Mbappé Law 2026: Madrid's 20% deduction for new residents who invest

If you move to Madrid from abroad, you can deduct 20% of what you invest in securities from your regional income tax, provided you meet Article 17 bis of Madrid's Legislative Decree 1/2010, added by Law 4/2024. Many sources present it as an add-on to the Beckham regime, but the two do not stack: the deduction applies to the regional share of IRPF, and a Beckham taxpayer has no regional share.

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BMC compares, for your case, the Beckham regime with ordinary IRPF plus the Madrid deduction, checks which investments meet Article 17 bis and by when, and applies the deduction in your income tax return.

  • The Mbappé Law is the popular name for Article 17 bis of Madrid's Legislative Decree 1/2010, added by Law 4/2024

    a deduction of 20% of the acquisition value of certain securities.

  • Requirements

    no Spanish residence in the previous five years, becoming a Madrid IRPF taxpayer from 2024, investing in the year of the move or the next, and holding the investment for six years.

  • Assets

    debt and equity in any entity, listed or not; in unlisted entities, a 40% cap together with relatives and no management role.

  • It does not stack with the Beckham regime

    it is a deduction from the regional share of IRPF, and Article 93 LIRPF taxes on a single scale with no regional share.

How we work

From first contact to case completion

  1. Comparison before the move

    Before you move we compare two scenarios for your first six years in Madrid, the Beckham regime (Art. 93 LIRPF) and ordinary IRPF with the Article 17 bis deduction. The deduction only fits the second, because it needs a regional share.

  2. Choosing the investments

    We check that the securities chosen fit Article 17 bis (debt or equity in any entity) and, for unlisted entities, the 40% cap with relatives and the absence of a management role.

  3. Timing

    The investment is made in the year you acquire Madrid residence or the next (for Spanish entities, also the year before) and is held for six years; sales only count if everything is reinvested within one month.

  4. Return and monitoring

    We apply the deduction in your IRPF return and, if the tax due is not enough, in the following five years, and we monitor that Madrid residence and the investment are maintained.

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The problem

If you move to Madrid from abroad, you can deduct 20% of what you invest in securities from your regional income tax, provided you meet Article 17 bis of Madrid's Legislative Decree 1/2010, added by Law 4/2024. Many sources present it as an add-on to the Beckham regime, but the two do not stack: the deduction applies to the regional share of IRPF, and a Beckham taxpayer has no regional share.

Our solution

BMC compares, for your case, the Beckham regime with ordinary IRPF plus the Madrid deduction, checks which investments meet Article 17 bis and by when, and applies the deduction in your income tax return.

Process

How we do it

1

Comparison before the move

Before you move we compare two scenarios for your first six years in Madrid, the Beckham regime (Art. 93 LIRPF) and ordinary IRPF with the Article 17 bis deduction. The deduction only fits the second, because it needs a regional share.

2

Choosing the investments

We check that the securities chosen fit Article 17 bis (debt or equity in any entity) and, for unlisted entities, the 40% cap with relatives and the absence of a management role.

3

Timing

The investment is made in the year you acquire Madrid residence or the next (for Spanish entities, also the year before) and is held for six years; sales only count if everything is reinvested within one month.

4

Return and monitoring

We apply the deduction in your IRPF return and, if the tax due is not enough, in the following five years, and we monitor that Madrid residence and the investment are maintained.

20%
Deduction on the acquisition value of the investment (Art. 17 bis.1 Madrid Legislative Decree 1/2010)
5 years
No Spanish residence in the five years before the move (Art. 17 bis.2.c)
6 years
Minimum holding period of the investment (Art. 17 bis.2.b)
40%
Maximum stake with relatives in unlisted entities (Art. 17 bis.2.a)

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Guide: Madrid's investment deduction for new residents (Mbappé Law)

The so-called Mbappé Law is a Madrid regional income tax deduction for people who move to Madrid from abroad and invest. It is Article 17 bis of Madrid’s Legislative Decree 1/2010, added by Madrid Law 4/2024 of 20 November (BOCM of 28 November 2024; BOE-A-2025-3302), and it applies from tax year 2024.

Short answer: someone who has not been resident in Spain in the previous five years and becomes a Madrid IRPF taxpayer can deduct 20% of what they invest in certain securities in the year of the move or the following year, provided they keep the investment for six years. It does not stack with the Beckham Law: the deduction is applied against the regional share of IRPF, and the Article 93 LIRPF regime has no regional share. In practice you choose one or the other.

What Article 17 bis says

  • Amount: 20% of the acquisition value, including acquisition costs and taxes and excluding interest (Art. 17 bis.1).
  • Who: individuals not resident in Spain who become IRPF taxpayers in the Community of Madrid from 1 January 2024 and who were not resident in Spain in the five years before the change of residence (Art. 17 bis.2.c and 17 bis.4).
  • Which assets: securities representing loans to third parties (debt) and securities representing shares in the equity of any type of entity, listed or not (Art. 17 bis.1).
  • Limits for unlisted entities: the entity cannot be in a tax haven; the taxpayer’s stake together with spouse and relatives up to the second degree cannot exceed 40% of the capital or voting rights; and the taxpayer cannot hold executive or management functions or an employment relationship in the entity (Art. 17 bis.2.a).

Deadlines and holding period

  • The investment is made in the year Madrid tax residence is acquired or the following year; for securities of Spanish entities, also in the previous year (Art. 17 bis.2.b).
  • It must be held for six years. A sale is allowed only if the full amount is reinvested within one month in qualifying assets (Art. 17 bis.2.b).
  • The deduction is applied in the year of the investment and, if the tax due is not enough, in the following five years, after the other regional deductions (Art. 17 bis.3).
  • You must remain a Madrid IRPF taxpayer until the last year of the holding period. Losing Madrid residence or selling without full reinvestment means losing the deduction applied (Art. 17 bis.4).
  • For the same investments, it cannot be combined with the deductions of Articles 15 and 17 of the same decree (Art. 17 bis.5).

