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Moving to Spain from the DACH Region 2026 — The Complete Guide for Germans, Austrians and Swiss

A move from Germany, Austria or Switzerland to Spain triggers a cascade of complex legal and tax obligations: the Wegzugsteuer exit tax (§6 AStG), double taxation treaties, visa requirements for Swiss nationals, NIE registration, and questions about maintaining existing business structures. Most Spanish asesorías do not understand DACH-specific nuances — and most German tax advisors are unfamiliar with Spanish tax law.

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Why BM Consulting

Specialised advice and personal service

BMC is the only bilingual (German/Spanish) advisory firm in Spain that accompanies DACH nationals through the relocation as a comprehensive, coordinated process: from Wegzugsteuer analysis before leaving Germany to tax optimisation in Spain — Beckham Law, ZEC Canarias or standard IRPF with DTA.

  • Over 200,000 Germans live in Spain — Mallorca, Costa del Sol and Madrid are the top DACH high-net-worth destinations.

  • The Wegzugsteuer (§6 AStG) exit tax applies to shareholders with ≥1% in capital companies — but the EU deferral is indefinite (§6 Abs. 4 AStG n.F. since 2022), not 7 years.

  • EU citizens (DE/AT) need no visa, but must register as EU residents and obtain a NIE within the first 3 months in Spain.

  • Swiss nationals (non-EU) can access Spain through the CH-EU Free Movement Agreement — a Tarjeta de Residencia for stays over 90 days.

How we work

From first contact to case completion

  1. Phase 1: Wegzugsteuer Analysis (6-12 months before move)

    Before deregistering your residence in Germany, we analyse all shareholdings in capital companies. Does a taxable unrealised gain exist? Does the EU deferral apply? This is the most critical phase — a mistake here can cost six or seven figures.

  2. Phase 2: Visa & Residency (3-6 months before move)

    EU citizens (DE/AT): registration as EU citizens + NIE. Swiss: Tarjeta de Residencia via CH-EU FMA. Third-country nationals: NLV, DNV, Highly Qualified, or Investor pathway analysis.

  3. Phase 3: Tax Optimisation in Spain (from arrival)

    Analysis of the optimal tax regime: Beckham Law (24% flat, 6 years), ZEC Canarias (4% corporate tax), or standard IRPF with DTA optimisation. Beckham must be applied for within 6 months of starting activity — an absolute, non-extendable deadline.

  4. Phase 4: Business Structure & Compliance

    Keep the German GmbH or set up a Spanish SL? DE-ES holding structure? ZEC for a new venture? AML analysis for DACH capital flows to Spain.

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The problem

A move from Germany, Austria or Switzerland to Spain triggers a cascade of complex legal and tax obligations: the Wegzugsteuer exit tax (§6 AStG), double taxation treaties, visa requirements for Swiss nationals, NIE registration, and questions about maintaining existing business structures. Most Spanish asesorías do not understand DACH-specific nuances — and most German tax advisors are unfamiliar with Spanish tax law.

Our solution

BMC is the only bilingual (German/Spanish) advisory firm in Spain that accompanies DACH nationals through the relocation as a comprehensive, coordinated process: from Wegzugsteuer analysis before leaving Germany to tax optimisation in Spain — Beckham Law, ZEC Canarias or standard IRPF with DTA.

Process

How we do it

1

Phase 1: Wegzugsteuer Analysis (6-12 months before move)

Before deregistering your residence in Germany, we analyse all shareholdings in capital companies. Does a taxable unrealised gain exist? Does the EU deferral apply? This is the most critical phase — a mistake here can cost six or seven figures.

2

Phase 2: Visa & Residency (3-6 months before move)

EU citizens (DE/AT): registration as EU citizens + NIE. Swiss: Tarjeta de Residencia via CH-EU FMA. Third-country nationals: NLV, DNV, Highly Qualified, or Investor pathway analysis.

3

Phase 3: Tax Optimisation in Spain (from arrival)

Analysis of the optimal tax regime: Beckham Law (24% flat, 6 years), ZEC Canarias (4% corporate tax), or standard IRPF with DTA optimisation. Beckham must be applied for within 6 months of starting activity — an absolute, non-extendable deadline.

4

Phase 4: Business Structure & Compliance

Keep the German GmbH or set up a Spanish SL? DE-ES holding structure? ZEC for a new venture? AML analysis for DACH capital flows to Spain.

