Specialised Tax Regimes: Beckham Law, Non-Residents and Crypto Assets

BMC’s specialised tax practice covers tax regimes that depart from the standard rate — from the Beckham Law for inpatriates to the Canary Islands ZEC, through non-resident taxation and digital assets. These regimes offer real advantages, but require precise processing, rigorous documentary compliance, and planning that anticipates AEAT reviews.

Beckham Law and inpatriate regime

The special regime for workers relocating to Spain (Art. 93 LIRPF, popularised as the “Beckham Law”) allows taxation at the flat rate of 24% on employment income up to €600,000 for six tax years, with taxation solely on Spanish-source income for all other income. It is a first-rate planning tool for international executives, remote workers, and entrepreneurs relocating to Spain:

• Beckham Law — Inpatriates: Eligibility analysis, Form 149 processing, coordination with the tax situation in the country of origin, and advisory throughout the six-year regime.

IRNR — Non-resident taxation

The Non-Resident Income Tax (IRNR) taxes income obtained in Spain by individuals and entities without tax residence in the country. Correct application of double tax treaties and the distinction between permanent establishment and non-establishment are decisive for the effective tax burden:

• Non-Resident Tax (IRNR): Periodic settlements, Forms 210 and 216, AEAT representation, real estate income, and double tax treaty analysis.

Special territories — ZEC, Canary Islands, Ceuta and Melilla

Territories with special tax regimes offer incentives that have no equivalent in the general regime. The Canary Islands ZEC, with a 4% corporate tax rate, expires in December 2026 and companies that do not start the registration process before summer will miss the last window of the current authorisation:

• ZEC and Special Territories: ZEC registration, real substance requirement analysis, RIC (Canary Islands Investment Reserve), and investment deductions in the Canary Islands.

Crypto asset and digital asset taxation

AEAT has intensified the supervision of crypto assets through data cross-referencing of Form 721 and the entry into force of Directive DAC8. Correct characterisation of each income type (capital, capital income, business income) and filing of all mandatory forms is more important than ever:

• Crypto Assets and Digital Assets: IRPF, corporate tax, Forms 721/172/173, staking, DeFi, NFTs, and regularisation of prior situations.

Cross-border structuring — international freelancers

Freelancers and small businesses operating across multiple countries face an additional layer of complexity: exit tax in the country of origin, application of the Beckham Law in Spain, choice of optimal corporate structure (Italian SRL, PEX holding), and coordination of the tax obligations of both countries during the year of residence change:

• Tax Structuring for Italian Freelancers in Spain: Comprehensive analysis of the forfettario threshold, Italian exit tax Art. 166 TUIR, PEX holding, Beckham Law, and bilateral coordination.

Why special regimes require specialised advice

The rules of each special regime are autonomous — they have their own application deadlines, maintenance requirements, grounds for losing the regime, and interactions with international taxation. An error in processing Form 149 (Beckham Law) can result in the irreversible loss of the regime for the following six tax years. A defective ZEC registration due to insufficient real substance can lead to a reassessment including standard rates plus interest and penalties. The specificity of each regime requires not only technical knowledge, but practical experience in managing AEAT resolutions and reviews.