Why it does not stack with the Beckham Law

Spanish regions regulate deductions from the regional share of IRPF (Article 46 of Law 22/2009), and Madrid’s Legislative Decree 1/2010 itself groups its deductions under “Deductions from the regional share”.

Under the Beckham regime, IRPF is calculated under the non-resident income tax rules with a single scale: 24% up to €600,000 of taxable base and 47% above, with its own scale for savings income (Art. 93.2 of Law 35/2006). There is no regional share against which the Madrid deduction could be applied.

So the real choice for your first six years in Madrid is between two paths:

  1. Beckham regime: 24% on employment income up to €600,000 and, in general, no Spanish tax on foreign-source income.
  2. Ordinary IRPF with the Madrid deduction: state plus Madrid regional rates on worldwide income, minus 20% of the investments that meet Article 17 bis.

Which one is better depends on your Spanish income, your foreign income, the amount you plan to invest and whether you want to keep that investment for six years in Madrid. We calculate it in the first meeting, which is free.

Sources

Related pages: Glossary: tax residency · International tax · Madrid office

General information. The applicable rule is Article 17 bis of the Community of Madrid’s Legislative Decree 1/2010 as currently in force.

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FAQ

Frequently asked questions

It is the popular name for the deduction in Article 17 bis of the Community of Madrid's Legislative Decree 1/2010, added by Law 4/2024 of 20 November, after the public debate around Kylian Mbappé's signing with Real Madrid. It allows new residents to deduct from IRPF 20% of the acquisition value of certain investments. It is not a special regime and does not remove the regional share of the tax.
Individuals not resident in Spain who become IRPF taxpayers in the Community of Madrid from 1 January 2024 and who were not resident in Spain in the five years before the change of residence (Art. 17 bis.2.c and 17 bis.4). They must also remain Madrid taxpayers until the end of the holding period.
Not in the same tax year. The Madrid deduction is applied against the regional share of IRPF (Article 46 of Law 22/2009 and Article 3 of Madrid's Legislative Decree 1/2010). A Beckham taxpayer calculates the tax under the non-resident rules with a single 24% and 47% scale (Article 93.2 LIRPF), with no regional share to deduct from. The two paths have to be compared for your case.
Securities representing loans to third parties and securities representing shares in the equity of any type of entity, listed or not (Art. 17 bis.1). For unlisted entities, the entity cannot be in a tax haven, the stake with spouse and relatives up to the second degree cannot exceed 40%, and the taxpayer cannot hold a management role or an employment relationship there.
In the year Madrid tax residence is acquired or the following year; for securities of Spanish entities, also in the previous year. The investment must be held for six years, and a sale only counts if the full amount is reinvested within one month in qualifying assets (Art. 17 bis.2.b). The deduction is applied in the year of the investment and, if the tax due is not enough, in the following five years.
The deduction applied is lost. Article 17 bis.4 provides this for losing Madrid residence during the holding period and for not holding the investment, including a sale without full reinvestment.
It depends on your Spanish employment income, your foreign income, the amount you plan to invest and whether you want to hold that investment for six years in Madrid. The Beckham regime taxes employment income at 24% up to €600,000 and generally does not tax foreign income in Spain; the Madrid deduction applies within ordinary IRPF, which taxes worldwide income. We calculate it in the first 30-minute meeting, which is free.

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Frequently asked questions

Questions about Mbappé Law Madrid 2026: 20% Deduction for New Residents Who Invest | BMC

It is the popular name for the deduction in Article 17 bis of the Community of Madrid's Legislative Decree 1/2010, added by Law 4/2024 of 20 November, after the public debate around Kylian Mbappé's signing with Real Madrid. It allows new residents to deduct from IRPF 20% of the acquisition value of certain investments. It is not a special regime and does not remove the regional share of the tax.
Individuals not resident in Spain who become IRPF taxpayers in the Community of Madrid from 1 January 2024 and who were not resident in Spain in the five years before the change of residence (Art. 17 bis.2.c and 17 bis.4). They must also remain Madrid taxpayers until the end of the holding period.
Not in the same tax year. The Madrid deduction is applied against the regional share of IRPF (Article 46 of Law 22/2009 and Article 3 of Madrid's Legislative Decree 1/2010). A Beckham taxpayer calculates the tax under the non-resident rules with a single 24% and 47% scale (Article 93.2 LIRPF), with no regional share to deduct from. The two paths have to be compared for your case.
Securities representing loans to third parties and securities representing shares in the equity of any type of entity, listed or not (Art. 17 bis.1). For unlisted entities, the entity cannot be in a tax haven, the stake with spouse and relatives up to the second degree cannot exceed 40%, and the taxpayer cannot hold a management role or an employment relationship there.
In the year Madrid tax residence is acquired or the following year; for securities of Spanish entities, also in the previous year. The investment must be held for six years, and a sale only counts if the full amount is reinvested within one month in qualifying assets (Art. 17 bis.2.b). The deduction is applied in the year of the investment and, if the tax due is not enough, in the following five years.
The deduction applied is lost. Article 17 bis.4 provides this for losing Madrid residence during the holding period and for not holding the investment, including a sale without full reinvestment.
It depends on your Spanish employment income, your foreign income, the amount you plan to invest and whether you want to hold that investment for six years in Madrid. The Beckham regime taxes employment income at 24% up to €600,000 and generally does not tax foreign income in Spain; the Madrid deduction applies within ordinary IRPF, which taxes worldwide income. We calculate it in the first 30-minute meeting, which is free.

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