200,000+
German nationals resident in Spain (INE 2024)
24%
Flat rate under the Beckham Law vs. 47% standard IRPF top rate
Indefinite
EU deferral of Wegzugsteuer (§6 Abs. 4 AStG n.F. since 2022)
4%
Corporate tax rate in ZEC Canarias for qualifying DACH businesses

BMC guided us through the Wegzugsteuer analysis in Germany, the Beckham Law application and the setup of our SL in Marbella. The tax saving over the six years of the Beckham regime exceeds €260,000. Without their bilingual expertise we would have made very costly mistakes.

Thomas Fischer Entrepreneur and Investor, Munich → Marbella, 2024

Download our guide

Guide: DACH Nationals Moving to Spain 2026 — Wegzugsteuer, Visas, Beckham & Business (28 pages)

The DACH region — Germany, Austria and Switzerland — is the second-largest source of high-net-worth relocation to Spain, immediately after Latin America and well ahead of the United Kingdom. Over 200,000 Germans reside in Spain; Austrians and Swiss are joining in growing numbers, drawn by the Mediterranean climate, quality of life, competitive taxation and the infrastructure available for the German-speaking community — particularly in Mallorca, Costa del Sol and Madrid.

The Three Main DACH Destinations in Spain

Mallorca: The German Capital of the Mediterranean

Mallorca has the largest German community outside Germany: over 55,000 registered residents, with an estimated 80,000–100,000 including unregistered long-term residents. The German-speaking infrastructure is exceptional — the Deutsche Schule Mallorca, German-language private medical practices, active business networks, and a well-established community of bilingual lawyers and advisors.

Tax consideration: The Balearic Islands have Spain’s highest Wealth Tax rates (0.28–3.45%). For net worths above €3 million, the annual Wealth Tax can reach tens of thousands of euros. This is why many DACH HNW individuals on Mallorca choose the Beckham Law (which exempts foreign-source wealth from Spanish taxation for 6 years) or hold real estate through corporate structures. Inheritance and gift tax in the Balearics is also significantly higher than in Madrid or Andalusia — a key planning factor for family wealth structures.

Costa del Sol (Marbella, Benahavís, Estepona): The High-Net-Worth Hub

The Andalusian Costa del Sol — particularly the triangle of Marbella, Benahavís and Estepona — is the preferred destination for the highest-net-worth DACH segment: family offices, business entrepreneurs, and professional investors. The combination of the Beckham Law, 0% Wealth Tax in Andalusia, world-class lifestyle infrastructure, and direct flights to Munich, Frankfurt, Vienna and Zurich makes this area the most tax-competitive of the three main DACH destinations.

The fiscal advantage is substantial and concrete: a DACH HNW individual with €5 million in net assets saves between €50,000 and €175,000 per year in Wealth Tax alone compared with equivalent taxation in Germany, Austria or Switzerland — or even in Mallorca. Three German-language private schools operate in the Costa del Sol region, along with large German-speaking gated communities (La Zagaleta, Sierra Blanca, Los Flamingos).

Madrid: For DACH Executives and Entrepreneurs

Madrid attracts a different DACH profile: younger business founders, corporate executives at multinational companies, fund managers, and fintech entrepreneurs. Its advantages are different from the coastal alternatives:

  • Connectivity: Barajas airport offers daily direct routes to all DACH capitals (Berlin, Hamburg, Munich, Frankfurt, Vienna, Zurich, Geneva, Basel)
  • Labour market: Headquarters of the majority of German and Swiss multinationals in Spain (Deutsche Bank, Siemens, BASF, Nestlé, Novartis)
  • Tax profile: Madrid is Spain’s most tax-competitive region — 0% Wealth Tax, reduced IRPF regional rates, full inheritance and gift tax exemption in direct line
  • German schools: Two accredited German-language schools (Colegio Alemán and Colegio Internacional Alemán ADEAG)

This guide is the comprehensive framework for a relocation from the DACH region to Spain: legal requirements, Wegzugsteuer analysis, visa options by nationality, tax optimisation in Spain, and business structure for DACH entrepreneurs and investors.

