Beckham Law: Pay 24% Tax as an Impatriate in Spain

The Beckham Law (Art. 93 LIRPF and Arts. 113 to 120 of the IRPF Regulation, Royal Decree 439/2007) is Spain's special tax regime for inbound workers that allows qualifying individuals to pay a flat 24% income tax rate on Spanish-source income — instead of progressive rates whose top rate ranges from 45% to 54% depending on the region — for the year of arrival and the following five tax years. Since the 2022 reform (Startup Act, Ley 28/2022), the regime has been extended to entrepreneurs with an activity qualified under Art. 70 of Law 14/2013 and to highly qualified professionals serving emerging companies or working in training, research, development or innovation, who may apply via Form 149 within six months of starting activity in Spain.

Territorial notice: the Beckham Law does not apply to anyone taking up tax residence in the Basque Country or Navarra. In Bizkaia the applicable regime is article 56 bis of Norma Foral 13/2013, with a 30% salary exemption, deductible relocation expenses and up to 11 years of duration. See our Bizkaia displaced workers service and the Basque Beckham guide.

We have managed the impatriate regime for executives and professionals from more than 30 different nationalities. Our practical knowledge of the regulation and the AEAT’s interpretative criteria ensures safe application and maximum tax savings.

Use our Beckham Law calculator to estimate your tax savings by comparing standard IRPF against the impatriate flat rate.

Why the Beckham Law is Decisive for Attracting International Executive Talent

Spanish companies compete for international executive talent from a disadvantaged salary position relative to London or Zurich. The impatriate regime under Art. 93 LIRPF reverses that equation: it allows a foreign executive to pay tax at 24% on all their employment income for six years, compared with IRPF top marginal rates of 45% to 53.85% depending on the region (50% in Catalonia, 53.85% in the Valencian Community). The problem is that the regime demands precision from day one. The six-month window for submitting Form 149 from the start of activity in Spain is mandatory: missing it means the permanent loss of the regime for that relocation, not just for one fiscal year. Many companies discover this too late, when the executive has already been on payroll for months and the deadline has passed. The cost — in additional taxes and in a lost talent attraction argument — is directly quantifiable.

Our Process for Applying the Beckham Law Impatriate Regime

Our tax team engages from the hiring stage, before the executive sets foot in Spain. We verify the eligibility requirements: no Spanish tax residency in the previous five fiscal years (Article 93.1.a LIRPF, as amended by Law 28/2022 — the previous wording in force from 2015 to 2022 required ten years), a move caused by one of the routes of Article 93.1.b LIRPF (employment, including remote work by employees, appointment as a director, an entrepreneurial activity qualified under Art. 70 of Law 14/2013, or work as a highly qualified professional), and no income obtained through a permanent establishment in Spain except under those last two routes (Article 93.1.c LIRPF). We prepare and submit Form 149 within the statutory deadline with all required supporting documentation. We then design the remuneration package to maximise the flat-rate benefit: the difference between a well-designed structure and a generic one can represent tens of thousands of euros per year. We manage annual compliance with Form 151 and plan the exit from the regime at the end of the sixth fiscal year with sufficient advance notice.

Regulatory Framework: Art. 93 LIRPF and the Start-Up Law 2022

The impatriate regime is regulated under Art. 93 of Law 35/2006 (LIRPF) and developed in Arts. 113 to 120 of the IRPF Regulations. Law 28/2022 on start-ups significantly broadened its scope: from 2023, entrepreneurs with an activity qualified under Art. 70 of Law 14/2013 and highly qualified professionals serving Spanish emerging companies or carrying out training, research, development or innovation work, with over 40% of their business, professional and employment income from it, can also opt in, and employees teleworking under the Law 14/2013 visa were expressly brought within Art. 93.1.b.1. This law also introduced the extension of the regime to the spouse and to the children under 25 (or of any age with a disability) of the impatriate under certain conditions. The regime requires Spanish-source income to be taxed at 24% up to EUR 600,000 and at 47% on the excess; foreign-source income is generally not taxed in Spain under the special regime, except employment income and income from an activity qualified as entrepreneurial, all of which is deemed obtained in Spain during the regime (Art. 93.2.b LIRPF).

Real Results in Beckham Law Management: Quantified Tax Savings

• Annual tax savings of EUR 20,000 to EUR 80,000 per executive depending on remuneration level, compared with the standard IRPF marginal rate.
• Form 149 filed within the deadline, guaranteed from day one of activity.
• Fully documented and optimised remuneration package: fixed salary, variable pay, benefits in kind, and deferred compensation integrated.
• Zero contingencies with the AEAT across the six years of the regime’s duration.
• Exit planning executed at least twelve months in advance to minimise the impact of the transition back to the standard regime.

