LLC + Beckham Law Tax Calculator

Methodology and sources

Assumptions applied by this calculator

US LLC treated as transparent (régimen de atribución de rentas, Art. 87 LIRPF)

Spain classifies US LLCs as entities subject to income attribution rules (régimen de atribución de rentas) under Art. 87 LIRPF, consistent with US federal treatment. The LLC's annual net income — whether distributed or not — is attributed proportionally to each member and must be declared in the member's Spanish tax return.

Beckham Law: 24% flat rate on Spanish-source income; foreign-source exempt

Under the impatriate special regime (Art. 93 LIRPF), Spanish-source employment and professional income is taxed at a flat 24% rate on the first €600,000 (47% above). Foreign-source income — including the member's proportionate share of a US LLC's foreign-source business profits — is generally exempt from Spanish IRPF during the six-year Beckham period.

Beckham Law suspends Modelo 720 obligation

Taxpayers under the Beckham Law regime are taxed as non-residents (IRNR) and are therefore not required to file Modelo 720 or Modelo 721 during the regime period. The Modelo 720 obligation (Category B — foreign securities including LLC interests) resumes from the first year after the Beckham regime ends.

Permanent establishment risk if LLC operates in Spain

If the US LLC has a fixed place of business, regular employees, or conducts its core activity in Spain, the AEAT may deem it to have a permanent establishment (EP) in Spain. Income attributable to the EP would be treated as Spanish-source income, reducing the Beckham benefit. Professional advice on EP risk is essential before applying the regime.

Official sources

• Ley 35/2006 (LIRPF), Art. 87 — income attribution regime for transparent entities
• Ley 35/2006 (LIRPF), Art. 93 — Beckham Law inpatriate regime
• OECD Model Tax Convention — transparent entity treatment guidance
• Ley 7/2012, DA Decimoctava — Modelo 720 obligation (foreign securities Category B)

This calculator provides an estimate for informational purposes. It does not replace professional advice. Results may vary based on personal circumstances and regulatory changes. Consult an advisor for personalized planning.