Mbappé Law 2026 — Madrid's regional tax deduction that, combined with the Beckham Law, can reduce your effective rate to historic lows

The Beckham Law — the special tax regime under Article 93 of Spain’s IRPF Act that allows new residents to pay a flat 24% rate on Spanish-source income for six years — is the best-known instrument in Spain’s expatriate tax toolkit. What most international professionals do not know in 2026 is that the Comunidad de Madrid has gone a step further: it has introduced, through Decreto Legislativo 1/2024 [VERIFY: exact BOCM reference], a 100% deduction on the regional IRPF quota for new residents who invest in qualifying Spanish assets.

This measure — colloquially known as the Mbappé Law, after the public debate surrounding the tax treatment applicable to footballer Kylian Mbappé at the time of his signing by Real Madrid — transforms the international tax landscape for high-net-worth new residents in Spain. Combined with the Beckham regime, it makes it possible to achieve effective rates on Spanish-source income that have no equivalent in any other Spanish autonomous community and that are competitive with the best European talent- and capital-attraction regimes.

This guide analyses in depth the regulatory framework, access requirements, the stacking mechanism with the Beckham Law, the qualifying investments required, the application procedure and the most common mistakes that can result in losing this fiscal opportunity.

Regulatory Framework: the Decreto Legislativo 1/2024 of the Comunidad de Madrid

Autonomous community tax powers within the IRPF

The Spanish IRPF is a tax partially devolved to the autonomous communities. Each community has legislative power over the regional tranche of the tax: it can set its own regional rate scale, establish its own deductions and modify the personal and family allowances applicable in its territory. This dual structure — national tranche plus regional tranche — is what opens the door to the Mbappé Law.

The Comunidad de Madrid has historically been the most active Spanish region in using its fiscal legislative powers to reduce the tax burden on its residents: it was a pioneer in eliminating the Wealth Tax (100% bonus it has maintained for years), has applied reductions to the regional IRPF rates and has introduced numerous specific deductions. The regional deduction for investor new residents in Decreto Legislativo 1/2024 is the most ambitious measure in this strategy.

Decreto Legislativo 1/2024: text and scope

The Comunidad de Madrid approved in July 2024 Decreto Legislativo 1/2024 [VERIFY: full official title and BOCM reference], consolidating and updating the regional IRPF normative text. This decree incorporated a new regional deduction specifically targeted at new residents in the Comunidad de Madrid who invest in certain categories of Spanish assets within the first years of their relocation.

The deduction is technically structured around the regional IRPF quota: the tranche of income tax corresponding to the Comunidad de Madrid. In the Spanish IRPF system, the total rate is split between a national component — fixed by the central State, applicable throughout the territory — and a regional component — set by each community, which can vary significantly between regions. For taxpayers combining the Beckham regime with the Mbappé Law, the deduction operates on the regional share of the quota, reducing the overall effective rate.

Interaction with Article 93 IRPF Act (Beckham Law)

The Beckham Law operates on the national tranche of the IRPF: it sets a flat rate of 24% on Spanish-source income up to €600,000 and excludes foreign-source income from Spanish taxation. The Mbappé Law, operating on the regional tranche, is normatively independent of the Beckham regime and can be applied simultaneously.

The technical key is that Article 93 IRPF Act generates a special quota calculated differently from the standard IRPF quota of an ordinary resident. The precise compatibility between the Beckham special quota and the Madrid regional deduction under Decreto 1/2024 is a technical point requiring verification in the implementing regulations and, where applicable, in the binding ruling from the Directorate General of Taxes (DGT) [VERIFY: existence of DGT binding rulings on this compatibility].

Who Can Benefit from the Mbappé Law in 2026

Subjective requirements: the new Madrid resident

The Madrid regional deduction is designed for new tax residents in the Comunidad de Madrid. This implies, in general terms [VERIFY: literal text of Decreto 1/2024]:

1. No prior residence in Spain — or at least not in the Comunidad de Madrid — for a specified number of years prior to relocation. In line with the philosophy of the Beckham regime (five years of prior non-residency), a similar or shorter requirement in the regional framework is to be expected.

2. Effective transfer of habitual residence to the Comunidad de Madrid: the taxpayer must become a tax resident for the purposes of the IRPF Act (Article 9: presence in Spanish territory for more than 183 days, or main centre of activities and economic interests in Spain) and, within that framework, have their habitual residence in the Comunidad de Madrid.