Why Spain? The DACH High-Net-Worth Perspective

Spain has become the leading destination for DACH high-net-worth individuals in Europe. The reasons are concretely measurable:

Tax Advantages

  • Beckham Law: 24% flat rate on Spanish income up to €600,000 for 6 years — vs. up to 47% in Spain’s standard IRPF or equivalent German top rates
  • Zero wealth tax: Madrid and Andalusia (where most DACH HNW individuals settle) have abolished the Wealth Tax (Impuesto sobre el Patrimonio) — saving up to hundreds of thousands of euros annually for significant net-worth profiles
  • ZEC Canarias: 4% corporate tax rate for qualifying companies on the Canary Islands — one of the most competitive business regimes in the EU
  • Double Taxation Treaties: The DE-ES, AT-ES and CH-ES DTAs prevent double taxation on most income streams

The DACH Segment by Region

RegionGermansAustriansSwiss
Mallorca/Balearics~55,000~8,000~12,000
Costa del Sol~35,000~5,000~9,000
Costa Blanca~28,000~4,000~7,000
Madrid~18,000~4,000~6,000
Barcelona~12,000~3,000~5,000
Canary Islands~15,000~3,000~4,000

Source: INE Padrón 2023, estimated totals including unregistered residents

The Wegzugsteuer: The Biggest Tax Trap for DACH Emigrants

What is the Wegzugsteuer?

The Wegzugsteuer under §6 of the Außensteuergesetz (AStG) is the cornerstone of German exit taxation. When a German tax resident moves abroad and holds a shareholding of at least 1% in a capital company (GmbH, AG, SE), a deemed disposal event occurs: the unrealised gains in that shareholding are taxed as if the shares had been sold — even though no actual sale takes place.

The EU Deferral is Indefinite — Not 7 Years

One of the most common and costly misconceptions among advisors and online sources is that the EU deferral of the Wegzugsteuer is limited to 7 years. This is outdated and incorrect following the 2021 reform.

Since 1 January 2022 (ATAD-Umsetzungsgesetz, BGBl. I 2021, 2051), §6 Abs. 4 AStG n.F. provides:

  • Within the EU/EEA: The tax is deferred indefinitely and interest-free, as long as the taxpayer remains resident within the EU/EEA and does not sell the shares
  • Outside the EU/EEA: The tax is paid in 7 equal annual instalments, generally without interest

Since Spain is an EU member, German nationals moving from Germany to Spain benefit from the indefinite interest-free EU deferral.

When does the deferral end? Upon actual sale of the shares, relocation to a non-EU/EEA country, insolvency, or distributions reducing the share value by more than one quarter.

For full details, see our comprehensive Wegzugsteuer and DACH tax guide for Spain.

Visa and Residency: Options by Nationality

Germans and Austrians (EU Citizens)

No visa required. Required steps:

  1. Empadronamiento — municipal registration within 3 months
  2. Certificado de Registro de Ciudadano de la UE + NIE at the Oficina de Extranjería
  3. AEAT registration when Spain becomes the tax domicile (>183 days/year or centre of economic interests in Spain)

Swiss Nationals

Not EU citizens, but the CH-EU Agreement on Free Movement of Persons (FMA, in force since 2002) grants equivalent residence rights. For stays over 90 days, Swiss nationals must apply for a Tarjeta de Residencia de Ciudadano de la UE (despite the name, accessible to Swiss via the FMA).

Critical difference from German/Austrian nationals: Switzerland is not EU/EEA, so Swiss nationals do not benefit from the German Wegzugsteuer EU deferral for any applicable German tax obligations.

For full visa details: DACH Visas and Residency in Spain 2026.

Tax Optimisation in Spain: Three Routes for DACH Residents

Route 1: The Beckham Law

The Beckham Law (Art. 93 LIRPF) is the most attractive tax regime for most DACH nationals arriving with employment or business activity:

  • 24% flat rate (vs. 19–47% progressive IRPF)
  • Foreign-source income not taxed in Spain
  • Duration: 6 years
  • Extendable to spouse and children under 25

Non-extendable deadline: The Modelo 149 application to AEAT must be submitted within 6 months of starting activity in Spain.

Route 2: ZEC Canarias

For DACH entrepreneurs wanting to establish or relocate a business to Spain, ZEC Canarias offers 4% corporate tax — vs. 25% standard. Requires real presence on the Canary Islands and minimum investment and employment thresholds. See business formation in Spain for DACH.

Route 3: Standard IRPF with DTA Optimisation

For DACH residents who cannot access the Beckham Law, or who have complex family deductions, standard IRPF with careful DTA application is the appropriate path. Key: correct classification of each income type under the applicable DTA (DE-ES, AT-ES or CH-ES).

