Beckham Law 2025: Definitive Guide to the Non-Resident Tax Regime in Spain

Did you know you could reduce your tax burden by up to 50% by moving to Spain? Since 2005, the Beckham Law has attracted thousands of international professionals by offering extraordinary tax advantages that far exceed standard tax benefits. Updated again in 2023 and with new jurisprudential developments in 2025, this special regime continues to be one of the most powerful tools for optimizing your tax situation if you are a displaced worker, entrepreneur, or digital nomad.

In this exhaustive guide, you will discover exactly how this revolutionary system works, who can benefit from it, and what the most relevant changes are that the Administration has confirmed this year. The information is updated as of October 2025 in accordance with the latest resolutions from the Central Economic-Administrative Court (TEAC) and the jurisprudence of the Superior Court of Justice of Madrid.

What is the Beckham Law and why is it called like that?

The popular name “Beckham Law” comes from the famous footballer David Beckham, who in 2005 became one of the first prominent beneficiaries of this tax regime when he signed with Real Madrid. However, the official regime that governs in 2025 is called the “Special Tax Regime Applicable to Workers, Professionals, Entrepreneurs and Investors Displaced to Spanish Territory,” regulated in Article 93 of Law 35/2006 on Personal Income Tax (IRPF).

Technically, it is a system that allows certain individuals who acquire tax residency in Spain the privilege of being taxed according to the rules of the Non-Resident Income Tax (IRNR), while simultaneously maintaining their status as IRPF taxpayers. The legislative creativity here lies in the fact that the person becomes a Spanish tax resident but applies taxation rules specific to non-residents, which creates an extraordinarily advantageous tax combination.

Why does this regime exist? Its motivation is unequivocal: to attract high-quality international talent that strengthens the competitiveness of the Spanish economy. In the current context of globalization and professional mobility, Spain needs to attract executives, scientists, entrepreneurs, and professionals who would otherwise choose more favorable tax jurisdictions. The regime responds to this need directly: it offers tangible tax advantages during a specific period to incentivize relocation.

Taxation in 2025: Tax Rates and Real Calculation

The tax structure of the Beckham Law in 2025 is organized into two tax brackets for the general taxable base (which includes work income, rental income, etc.):

For income up to 600,000 euros: fixed rate of 24%

For income exceeding 600,000 euros: rate of 47%

This virtually flat tax system contrasts radically with the general IRPF regime, where progressive rates can reach between 19% and 54% depending on the autonomous community of residence. The difference is especially dramatic for professionals with high incomes.

Let us analyze a practical case with real figures: an international executive with an annual salary of 150,000 euros would pay, under the Beckham Law, 36,000 euros (150,000 × 24%), whereas under the general IRPF regime they would pay approximately 52,500 euros (assuming an effective rate of 35% due to the characteristics of progressive IRPF). This represents a net saving of 16,500 euros annually, which over the six years of application of the regime would accumulate 99,000 euros in gross savings.

Main Tax Advantages of the Beckham Law in 2025

1. Taxation Only for Spanish-Source Income (with important exception)

One of the most significant advantages is that beneficiaries are taxed exclusively on income obtained in Spanish territory. This means that income from abroad—dividends from foreign stocks, interest from international accounts, capital gains from assets outside Spain—are completely exempt from taxation in Spain.

The only important exception: income from work activities and entrepreneurial activities obtained abroad are indeed taxed in Spain, as if they were Spanish income. This limitation is logical, since the regime is designed to attract work to Spanish territory.

Application example: A consultant who earns 100,000€ working for a Spanish company and maintains an international stock portfolio that generates dividends of 50,000€ annually, would pay taxes only on the 100,000€ from Spain. The 50,000€ in foreign dividends remain exempt from taxation in Spain, resulting in a tax saving of approximately 9,500€ annually.

2. Exemption from Wealth Tax

Wealth Tax is one of the most burdensome taxes for individuals with considerable assets. Under the general regime, taxpayers are taxed on worldwide net assets at rates that can reach 3.75% in some autonomous communities.