3. Making qualifying investments in the assets and within the timeframes set by Decreto Legislativo 1/2024.

The target profile: international professionals and HNW individuals

The regime is aimed primarily at four profiles:

• International executives and senior professionals relocating to Madrid on behalf of a company (compatible with the Beckham Law).
• Entrepreneurs and high-net-worth investors who transfer their residence and investment activity to Madrid.
• Family office and private wealth managers seeking a stable and competitive tax framework.
• Independent professionals and consultants with Spanish-source income and investable financial assets.

In all these cases, the ability to invest in qualifying Madrid assets — particularly equity in unlisted companies with activities in the region — is the differentiating requirement compared with other fiscal attraction regimes.

Compatibility with the digital nomad visa and the startup regime

Taxpayers accessing Spain via the digital nomad visa or the entrepreneur authorisation under Act 14/2013 can combine this with the national Beckham Law. The Madrid regional Mbappé Law adds an additional layer if they establish their residence in the Comunidad de Madrid. For digital nomads with predominantly foreign-source income (which is exempt under the Beckham Law), the Mbappé Law may be less quantitatively determinative in absolute terms, but it still reduces the burden on the Spanish-source income that does attract taxation.

How It Stacks with the Beckham Law: the Mechanism Explained

The architecture of the Spanish IRPF: national quota + regional quota

To understand the stacking mechanism, it is necessary to understand the architecture of the IRPF:

• The national rate scale has its own set of brackets, fixed by the State, ranging from 9.5% to 24.5% across different bands of taxable income.
• The regional rate scale is set by each community. The Comunidad de Madrid has maintained one of the lowest regional scales in Spain.
• The combined application of both scales produces the integrated IRPF rate, which in Madrid runs from approximately 19% to 46.5% for employment income in common territory [VERIFY: exact 2026 Madrid regional rate schedule].

The Beckham Law replaces this framework with a flat rate of 24% representing the combined national and regional components under the special regime of Article 93 IRPF Act.

The Mbappé Law operates on the regional component: if the 100% deduction eliminates the regional quota, the effective rate on Spanish-source income approaches solely the national tranche of the Beckham 24%, or potentially reduces the overall burden further if the regional deduction can be applied in articulation with the special regime [VERIFY: precise technical interaction between Decreto 1/2024 and Art. 93 IRPF Act].

Stacking example: €200,000 Spanish-source income

Approximate estimates [VERIFY: calculate using 2026 Madrid regional rate and national/regional split under Art. 93 IRPF Act]. Excludes Social Security contributions and other taxes. Each case requires individual analysis.

Foreign-source income under the stacking arrangement

Under the Beckham Law, foreign-source income — dividends from international portfolios, interest on deposits in foreign financial institutions, rental income from overseas property, capital gains on assets outside Spain — is not taxed in Spain. This point is unaffected by the Mbappé Law, which operates on income that is subject to Spanish taxation. For a professional with mixed income (partly Spanish, partly foreign), the stacking maximises efficiency on the Spanish component whilst the Beckham exemption protects the foreign component.

Comparative burden for a typical HNW profile

For an investor with a family office who transfers residence to Madrid with €300,000 Spanish-source employment income and €200,000 foreign-source capital income:

• Standard IRPF (no special regime): would be taxable in Spain on a €500,000 aggregate base, with a liability of approximately €230,000 (effective rate ~46%).
• Beckham Law only: 24% on the €300,000 Spanish-source income → ~€72,000. Foreign-source income is not taxed. Total: ~€72,000.
• Beckham + Mbappé: the regional deduction reduces the liability on the €300,000 Spanish-source income to approximately €45,000–54,000. Foreign-source income continues to be exempt. Total: ~€45,000–54,000 [VERIFY].

Qualifying Investments: Which Assets Give Access to the Deduction

Spanish government bonds

Securities issued by the Spanish State, the autonomous communities or local entities constitute the most accessible category of qualifying investment. They are liquid, have an active secondary market and their classification as qualifying assets under Decreto 1/2024 makes them the easiest entry point for taxpayers wishing to secure compliance with the investment requirement [VERIFY: specific conditions in the Decreto: holding period, investment threshold].

Equity in unlisted companies with activities in Madrid

This is the category with the greatest potential — and also the greatest complexity. Decreto 1/2024 includes as qualifying assets equity interests in unlisted entities whose principal economic activity is based in the Comunidad de Madrid [VERIFY: exact requirements: percentage of activity, minimum headcount, excluded sectors, etc.].

This category is particularly relevant for family office investors who wish to combine their relocation to Madrid with an investment strategy in the Madrid entrepreneurial ecosystem: technology startups, venture capital funds constituted in Madrid, unlisted Madrid property companies, and so forth. Investment in this type of asset can also generate returns superior to those of government bonds, turning the investment requirement into a financial opportunity in its own right.

