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

The Beckham Law (Art. 93 LIRPF, Royal Decree 687/2005) 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 up to 47% — 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 self-employed workers, entrepreneurs, and highly qualified professionals, who may apply via Form 149 within six months of starting activity in Spain.

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 their Spanish remuneration for six years, compared with IRPF marginal rates exceeding 47% in regions such as Catalonia or Andalusia. 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 benefit for that 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 ten fiscal years, displacement arising from an employment contract or appointment as a director, activity carried out in Spain, and the company not being a resident entity or having a permanent establishment in Spanish territory. 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 Art. 113 of the IRPF Regulations. Law 28/2022 on start-ups significantly broadened its scope: from 2023, self-employed workers with predominantly foreign clients, entrepreneurs with an innovative business project, and highly qualified professionals working for start-ups can all opt in. This law also introduced the extension of the regime to the spouse and minor children 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, with limited exceptions applying to employment income.

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 IRPF marginal rates that can exceed 47% in some autonomous communities, 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 individual.

The 2022 Start-Up Law reform significantly extended the eligibility perimeter. Beyond employees and company directors, the regime is now open to self-employed workers with predominantly foreign clients, entrepreneurs with an innovative company project, and highly qualified professionals working for start-ups. This expansion has opened the regime to the digital and technology professional profile that was previously excluded, making Spain a more attractive destination for the digital nomad and global talent in high-value sectors.

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 Spanish-source income, but foreign-source income is generally not taxed in Spain under the special regime. This asymmetry, combined with intelligent planning 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.