With the Beckham Law, beneficiaries are exempt from this tax on the portion of assets located abroad.

3. No Obligation to File Form 720

Form 720 is an informative statement that requires every Spanish tax resident to report their assets and rights located abroad to the Tax Agency. Its non-compliance carries very high omission penalties depending on severity.

Contributors covered by the Beckham Law are exempt from filing this statement, greatly simplifying their administrative obligations and eliminating this risk of penalties. This advantage is particularly relevant for professionals with international investments dispersed across multiple jurisdictions.

4. Fixed Rate without Penalty for Higher Income

Here lies an important psychological and economic advantage: regardless of whether your income reaches 200,000€ or 600,000€, the tax rate remains at 24%. There is no progressive penalty for increasing your activity or productivity, unlike IRPF where rates increase as income rises.

Requirements to Apply for the Beckham Law in 2025

To access this special regime, you must strictly comply with a series of conditions established in current regulations and recently confirmed by tax jurisprudence.

Fundamental Requirement: Prior Non-Residency

Not having been a tax resident of Spain during the five years prior to relocation. This requirement was reduced from ten to five years through Law 28/2022 reform, effective January 1, 2023, significantly expanding the scope of application.

What does “not having been a resident” mean? That during that five-year period, you have not remained in Spanish territory more than 183 days in any tax year, nor have you had habitual residence in the country. This opens opportunities for Spanish emigrants who return after years abroad.

Valid Reasons for Relocation

The relocation to Spain must respond to one of these specific circumstances:

a) Work contract with a Spanish company or relocation arranged by a foreign company: You must have a job offer from a Spanish company or formal letter of relocation documenting your transfer to Spanish territory for work reasons. The relocating company may be national or international.

b) Digital nomads: As of 2023, workers who provide services remotely through telematic means can be covered by the regime, provided they have an international telework visa and demonstrate the performance of qualified economic activities.

c) Appointment as administrator or manager: If you are appointed administrator of a commercial company, you can be covered by the regime provided your participation does not exceed 25% in patrimonial companies. This threshold does not apply if you hold an entrepreneur visa.

d) Initiation of innovative business activity: Entrepreneurs who create a company with innovative activities can benefit from the regime.

e) Highly qualified professionals: If you perform highly qualified professional activities linked to emerging companies, research, development and innovation (R&D+i) projects, with at least 40% of income derived from such activities, you are eligible.

Application Timeline: Critical Element

You have a maximum of 6 months from the date of your enrollment in Social Security to submit the application using Form 149 to the Tax Agency.

Failure to meet this deadline can result in loss of rights retroactively, becoming a costly error. Many international professionals are unaware of this requirement until it is too late.

Beneficiaries of the Beckham Law in 2025: Expansion of the Catalog

Self-Employed Employees

They are the traditional beneficiaries. Any salaried worker who relocates to Spain with a valid employment contract can request it, provided they meet the other requirements.

Digital Nomads and Remote Workers

The 2023 reform explicitly opened the regime to remote workers who provide services to foreign companies through digital platforms. The requirement to have an international telework visa is fundamental. In 2025, following the recent jurisprudential ruling, it is confirmed that digital nomads can fully benefit from the regime.

Entrepreneurs and Startuppers

Founders of startups and innovative companies that invest directly in the creation of the company can be covered. Majority participation is not an impediment if the company is classified as a startup.

Highly Qualified Professionals

Scientists, researchers, specialized consultants, and other professionals with specialized training working on R&D+i projects. The requirement of 40% income derived from such activities is verifiable through billing documentation.

Administrators and Managers

If you assume managerial or administrative positions without exceeding the participation thresholds established (25% in patrimonial companies, except in specific situations).

Extension to Family Members

An innovation from 2023 allows the regime to be extended to the spouse and children under 25 years of age of the main contributor, as well as elderly parents or persons with disabilities who relocate with the main contributor, provided their income is lower than that of the main contributor and they meet the other requirements.