Real estate assets in the Comunidad de Madrid

[VERIFY: The inclusion of real estate assets in the Comunidad de Madrid as qualifying investments must be verified in the definitive text of Decreto Legislativo 1/2024. Some preliminary analyses suggest that certain forms of real estate investment in the region may be within the scope of the deduction, but this point requires regulatory confirmation before being factored into any planning exercise.]

If real estate is indeed included, this would open a particularly attractive integrated planning avenue: a taxpayer who acquires a primary residence or investment property in Madrid could simultaneously satisfy the relocation effectiveness requirement (by establishing residence there) and the qualifying investment requirement (by counting the property as an eligible asset).

Investment thresholds and timeframes

[VERIFY: Decreto Legislativo 1/2024 must specify: (a) a minimum aggregate investment threshold to access the deduction; (b) the maximum timeframe within which investments must be made from the date of transfer of residence to Madrid; and (c) the minimum holding period to avoid regularisation of the deduction. These details are critical for planning purposes and must be obtained directly from the regulatory text before advising any client.]

Application Procedure and Timing

How to apply the deduction

The Madrid regional deduction under Decreto 1/2024 is applied in the IRPF self-assessment for the tax period in which the taxpayer satisfies the requirements [VERIFY: exact filing model — modelo 100 with the Madrid autonomous community box, or a specific supplementary self-assessment].

For taxpayers simultaneously applying the Beckham Law (modelo 151), the technical articulation between both models and between the Article 93 IRPF Act special quota and the Decreto 1/2024 regional deduction must be carefully documented [VERIFY: confirmation via DGT binding ruling or ATAM — Madrid regional tax agency — administrative criterion].

Documentation of qualifying investments

The taxpayer must evidence to the Madrid regional tax agency (ATAM) that qualifying investments have been made within the established timeframe. Documentation typically required includes:

• Public deed or private contract with a certified date in the case of equity interests in unlisted companies.
• Certificate from the issuing or depositary entity in the case of government bond securities.
• Purchase deed and updated Land Registry entry in the case of real estate assets (if included as qualifying).

Correct documentation of the investments and their maintenance for the required period is the key to avoiding subsequent regularisations in any verification procedure.

Filing deadlines

The deduction is applied within the standard IRPF filing period, normally between 2 April and 30 June of the year following the relevant tax period (in accordance with the AEAT’s annual calendar). No special deadline for this specific regional deduction is known to exist [VERIFY].

Comparative Analysis: Madrid Mbappé vs Other Regional and European Options

Madrid (Mbappé + Beckham) vs Andalusia (wealth tax shield)

Andalusia approved in 2022 a 100% bonus on the Wealth Tax for its residents, following the Madrid model. However, Andalusia has no equivalent measure to the Mbappé Law on the regional IRPF quota. For a new resident with employment and capital income, Madrid offers the most powerful combination in 2026: Mbappé Law (0% regional IRPF quota) + 100% Wealth Tax bonus + Beckham Law (24% national rate). Andalusia offers only the Wealth Tax bonus without the Mbappé equivalent on IRPF.

Madrid vs the Basque Country and Navarre (foral regimes)

The Basque Country and Navarre have their own foral IRPF regimes, historically attractive for certain profiles. Maximum foral rates are below those of common territory, and there are specific deductions. However, the foral regimes do not offer a combination equivalent to Beckham + Mbappé in terms of a flat rate combined with a full regional deduction. For international professionals relocating to Spain, the Madrid combination is generally more advantageous, particularly during the first six years of residence.

Madrid vs Lisbon (IFICI) and Amsterdam (30% ruling)

The main European competitors are:

• Portugal IFICI (2024 NHR successor): reduced 20% rate on qualifying Portuguese-source income for 10 years, with potential exemption on foreign-source income. Less flexible than Beckham + Mbappé for profiles with predominantly Spanish-source employment income.
• Netherlands 30% ruling: 30% reduction in the tax base for internationally recruited workers, for a maximum of five years. Effective for employment income, but without the foreign-source income exemption offered by the Beckham Law.
• United Kingdom non-domiciled regime: undergoing significant reform that limits its historic advantages.

For professionals with Spanish-source income and a diversified financial portfolio, the Madrid Beckham + Mbappé combination offers an effective rate that no European equivalent can match in absolute terms during the first six years.