Business Structure for DACH Entrepreneurs in Spain

The decision between keeping the German GmbH, creating a Spanish SL, or implementing a DE-ES holding structure depends on the nature of the activity, profit volumes, employee presence in Spain and exit horizon.

Full guide: Business Formation in Spain for DACH 2026.

The DACH-to-Spain Relocation Roadmap: Month by Month

A well-planned relocation from DACH to Spain requires a minimum of 6 months of preparation — 12 months for full comfort and error-free execution. Below is the critical-path timeline.

Months 12–9 Before the Move: Analysis and Decision

Wegzugsteuer analysis: The first step is always a full analysis of shareholdings in capital companies. Is there an unrealised gain subject to §6 AStG? What is the current market value under the Ertragswertmethode? Does the indefinite EU deferral apply? Are there any realisation events (share sales, capital reductions) planned that should be completed or deferred in light of the move? This analysis cannot be delegated to a Spanish advisor unfamiliar with the AStG, nor to a German advisor unfamiliar with the DE-ES DTA and the Beckham Law. It requires coordination across both legal systems.

Destination choice in Spain: The choice of autonomous community has concrete fiscal consequences: Wealth Tax (0% in Madrid/Andalusia vs. 0.28–3.45% in Balearics), Inheritance Tax, and IRPF regional surcharge. BMC provides a personalised comparison for each client profile.

Business structure decision: Continue with the GmbH from Spain (with effective management risks), create a Spanish SL, implement a DE-ES holding, or explore ZEC Canarias for new activities. This decision is far cheaper to make before the move than to restructure afterwards.

Months 9–6 Before the Move: Documentation

  • Obtain the NIE at the Spanish Consulate in Germany, Austria or Switzerland — recommended over waiting to process it in Spain, where queues can take 1–3 months
  • Obtain Apostille of the Hague Convention for German documents (criminal record certificate, civil status certificate, GmbH incorporation deed)
  • Begin opening a Spanish bank account as non-resident if the chosen bank allows it
  • Start the property search with fiscal criteria in mind (which region; own vs. rent; corporate vs. personal holding)

Months 6–3 Before the Move: Notifications and Deregistration

  • German deregistration (Abmeldung): The Abmeldung date is when Germany considers tax residence to have ended. This date must be coordinated carefully with the start of Spanish tax residence (>183 days in the calendar year)
  • Communication to the German Finanzamt of the imminent loss of tax residence — initiating the Wegzugsteuer procedure with the EU deferral request
  • Confirmation of empadronamiento (municipal registration) at the Spanish destination municipality

First 6 Months in Spain: Mandatory Registrations

  • Empadronamiento at the local Ayuntamiento (mandatory for almost all subsequent procedures)
  • Certificado de Registro de Ciudadano de la UE + NIE at the Oficina de Extranjería (for EU citizens)
  • AEAT census registration (Modelo 030 or 036/037): communicate the new Spanish fiscal address to the Spanish tax authorities
  • Modelo 149: Beckham Law application — maximum 6-month deadline from starting activity in Spain. Non-extendable.
  • Spanish SL incorporation if the business structure decision was made to create one

From Month 6 Onwards: Recurring Compliance

  • Annual IRPF (Modelo 100) or Beckham return (Modelo 151)
  • Modelo 720: Annual informational declaration of foreign assets above €50,000 per category (bank accounts, real estate, securities). Mandatory even under Beckham if the assets exist.
  • Annual §6 Abs. 5 AStG n.F. notification to the German Finanzamt: Confirmation that EU deferral conditions continue to be met
  • D6 informational declaration for shareholdings in foreign companies above certain thresholds
  • IBI (council tax) on owned real estate in Spain

BMC: The Bilingual DACH-Spain Specialist

BMC is the only bilingual (German/Spanish) advisory firm in Spain offering DACH relocation as a comprehensive, coordinated service. Our specialists in tax law, corporate law and immigration law are fluent German speakers who know both the German and the Austrian and Swiss tax systems.

The BMC DACH Team

International tax planning (Wegzugsteuer + DTA + Beckham + ZEC): Our tax advisors have direct hands-on experience applying §6 AStG in combination with the DE-ES, AT-ES and CH-ES double taxation treaties. We coordinate with each client’s German tax advisor to ensure the EU deferral is correctly documented at the appropriate Finanzamt.