Jurisprudential Clarifications 2025

Taxation on Principal Residence: TEAC Resolution 3697/2025

One of the most controversial issues in 2025 is the taxation of principal residence. The Resolution of the Central Economic-Administrative Court number 3697/2025 of July 17, 2025, has established unified criteria on this matter.

The Tax Agency maintains that, by opting for the special regime, the taxpayer accepts the rules of IRNR in their entirety. In accordance with IRNR, all imputed income from urban real estate properties in Spanish territory—including principal residence—generate taxation. Although there is jurisprudential disagreement with the Superior Court of Justice of Madrid (which maintains a position favorable to taxpayers in decisions such as 665/2025 of September 17), TEAC Resolution 3697/2025 represents the official criteria of the Administration.

Practical implication: an expatriate owner of their principal residence valued at 500,000€ (generating approximate imputed income of 10,000€ annually) will have to pay taxes on that amount, significantly reducing expected savings. This aspect should be carefully considered in decisions about housing.

Changes and Legal Developments in 2025

2023 Reform (in effect since January 2023): Continued Impact in 2025

Law 28/2022, dated December 21, 2022, on the promotion of emerging company ecosystems, introduced profound changes that continue to develop in 2025:

  • Reduction from 10 to 5 years of the prior non-residency period
  • Expansion of the beneficiary catalog to digital nomads, entrepreneurs, and professionals
  • Extension to family nucleus under specific conditions
  • Updating requirements for qualified professionals and R&D+i

Changes in Interpretation: Residents vs. Non-Residents

A conceptual tension persists between considering the taxpayer as a “special resident” (who should receive favorable IRPF treatments such as exemption for principal residence) versus as a “de facto non-resident” (fully subject to IRNR rules). Jurisprudence in 2025 has oscillated, but the administrative trend is more restrictive.

Duration of the Regime: How Many Years Does It Last?

The regime applies for six tax periods:

  • The tax period in which tax residency in Spain is acquired
  • The five following tax periods

If you acquire tax residency in 2024, the regime accompanies you during 2024, 2025, 2026, 2027, 2028, and 2029. From 2030 onward, you would pay taxes as any regular resident under the general IRPF regime.

Important clarification: tax residency is acquired in the first full calendar year in which you remain more than 183 days in Spain. If you arrive in October 2024, you probably will not be a resident in 2024, but rather in 2025.

Impact on Other Taxes

Inheritance and Gift Tax

Unlike other benefits, the expatriate regime does NOT apply to Inheritance and Gift Tax. You will be considered a full tax resident for purposes of this tax, which means taxation on inheritances and gifts in accordance with applicable autonomous community rules.

Tax on Transfer of Patrimonial Assets

Transfers of real estate are taxed in accordance with general legislation. There is no special benefit.

Social Contributions

The obligation to pay into Social Security remains intact. There are no reductions in employer or employee contributions.

Exceptions and Limitations: When You Lose the Regime

Exclusion Due to Permanent Establishment

If you conduct economic activities through a permanent establishment in Spain (that is, if you become self-employed working from a permanent physical office in the country), you immediately lose the special regime. This applies even within the same tax period.

In 2024, the General Directorate of Taxes issued binding consultation CV2248-24 of October 21, clarifying that a worker who leaves their employment to become self-employed in the same fiscal year is automatically excluded from the regime.

Change in Beneficiary Category

If you begin an activity not contemplated in the regime (for example, if you were a dependent employee and become a manager with participation exceeding the permitted thresholds), you must report this to the Tax Agency.

Passage of the 6-Year Period

Obviously, at the end of the sixth tax period, the regime ceases automatically, except for prior express waiver.

Waivers and Regime Changes

You can voluntarily waive the regime at any time. Some taxpayers do so when personal circumstances change (marriage, children, change of autonomous community residence) such that the regular IRPF becomes more advantageous.

The waiver requires formal communication to the Tax Agency and becomes effective from the period following that in which it is communicated.

Comparison with Alternatives: Digital Nomad Visa

In 2023, Spain introduced the Digital Nomad Visa, an alternative for remote workers. The main difference:

  • Beckham Law: requires actual relocation and permanence in Spain; better for high incomes.
  • Digital Nomad Visa: allows telework; better for self-employed and freelancers with moderate incomes.

