 93 LIRPF:

1. Employees seconded to Spain or newly hired by Spanish employers
2. Remote workers (nómadas digitales) for non-Spanish employers — expressly included since Ley 28/2022
3. Entrepreneurs with startup visa in qualifying sectors
4. Directors of non-affiliated Spanish companies

DRV pension — Spanish taxation since 2011

Under the Convention of 3 February 2011 (BOE-A-2012-10212), DRV pensions of residents in Spain are taxed in Spain; Germany may also tax pensions first paid from 1 January 2015, up to 5% of the gross amount (10% for a first payment from 2030), under Art. 17(2) DTT and point VI of the Protocol. The procedure:

1. Request a Spanish Tax Residence Certificate from the AEAT
2. Declare the DRV pension in the Spanish income tax return as employment income
3. Credit any German tax levied under Art. 17(2) DTT against the Spanish tax (Art. 22 DTT)

Civil-service pensions (Beamtenpensionen) remain taxable in Germany under the government-function principle (Art. 18(2) DTT).

Anonymous BMC case patterns

Case 1 — Munich entrepreneur, Mallorca: A 52-year-old Munich entrepreneur with a 20% GmbH shareholding (unrealised gains €1.8m) planned a move to Mallorca. BMC coordinated with his Munich adviser to report the exit tax, apply for payment in seven instalments under §6 Abs. 4 AStG and file the Beckham Modelo 149. The combination of instalment payment and Beckham foreign-income exemption produced an effective tax rate below 20% on distributions during the first 6 years. Estimated net saving vs remaining in Germany: ~€480,000.

Case 2 — Hamburg retiree couple, Costa del Sol: A retired Hamburg couple with DRV pensions and a substantial German securities portfolio relocated to Marbella. BMC prepared the Modelo 720 for German bank accounts and shares, and manages annual Spanish IRPF returns with credit for German dividend withholding.

Spain vs Germany — Direct Tax Comparison (2026)

The Beckham regime’s 24% flat rate vs Germany’s 45% + solidarity surcharge marginal rate represents a potential saving of over 20 percentage points on Spanish-source income. For a German professional earning €300,000 annually, the annual tax saving vs remaining in Germany exceeds €60,000.

Autonomous Community Selection — Key Decision for German Residents

Beyond the national IRPF, German residents in Spain must consider the regional tax layer:

Community of Madrid:

• Regional IRPF rate: lower than Balearics, competitive nationally
• Wealth tax: 100% bonificación → effectively 0%
• Inheritance tax: 99% bonificación for direct-line heirs
• Best for: HNW families, entrepreneurs with large estates

Andalusia (Costa del Sol, Marbella, Málaga):

• Wealth tax: 100% bonificación → effectively 0%
• Inheritance tax: 99% bonificación for direct-line heirs
• Best for: Retirees and HNW families preferring the Mediterranean lifestyle

Balearic Islands (Mallorca):

• Wealth tax: Progressive scale up to 3.45% on net assets
• IRPF regional rate: higher than Madrid and Andalusia for high earners
• Inheritance tax: More complex than Andalusia/Madrid, but improving
• Best for: Those prioritising lifestyle above tax optimisation

Canary Islands (Las Palmas, Tenerife):

• ZEC (Zona Especial Canaria): Corporate tax of 4% for qualifying businesses
• IGIC (local VAT equivalent): 7% vs mainland 21% standard VAT
• IRPF: Standard national rules with some regional modifications
• Best for: German entrepreneurs in qualifying international trade activities

German Expat Community and Practical Life in Spain

German-Language Infrastructure

Germany’s expat community in Spain is the most established and best-resourced of any non-Spanish European group. In Mallorca, the Mallorca Zeitung (daily newspaper in German), German bookshops, German bakeries and German-speaking doctors have created a seamless German-language infrastructure. On the Costa del Sol, Marbella’s Golden Mile and Fuengirola’s Carvajal neighbourhood have German butchers, bakeries, sports clubs (Tennisclub, Golfclub) and a German-speaking school.

Healthcare for German Residents

The Spanish public health system (Sistema Nacional de Salud) is accessible to German residents who register with the Seguridad Social. Many Germans opt for private health insurance alongside or instead of public coverage: Sanitas, Adeslas and Asisa offer plans with German-speaking doctors (Deutschsprachige Ärzte) in all major German expat locations. Key private hospitals include Hospital Quirónsalud Marbella, Clínica Rotger in Palma and Hospital Universitario La Paz in Madrid.

German Schools in Spain

German families moving to Spain with school-age children have excellent options: Deutsche Schule Madrid (founded 1896), Deutsche Schule Málaga, Deutsche Schule Palma de Mallorca, Deutsche Schule Tenerife and Deutsche Schule Las Palmas — all follow the German Bildungsplan and award the Abitur, recognised for German university entry. All receive partial funding from the German Kultusministerkonferenz.

Banking and Financial Services

German residents frequently maintain their German bank accounts (Deutsche Bank, Commerzbank, Sparkasse, Volksbank) for German transactions and open a Spanish account (Santander, BBVA, CaixaBank) for daily life in Spain. N26 (German-founded neobank) is widely used for international transfers. All German accounts with balances above €50,000 must be declared in the Modelo 720 — German residents in Spain are subject to full AEAT reporting obligations.

Post-Beckham Planning — Year 7 and Beyond

The Beckham regime lasts 6 years. German nationals planning a long-term life in Spain must prepare for the post-Beckham phase from year 3 or 4 at the latest:

Strategic options:

1. Realise German capital gains during Beckham: GmbH share disposals, German fund gains and other German capital gains realised during the Beckham period are exempt from Spanish tax under the foreign-income exemption. Deferring these to the post-Beckham period can significantly increase the tax burden.

2. Spanish ETVE holding vehicle: German entrepreneurs receiving dividends from German GmbHs can consider establishing a Spanish ETVE (Entidad de Tenencia de Valores Extranjeros — equivalent to a participation exemption holding company) to receive dividends at the corporate IS rate (25%) rather than the IRPF rate (combined top rate of 45% to 53.85% depending on the region, 2026).

3. Regional residence optimisation: Choosing Madrid or Andalusia over the Balearics for primary residence can reduce wealth tax and inheritance tax exposure substantially in the post-Beckham years.

4. German pension timing: For German retirees approaching DRV pension age, timing the Spanish tax residency change around the start of DRV payments (taking into account that, under Art. 17(2) of the 2011 Convention, Germany may tax up to 5% of DRV pensions first paid from 2015) is a planning opportunity worth quantifying.

Cross-references

• DACH Pillar: Germans, Austrians and Swiss moving to Spain 2026: DACH relocation guide
• Wegzugsteuer guide: German exit tax (Wegzugsteuer) when moving to Spain 2026
• Beckham Law: Beckham Law — complete guide 2026