Mbappé Law 2026 — Madrid's Ley 4/2024 regional investment deduction that, combined with the Beckham Law, can significantly reduce your effective tax rate

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, via Ley 4/2024 (BOCM-20241128-1, 20 November 2024), a regional investment deduction of 20% on the value of qualifying assets, set out in art. 17 bis of Decreto Legislativo 1/2010 of Madrid, 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: Ley 4/2024 and Article 17 bis 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 investment deduction for new residents introduced by Ley 4/2024 (art. 17 bis DL 1/2010 of Madrid) is the most ambitious measure in this strategy.

Ley 4/2024: text and scope

The Comunidad de Madrid approved in November 2024 Ley 4/2024, de 20 de noviembre (BOCM-20241128-1), which added art. 17 bis to Decreto Legislativo 1/2010 (the consolidated Madrid IRPF text). This article introduces a regional investment deduction specifically targeted at new residents in the Comunidad de Madrid who invest in certain categories of qualifying Spanish assets within the first years of their relocation.

The deduction is technically structured as a 20% deduction on the value of qualifying investments and operates on the regional IRPF component. In the Spanish IRPF system, the total rate is split between a national component — fixed by the central State — and a regional component set by each community. For taxpayers combining the Beckham regime with the Mbappé Law, the deduction reduces the regional component of the liability, lowering 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 investment deduction under Ley 4/2024 (art. 17 bis DL 1/2010) requires verification in the implementing regulations and, where applicable, in the binding ruling from the Directorate General of Taxes (DGT). Check the PETETE database for DGT rulings on this point or consult with our team before planning on this basis.

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. Under art. 17 bis of DL 1/2010 of Madrid (as amended by Ley 4/2024), the general requirements are:

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 art. 17 bis of DL 1/2010 of Madrid (as amended by Ley 4/2024); confirm the specific current requirements with our team.

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 (confirm the 2026 Madrid regional IRPF rate schedule against the current DL 1/2010 of Madrid as published in the BOCM).

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 (Ley 4/2024, art. 17 bis DL 1/2010) operates on the regional component: the 20% deduction on the value of qualifying investments reduces the regional quota liability, lowering the overall effective rate when combined with the Beckham flat rate on the national tranche. The precise technical interaction between the Beckham special quota (Modelo 151) and the Ley 4/2024 deduction must be confirmed via DGT ruling or ATAM criterion before planning.

Stacking example: €200,000 Spanish-source income

Approximate estimates. Recalculate using the 2026 Madrid regional rate (DL 1/2010, as published in BOCM) and Art. 93 LIRPF national/regional split before using in client advice. 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 Ley 4/2024 investment deduction reduces the regional component of the liability on the €300,000 Spanish-source income; the combined saving depends on the amount invested in qualifying assets. Foreign-source income continues to be exempt under Beckham. Request an individual calculation from our team.

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 under art. 17 bis of DL 1/2010 of Madrid (Ley 4/2024). They are liquid and have an active secondary market. Confirm the specific holding period, investment threshold, and eligible instruments against the current text of art. 17 bis or with our team before advising.

Equity in unlisted companies with activities in Madrid

This is the category with the greatest potential — and also the greatest complexity. Art. 17 bis of DL 1/2010 of Madrid (Ley 4/2024) includes as qualifying assets equity interests in unlisted entities whose principal economic activity is based in the Comunidad de Madrid. Confirm the exact requirements (% of activity in Madrid, minimum headcount, excluded sectors) against the current text of art. 17 bis or with our team before advising.

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

Art. 17 bis of DL 1/2010 of Madrid (Ley 4/2024) may include certain real estate assets in the Comunidad de Madrid as qualifying investments. The regulatory text and any implementing guidance must be confirmed with our team before advising any client on this basis.

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

The specific requirements under art. 17 bis of DL 1/2010 of Madrid (Ley 4/2024) — including (a) minimum aggregate investment threshold, (b) maximum timeframe from date of transfer, and (c) minimum holding period — must be confirmed against the current text of art. 17 bis before advising any client.

Application Procedure and Timing

How to apply the deduction

The Madrid regional deduction under Ley 4/2024 (art. 17 bis DL 1/2010) is applied in the IRPF self-assessment for the tax period in which the taxpayer satisfies the requirements. Confirm the exact filing model — whether the deduction is claimed in the Modelo 100 Madrid autonomous community box or requires a specific supplementary form — per ATAM criterion or BOCM implementing regulation before filing.

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 Ley 4/2024 investment deduction (art. 17 bis DL 1/2010) must be carefully documented. Seek a DGT binding ruling or ATAM administrative criterion confirming this articulation before advising clients.

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. No special deadline for this specific regional deduction is currently known to exist; confirm in the text of art. 17 bis DL 1/2010 or ATAM implementing guidance before advising.

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 (20% investment deduction reducing the regional IRPF component, Ley 4/2024) + 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 art. 17 bis of DL 1/2010 of Madrid (Ley 4/2024), 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 art. 17 bis of DL 1/2010 of Madrid (Ley 4/2024). 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 Ley 4/2024 investment deduction — 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 (Ley 4/2024) 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 art. 17 bis DL 1/2010 (Ley 4/2024) 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 2010, 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
• Ley 4/2024, de 20 de noviembre, de la Comunidad de Madrid (BOCM-20241128-1) — art. 17 bis of Decreto Legislativo 1/2010 (consolidated Madrid IRPF text)

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. The regulatory framework described (Ley 4/2024, BOCM-20241128-1; art. 17 bis of Decreto Legislativo 1/2010 of Madrid) must be verified against the current text of the legislation before application to any specific situation. BMC recommends not taking any fiscal action based solely on this analysis without prior individual advice.

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