Both are not mutually exclusive; some Digital Nomad Visa beneficiaries may be covered by Beckham Law if they meet requirements.

Real Cases Recognized Through our Office:

Case 1: International Executive Relocated

María, a Mexican executive, is hired by a multinational with headquarters in Madrid. She earns 200,000€ annually. She has not resided in Spain during the last 5 years.

Situation: She meets all requirements. In 2025 she applies for Beckham Law.

Taxation 2025-2030 (6 years):

  • Under Beckham Law: 200,000€ × 24% = 48,000€ annually = 288,000€ in 6 years
  • Under regular IRPF (estimated): ~70,000€ annually = 420,000€ in 6 years
  • Total saving: 132,000€ in the six-year period

Case 2: Digital Nomad Remote Worker

Carlos, English consultant, works remotely for a Canadian company. He earns 120,000€ annually. He obtains an international telework visa (Digital nomad).

Situation: He meets the requirements of digital nomad if he has not been a resident in Spain previously.

Taxation: 120,000€ × 24% = 28,800€ annually under Beckham Law. His foreign-source income remains exempt (except for 24% on work income).

Case 3: Entrepreneur with a Startup

Juan, Spanish resident in Singapore, returns to Spain to create a technology startup. He has not resided in Spain for 8 years.

Situation: As a new businessman, he meets the prior non-residency requirement (8 years > 5 years). He accesses Beckham Law as an entrepreneur.

Implication: His business income is taxed at 24% for 6 years, incentivizing reinvestment and growth.

Frequently Asked Questions

Can Spanish citizens be covered by the Beckham Law when they return to Spain?

Yes, Spanish citizens can benefit provided they have not been tax residents of Spain during the five years prior to relocation. Nationality is irrelevant; what matters is prior tax residency. Many Spanish emigrants take advantage of this opportunity when they return professionally.

How long does it take for the application to be approved?

The regulations establish 10 days but this is rarely the case. It usually ranges from two weeks to 4 months depending on the Autonomous Community.

What happens if I change jobs during the six-year application period?

If you change to a Spanish employer, you maintain the regime, provided you continue to meet the requirements. If you change from a foreign employer to a permanent establishment in Spain, you lose the regime immediately.

Can I claim professional expenses under the Beckham Law?

No. The expatriate regime is calculated on gross income without deduction of professional expenses. Under normal IRPF you could deduct, which sometimes makes the regime less advantageous for self-employed individuals with many expenses.

What implications does it have for declaring assets abroad?

You are not required to file Form 720 (informative statement of assets abroad), completely eliminating this risk of penalties for omission.

Special Considerations: Recent Changes and Tax Disputes

The Controversy over Principal Residence (TEAC vs. TSJM)

In September 2025, the Superior Court of Justice of Madrid reiterated (judgment 665/2025) its position that principal residence does NOT generate taxation on imputed income for expatriates. However, TEAC has established the opposite criteria (resolution 3697/2025 from July).

Practical advice: This divergence persists. If you are a beneficiary and acquire principal residence, consult with a specialized advisor to evaluate potential claims if the Tax Agency improperly demands taxation. The judicial trend evolves in your favor, but temporary uncertainty exists.

Conclusion: Is the Beckham Law Right for You?

The Beckham Law 2025 remains an extraordinarily advantageous tax tool for international professionals, entrepreneurs, and digital nomads who relocate to Spain. The potential savings—up to 50% in tax burden compared to regular IRPF—fully justify the investment in specialized advice.

However, it is essential to:

  1. Carefully prove the requirements, especially the prior non-residency period
  2. Apply within six months of your enrollment in Social Security
  3. Meticulously document the relocation through formal contracts
  4. Consult with an international tax specialist before acquiring real estate (especially principal residence) given the current jurisprudential uncertainty
  5. Review your situation annually to assess whether personal changes make the general IRPF regime more advantageous

The tax landscape is constantly evolving. Any definitive decision should be made after professional individual consultation that assesses your specific situation.

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