The Beckham Law is one of the most competitive tax regimes in Europe for attracting executive and professional talent. Paying a flat rate of 24% for six years, against an IRPF combined top rate of 45% to 53.85% depending on the autonomous community (2026), is an advantage that Spain’s most dynamic companies already use as a differentiating argument in their international recruitment processes. However, the regime demands precision: the six-month deadline for filing Form 149 from the start of activity in Spain is mandatory, and missing it means the permanent loss of the benefit for that relocation.

The 2022 Start-Up Law reform significantly extended the eligibility perimeter. Beyond employees and company directors, the regime is now open to entrepreneurs whose economic activity is qualified as entrepreneurial under Art. 70 of Law 14/2013 with a favourable ENISA report, and to highly qualified professionals serving Spanish emerging companies or carrying out training, research, development or innovation work with over 40% of their business, professional and employment income from that activity. This expansion has opened the regime to remote employees and to technology founders and specialists who were previously excluded, making Spain a more attractive destination for global talent in high-value sectors; a self-employed digital nomad with foreign clients still needs the entrepreneurial or highly qualified professional route.

The remuneration package optimisation is the other differentiating element of our service. Opting into the regime is not enough: the remuneration structure must be designed to maximise its impact. The 24% rate applies to all employment income, which is deemed obtained in Spain wherever the work is done (Art. 93.2.b LIRPF), while foreign investment income is generally not taxed in Spain under the special regime. Intelligent structuring of variable pay, benefits in kind, and long-term instruments, can generate very significant savings. We coordinate this planning with our employment law services to ensure the employment contract is consistent with the designed tax structure. We also coordinate with our tax planning practice to integrate the Beckham regime into the company’s overall tax strategy.

Planning the exit from the regime at the end of the sixth fiscal year is a frequently overlooked element that deserves attention from the outset. The transition to standard IRPF can generate a substantial increase in the tax burden that both the executive and the company must anticipate. We plan the exit with sufficient advance notice to minimise the impact, including possible adjustments to the remuneration structure and, where appropriate, evaluation of alternatives such as a change of tax residence to a more efficient jurisdiction at the end of the regime.

Ley Beckham 2026: the current regime and recent changes

The Ley Beckham (Article 93 LIRPF), formally the Spanish special expatriate tax regime, was significantly modified by the Startup Law (Ley 28/2022), with effect from 1 January 2023. The reformed regime extends access to new categories of beneficiaries and improves its terms in several respects, making it one of the most competitive expatriate tax regimes in Europe for qualifying individuals.

Under the current regime, qualifying individuals pay Spanish income tax only on Spanish-source income (plus all employment income regardless of source), at the general IRNR flat rate of 24% on income up to EUR 600,000 (with a 47% rate on the excess). They are also exempt from Wealth Tax (IP) on non-Spanish assets and do not need to file the Modelo 720 declaration for overseas assets — two significant benefits for internationally mobile high-net-worth individuals.

The 2023 reforms extended qualifying categories to include: employees teleworking for a non-Spanish employer, including holders of the international telework visa (Art. 93.1.b.1), entrepreneurs qualified under Art. 70 of Law 14/2013 (Art. 93.1.b.3), highly qualified professionals serving Spanish start-ups or in R&D&I who earn over 40% of their income from it (Art. 93.1.b.4), and qualifying family members of the principal applicant. This broadening has made the Ley Beckham accessible to a much wider population of international professionals and entrepreneurs relocating to Spain.

Qualifying conditions: the four key requirements

To qualify for the Ley Beckham regime, an individual must meet all of these conditions:

1. Prior non-residence: the individual must not have been Spanish tax resident in the five tax periods before the year of the move to Spain (reduced from ten by Law 28/2022).
2. Qualifying reason for relocation: the move to Spain, in the first year of the regime or the year before, must be triggered by one of the qualifying events — employment contract with a Spanish entity, assignment to Spain ordered by the employer with a secondment letter, acquiring the position of director of a company (ownership limit only if the company is an entidad patrimonial), employee telework (Art. 93.1.b.1), an entrepreneurial activity qualified under Art. 70 of Law 14/2013, or work as a highly qualified professional serving Spanish start-ups or in R&D&I that provides over 40% of income.
3. No permanent establishment: the individual must not obtain income through a permanent establishment in Spain, except under the entrepreneur and highly qualified professional routes (Art. 93.1.c).
4. Timely application (Modelo 149): the application must be filed within six months of the start date of activity shown in the Spanish Social Security registration, or in the documentation that keeps the home country’s Social Security (Art. 116.1.a RIRPF).

Missing the Modelo 149 filing deadline is the most common error we encounter — and it is not recoverable. The six-month window runs from the start date of activity shown in the Social Security registration (or in the documentation that keeps the home country’s Social Security), not from the contract date, the first working day or the calendar year start.

Financial benefits: the numbers

For a qualifying individual with EUR 300,000 in annual employment income, the Ley Beckham regime produces a substantially lower effective tax rate than standard IRPF:

• Standard IRPF: progressive rates (combined top rate of 45% to 53.85% depending on the region, 2026) on worldwide income, resulting in an effective rate of approximately 42-44% at this income level.
• Ley Beckham regime: 24% flat rate on the first EUR 600,000 of income, resulting in an effective rate of 24%.