Immigration and residency law: NIE processing, EU citizen registration certificates, Swiss resident cards, and visas for non-lucrative residency, digital nomads, and entrepreneurs — for third-country nationals arriving via DACH employment.

Corporate law and company formation: Spanish SL incorporation in 7–10 working days, ZEC Canarias enrolment applications, DE-ES holding structures, and registration in the Registro de Titulares Reales.

Recurring compliance: Modelo 720, annual IRPF/IS returns, annual Finanzamt notifications, transfer pricing documentation for DE-ES groups.

The BMC Service Model for DACH Clients

BMC operates on an integrated advisory model that eliminates the fragmentation typically found when German and Spanish advisors work in parallel without coordination. The process:

  1. Free bilingual initial consultation: Preliminary analysis of Wegzugsteuer situation, net worth, business structure and Spanish tax options.
  2. Integrated service proposal: One contract, one point of contact, coordinated internal specialists.
  3. Phased execution: Aligned with the relocation timeline, with all critical deadlines clearly documented and monitored.
  4. Recurring compliance: Maintenance of all Spanish tax and corporate obligations, plus coordination of German ones (annual Finanzamt notification, Modelo 720, etc.).

Legal sources:

FAQ

Frequently asked questions

Not necessarily. The Wegzugsteuer under §6 AStG only applies to shareholders who hold at least 1% in a capital company (GmbH, AG, etc.) and where the market value of that shareholding exceeds €500,000. If these thresholds are met, a deemed disposal event occurs and the unrealised gains are taxed. However, since Spain is an EU member, the indefinite interest-free EU deferral under §6 Abs. 4 AStG n.F. (in force since January 2022) applies — the tax is deferred indefinitely with no interest charges, as long as you remain resident within the EU and do not sell the shares.
No. As EU citizens, Germans and Austrians have free movement rights in Spain. However, they must register as EU citizens within 3 months of establishing residence: they need a Certificado de Registro de Ciudadano de la UE (EU Citizen Registration Certificate) and a NIE (Número de Identificación de Extranjero — foreigner's tax identification number). The NIE is indispensable for all tax, banking, real estate and administrative matters in Spain.
Swiss nationals are not EU citizens, but benefit from the CH-EU Agreement on the Free Movement of Persons (FMA), which grants them equivalent residence rights in EU member states. For stays over 90 days, Swiss nationals must apply for a Tarjeta de Residencia de Ciudadano de la UE (despite the name, accessible to Swiss via the FMA). The key difference from Germans or Austrians: Switzerland is not an EU/EEA member, so Swiss nationals leaving Switzerland do not benefit from the EU deferral of any German Wegzugsteuer obligations. This is a critical distinction that must be analysed individually.
The Beckham Law (Art. 93 LIRPF, as amended by the Startups Law, Ley 28/2022) allows new tax residents in Spain to pay a flat 24% rate on Spanish-source income (up to €600,000) for 6 years. Foreign-source income — dividends, rents, interest from Germany, Austria or Switzerland — is not taxed in Spain during this period. For a German entrepreneur with €200,000 in Spanish employment income and €80,000 in German dividends, the annual saving can exceed €60,000. The application (Modelo 149 with AEAT) must be submitted within 6 months of starting activity in Spain.
The largest German-speaking communities in Spain are in: Mallorca/Balearic Islands (~55,000 Germans), Costa del Sol/Marbella (~35,000), Costa Blanca/Alicante (~28,000), Madrid (~18,000 — predominantly entrepreneurs and executives), and Barcelona (~12,000 — tech and startups). Mallorca and Marbella are the preferred destinations for DACH high-net-worth individuals due to climate, infrastructure and the established German-speaking community.
As a Spanish tax resident you will pay: IRPF (Spanish income tax, 19–47% progressively — or 24% flat under Beckham for 6 years), Impuesto sobre el Patrimonio (wealth tax, 0.2–3.5% by region — Madrid and Andalusia have reduced it to 0%), IBI (property tax on owned real estate), and potentially Modelo 720 (informational reporting of foreign assets exceeding €50,000 per category). Inheritance and gift taxes vary enormously by region.
Technically yes, but with significant risk. If you manage the GmbH from your home in Spain — answering emails, signing contracts, making strategic decisions — the tax authorities (German or Spanish) could argue that the GmbH's 'effective place of management' (§10 AO / Art. 4 DTA DE-ES) is now in Spain, potentially creating unlimited corporate tax liability in Spain for the GmbH. The safest approach is to appoint a genuinely active director resident in Germany, or to implement a well-documented DE-ES holding structure. BMC develops a management documentation protocol for each case.
With adequate lead time (6-12 months), the process can be managed in a structured, tax-efficient manner. The minimum advance planning time for correct Wegzugsteuer planning is 3-6 months before deregistering residence in Germany. NIE processing in Spain takes 1-6 weeks depending on the region. The Beckham Law application must be submitted within 6 months of starting activity in Spain — this deadline is absolute and cannot be extended.