Madrid vs Barcelona: the intra-Spanish differential

The contrast with Catalonia is particularly relevant for professionals considering either city. Catalonia has the highest regional IRPF rate in Spain (up to 25.5% regional for income above €300,000), has no Wealth Tax bonus, and has no equivalent to the Mbappé Law. The fiscal differential between Madrid and Barcelona for a high-net-worth resident under the Beckham Law can exceed 10 percentage points of effective rate — a compelling argument in the location decision.

Common Mistakes to Avoid

1. Not verifying the technical compatibility between Beckham and the regional deduction before relocating

The stacking of the Beckham Law with the Madrid regional deduction under Decreto 1/2024 is technically complex. The Article 93 IRPF Act special quota has a different structure from the standard IRPF quota of an ordinary resident, and the interaction between both provisions — one national, one regional — requires a detailed prior analysis, ideally supported by a DGT binding ruling or applicable administrative case law. Acting without this verification can result in a regularisation with surcharges and late payment interest.

2. Failing to make qualifying investments within the required timeframe

If the taxpayer transfers their residence to Madrid but does not make qualifying investments within the timeframe set by Decreto 1/2024, they lose the right to the regional deduction for that period and potentially for all remaining years of the regime. This is the most costly and most common mistake: the relocation is well planned (with the Beckham Law), but the investment component is deferred and the deadline passes without it having been materialised.

3. Treating the Mbappé Law as automatic

The regional deduction is not automatic simply by virtue of relocating to Madrid. It requires the active fulfilment of the investment requirements, the correct documentation of qualifying investments and their reflection in the regional IRPF self-assessment. A taxpayer who relocates to Madrid under the Beckham Law but does not apply or plan for the regional deduction will be paying more tax than they are legally required to.

4. Investing in non-qualifying assets

Not all investments that might intuitively seem “qualifying” satisfy the requirements of Decreto 1/2024. For example, interests in collective investment vehicles (even if they invest in Madrid companies), shares in publicly listed companies (even if headquartered in Madrid) or certain intermediate holding structures may not fulfil the requirements of the deduction. Prior verification of the qualification of each asset is essential.

5. Not planning the exit phase with sufficient lead time

At the end of the application period — whether of the Beckham Law regime or the regional deduction itself — the taxpayer must manage the change of regime. Holding illiquid assets (equity in unlisted Madrid companies) can create difficulties if the divestment calendar is not coordinated with the expiry of the regimes. Exit planning should begin at least two years before the regimes expire.

The Early Mover Advantage

The Mbappé Law is a 2024 regime. Unlike the Beckham Law, which has been in force for over twenty years and on which there is a consolidated body of administrative and judicial precedent, the Madrid regional deduction under Decreto 1/2024 is still a young regime, with few examples of practical application and on which major international law firms have barely begun to publish analysis.

This implies two things for the professional or investor evaluating a relocation to Madrid:

Opportunity: Those who apply the regime correctly first will benefit from a fiscal window that, if it proves effective, may be reformed or limited in future years — as has happened with similar regimes elsewhere (the Portuguese NHR, the British non-dom). Moving promptly is, in this context, a competitive advantage.

Need for specialist advice: The novelty of the regime means that not all advisers are familiar with its nuances. The risk of incorrect application — whether by excess (claiming more than is available) or by defect (not claiming the full deduction available) — is higher than with established regimes. The choice of adviser is critical.

Since 2007, BMC’s international tax team has managed over 400 Beckham Law applications and has followed the regulatory development of the Madrid regional deduction since its approval. We are among the first practices to have integrated the combined Beckham + Mbappé planning into our standard advisory service for new Madrid residents.

Legal References and Related Resources

Applicable legislation:

• Ley 35/2006, de 28 de noviembre, del Impuesto sobre la Renta de las Personas Físicas — BOE-A-2006-20764
• Real Decreto 439/2007 (IRPF Regulations) — Arts. 113–120 (expatriate regime)
• Ley 28/2022, de 21 de diciembre, de fomento del ecosistema de las empresas emergentes (Startup Act) — BOE-A-2022-21739
• Decreto Legislativo 1/2024 de la Comunidad de Madrid [VERIFY: full title and BOCM reference]

Related pages on this site:

• Beckham Law 2026: complete guide
• Glossary: Beckham Law
• Glossary: Tax residency
• International tax planning

Download our guide:

For a full analysis of Beckham + Mbappé stacking with calculation tables and scenarios by profile, download our 16-page whitepaper or contact BMC’s international tax team directly.

Note: This content is for general information purposes only. Statements marked [VERIFY] correspond to regulatory points pending confirmation in the definitive text of Decreto Legislativo 1/2024 of the Comunidad de Madrid and must be verified before application to any specific situation. BMC recommends not taking any fiscal action based solely on this analysis without prior individual advice.