The difference — approximately 18-20 percentage points of effective rate — represents a very substantial saving for high earners relocating to Spain. When combined with the IP and Modelo 720 exemptions, the total financial benefit over a 6-year eligibility period can be several hundred thousand euros for senior executives or entrepreneurs.

Application process and ongoing compliance

The application process involves: obtaining a NIE (Número de Identificación de Extranjero), registering with Spanish Social Security (alta en Seguridad Social), filing Modelo 149 within the six-month window, and receiving confirmation from the AEAT. Annual tax compliance under the regime uses Modelo 151 (rather than the standard Modelo 100 for IRPF) — a structurally different form that requires specific preparation.

Our Ley Beckham advisory covers the full lifecycle: pre-relocation eligibility assessment, application filing, annual Modelo 151 preparation, and transition planning as the six-year regime period approaches expiry. The transition back to standard IRPF requires its own planning — particularly for individuals with significant overseas assets or investments that become taxable under the standard regime.

Contact our international mobility team for a personalised assessment of your Ley Beckham eligibility and projected tax savings.

Beckham Law in practice: case examples and typical structures

The typical Beckham Law applicant at BMC is an executive or senior professional relocating from the UK, Germany, France, the US, or a Latin American country to take up a senior position at a Spanish or multinational company. However, since the 2022 reform, the profile has broadened significantly:

Digital nomads and remote workers: an employee working remotely for a foreign employer can qualify, because Art. 93.1.b.1 LIRPF expressly covers remote work by telematic means and names the Law 14/2013 teleworking visa as one case, only for employees. A self-employed professional with foreign clients does not qualify on that basis, whatever the visa says, and must instead fit the entrepreneurial or highly-qualified-professional route. For the employee route the visa is one case the law names expressly, not a requirement: what counts is working remotely as an employee and not having been a Spanish tax resident in the previous five years. The 24% flat rate on Spanish-source income — which in this context means all employment income, wherever performed — makes Spain materially more attractive than most EU alternatives for high-earning remote workers.

Startup founders and entrepreneurs: under the 2022 reform, entrepreneurs whose economic activity is qualified as entrepreneurial under the procedure in Art. 70 of Law 14/2013, with a favourable ENISA report, can access the impatriate regime (Art. 93.1.b.3). This is not the same as the emerging-company certification of the Startups Act (Law 28/2022, Art. 3), which matters for the company’s 15% corporate tax rate and for the highly qualified professional route. A founder who runs the business through a Spanish company and is appointed its director can also qualify under Art. 93.1.b.2, with no shareholding limit unless the company is a wealth-holding entity (Art. 5.2 LIS); combined with the reduced 15% IS rate of a certified emerging company, this creates a powerful incentive for international entrepreneurs establishing in Spain.

Executive packages and remuneration design: the 24% flat rate applies to Spanish-source income, which for executives means all their employment income, wherever the work is done (Art. 93.2.b LIRPF), including fixed salary, performance bonuses, and most benefits in kind. Income from foreign sources — dividends from foreign holdings, capital gains on non-Spanish assets, foreign rental income — is generally exempt from Spanish tax under the impatriate regime, with limited exceptions. This asymmetry concerns investment income, not pay: no part of the remuneration package can be treated as foreign-source, because all employment income is deemed obtained in Spain during the regime. The lever is the location of personal investments and the timing and form of variable pay, which can significantly increase the effective benefit of the regime beyond the headline 24% rate differential.

Transition from Beckham regime to standard IRPF

The end of the impatriate regime — at the close of the sixth fiscal year of Spanish tax residency — requires careful planning at least twelve to eighteen months in advance. The transition back to standard IRPF affects:

Worldwide income inclusion: from year seven, the resident is subject to IRPF on worldwide income, including dividends and capital gains from foreign assets that were exempt under the impatriate regime. The immediate tax cost of this transition depends on the volume of foreign-source income.

Wealth tax (IP) on worldwide assets: under the impatriate regime, IP applies only to Spanish-sited assets. From year seven, worldwide net wealth is included in the IP base (above EUR 700,000), which for executives with significant asset portfolios can represent a material additional tax cost.

Modelo 720 filing obligation: from year seven, the worldwide overseas assets declaration (Modelo 720) must be filed for each block of overseas assets (accounts; securities, insurance and annuities; real estate) whose value exceeds EUR 50,000. Not filing is fined EUR 20 per data item (minimum EUR 300, maximum EUR 20,000), and the AEAT already receives most of that data through CRS, so filing on time matters.

We begin exit planning discussions with Beckham regime clients no later than year four, modelling the transition options and identifying whether any structural changes — including potential relocation to another jurisdiction, changes to the asset holding structure, or acceleration/deferral of income recognition — would improve the overall outcome.