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 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), 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.

Ley Beckham 2026: the current regime and recent changes

The Ley Beckham (Article 93 LIRPF), formally the Spanish special expatriate tax regime, underwent significant modification in 2023 (applicable from the 2024 tax year) as part of the Startup Law (Ley 28/2022). 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: digital nomads and remote workers (provided they work primarily for a non-Spanish employer or as freelancers for predominantly non-Spanish clients), entrepreneurs and startup founders under the Startup Law framework, 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 six key requirements

To qualify for the Ley Beckham regime, an individual must satisfy all six conditions simultaneously:

1. Prior non-residence: the individual must not have been Spanish tax resident in the 5 years (now reduced from 10) immediately prior to the year of application.
2. Qualifying reason for relocation: the move to Spain must be triggered by one of the qualifying events — employment contract with a Spanish entity, assignment to a Spanish entity from a foreign group company, appointment as a director of a Spanish company (with ownership restrictions), digital nomad / remote work under Startup Law provisions, or entrepreneurial activity.
3. Spanish-source income: the individual must receive income from Spanish sources or (for employment) income subject to Spanish IRPF regardless of source.
4. No permanent establishment: the individual must not operate through a permanent establishment in Spain before the relocation.
5. No Spanish-resident spouse with different regime: the regime applies individually — a spouse who is already Spanish tax resident does not automatically disqualify the applicant, but family planning considerations apply.
6. Timely application (Modelo 149): the application must be filed within six months of the date of commencement of activity registered in Spanish Social Security.

Missing the Modelo 149 filing deadline is the most common error we encounter — and it is not recoverable. The six-month window runs from Social Security registration, not from 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 (19% to 47%) 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: professionals working remotely for a foreign employer or as freelancers for predominantly foreign clients can qualify for the impatriate regime under the Digital Nomad Visa framework introduced by Law 28/2022. The key requirements are: holding a Digital Nomad Visa, working primarily for a non-Spanish employer, 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 who move to Spain to develop an innovative business project certified under the Startups Act can access the impatriate regime. The certification process is managed by ENISA and requires demonstrating an innovative business model with scalable potential. The combination of the Beckham regime flat rate and the reduced 15% IS rate for the company creates a powerful combined 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 their Spanish employment income 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 is the key planning lever: designing the total remuneration package to maximise the proportion of income treated as foreign-source (and therefore exempt) 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 if the aggregate value of overseas assets exceeds EUR 50,000. Non-compliance attracts penalties of EUR 5,000 per data item (minimum EUR 10,000), making proactive disclosure essential.

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.