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Frequently asked questions

Questions about Germans, Austrians and Swiss Moving to Spain 2026: Complete DACH Relocation Guide | BMC

Not necessarily. The Wegzugsteuer under §6 AStG only applies to shareholders who hold at least 1% in a capital company (GmbH, AG, etc.) and where the market value of that shareholding exceeds €500,000. If these thresholds are met, a deemed disposal event occurs and the unrealised gains are taxed. However, since Spain is an EU member, the indefinite interest-free EU deferral under §6 Abs. 4 AStG n.F. (in force since January 2022) applies — the tax is deferred indefinitely with no interest charges, as long as you remain resident within the EU and do not sell the shares.
No. As EU citizens, Germans and Austrians have free movement rights in Spain. However, they must register as EU citizens within 3 months of establishing residence: they need a Certificado de Registro de Ciudadano de la UE (EU Citizen Registration Certificate) and a NIE (Número de Identificación de Extranjero — foreigner's tax identification number). The NIE is indispensable for all tax, banking, real estate and administrative matters in Spain.
Swiss nationals are not EU citizens, but benefit from the CH-EU Agreement on the Free Movement of Persons (FMA), which grants them equivalent residence rights in EU member states. For stays over 90 days, Swiss nationals must apply for a Tarjeta de Residencia de Ciudadano de la UE (despite the name, accessible to Swiss via the FMA). The key difference from Germans or Austrians: Switzerland is not an EU/EEA member, so Swiss nationals leaving Switzerland do not benefit from the EU deferral of any German Wegzugsteuer obligations. This is a critical distinction that must be analysed individually.
The Beckham Law (Art. 93 LIRPF, as amended by the Startups Law, Ley 28/2022) allows new tax residents in Spain to pay a flat 24% rate on Spanish-source income (up to €600,000) for 6 years. Foreign-source income — dividends, rents, interest from Germany, Austria or Switzerland — is not taxed in Spain during this period. For a German entrepreneur with €200,000 in Spanish employment income and €80,000 in German dividends, the annual saving can exceed €60,000. The application (Modelo 149 with AEAT) must be submitted within 6 months of starting activity in Spain.
The largest German-speaking communities in Spain are in: Mallorca/Balearic Islands (~55,000 Germans), Costa del Sol/Marbella (~35,000), Costa Blanca/Alicante (~28,000), Madrid (~18,000 — predominantly entrepreneurs and executives), and Barcelona (~12,000 — tech and startups). Mallorca and Marbella are the preferred destinations for DACH high-net-worth individuals due to climate, infrastructure and the established German-speaking community.
As a Spanish tax resident you will pay: IRPF (Spanish income tax, 19–47% progressively — or 24% flat under Beckham for 6 years), Impuesto sobre el Patrimonio (wealth tax, 0.2–3.5% by region — Madrid and Andalusia have reduced it to 0%), IBI (property tax on owned real estate), and potentially Modelo 720 (informational reporting of foreign assets exceeding €50,000 per category). Inheritance and gift taxes vary enormously by region.
Technically yes, but with significant risk. If you manage the GmbH from your home in Spain — answering emails, signing contracts, making strategic decisions — the tax authorities (German or Spanish) could argue that the GmbH's 'effective place of management' (§10 AO / Art. 4 DTA DE-ES) is now in Spain, potentially creating unlimited corporate tax liability in Spain for the GmbH. The safest approach is to appoint a genuinely active director resident in Germany, or to implement a well-documented DE-ES holding structure. BMC develops a management documentation protocol for each case.
With adequate lead time (6-12 months), the process can be managed in a structured, tax-efficient manner. The minimum advance planning time for correct Wegzugsteuer planning is 3-6 months before deregistering residence in Germany. NIE processing in Spain takes 1-6 weeks depending on the region. The Beckham Law application must be submitted within 6 months of starting activity in Spain — this deadline is absolute and cannot be extended.
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