The Spanish Special Tax Regime for Expatriates, commonly known as the Beckham Law, offers significant tax advantages for foreign professionals and returning Spanish citizens. This comprehensive guide explains the 2025 regulations, requirements, and benefits of this advantageous tax framework, providing essential information for professionals considering relocation to Spain.
What is the Beckham Law? Origin and Legal Basis in 2025
The “Beckham Law” is the popular name for the special tax regime applicable to workers, professionals, entrepreneurs, and investors who relocate to Spanish territory. It owes its name to the famous footballer David Beckham, who was one of the first beneficiaries when he moved to Spain to play for Real Madrid.
This special regime allows those who transfer their residence to Spain to pay personal income tax (IRPF) at a fixed rate of 24% instead of the progressive tax brackets that reach up to 47%. The regulations are primarily governed by Article 93 of Law 35/2006 on Personal Income Tax and Articles 113 to 120 of the Personal Income Tax Regulations. Since January 1, 2023, following the entry into force of Law 28/2022 on the promotion of startup ecosystems, this regime has undergone substantial modifications that have made it more accessible and beneficial for a greater number of professionals.
Main Modifications to the Expatriate Tax Regime
Reduction of the Prior Non-Residency Period
One of the most significant modifications introduced by Law 28/2022 has been the reduction of the prior non-residency period in Spain from 10 to 5 years. This means that individuals who have not been residents in Spain during the five tax periods prior to the year in which their relocation to Spanish territory occurs can now benefit from this regime.
This reduction has significantly expanded the number of potential beneficiaries, particularly facilitating the return of Spanish professionals who had emigrated abroad.
Requirements to Qualify for the Special Regime
To benefit from the expatriate tax regime, it is necessary to simultaneously meet several requirements:
Prior Fiscal Non-Residency Condition
As mentioned, you must not have been a tax resident in Spain during the five tax periods prior to relocating to Spanish territory. This requirement must be documented, generally through tax residency certificates issued by the competent authorities of the countries where you have previously resided.
Relocation to Spain: Valid Causes
The relocation to Spain must occur as a result of one of the following circumstances:
- An employment contract with an employer in Spain or a posting letter from a foreign employer
- Acquiring the status of director of an entity in which you do not have an ownership interest equal to or greater than 25%
- Carrying out an economic activity classified as entrepreneurial
- Providing services to startup companies or conducting training, research, or development activities
- Performing remote work through computer and telematic means
Tax Advantages of the Expatriate Regime
Taxation as a Non-Resident
The main advantage of the regime is that it allows taxation according to the rules of the Non-Resident Income Tax (IRNR), while maintaining the status of an IRPF taxpayer. This means:
- Taxation at a fixed rate of 24% for income up to 600,000 euros
- Taxation only on income obtained in Spain, not on worldwide income (with the exception of employment income, which is considered to be entirely obtained in Spain)
- No taxation on assets located outside of Spain
Comparison with the General IRPF Regime
To better understand the tax benefit, it is useful to compare the tax rates of the general IRPF regime and the special expatriate regime:
2025 IRPF rates (general regime):
- 0 – 12,450 €: 19%
- 12,450 – 20,200 €: 24%
- 20,200 – 35,200 €: 30%
- 35,200 – 60,000 €: 37%
- 60,000 – 300,000 €: 45%
- +300,000 €: 47%
Expatriate regime rates:
- Up to 600,000 €: 24%
- From 600,001 €: 47%
As observed, the tax savings are especially significant for middle-high and high incomes, potentially exceeding 20% savings for incomes between 60,000 and 600,000 euros.
Extension to Family Members
One of the most notable developments of the reform is the possibility for the taxpayer’s family members to also benefit from the special regime. Specifically:
- Spouses or domestic partners
- Children under 25 years of age
- Children with disabilities (without age limit)
For this, they must meet the following requirements:
- Relocate to Spain with the main taxpayer or subsequently, but always before the end of the first tax period of application of the regime
- Acquire tax residency in Spain
- Not have been residents in Spain during the five previous tax periods
- Not obtain income that would be classified as obtained through a permanent establishment in Spain (with the provided exceptions)
Application Procedure and Management
Deadlines for Joining the Regime
The taxpayer who wishes to join the special regime must communicate their option within a maximum period of six months from the start date of the activity as recorded in the Social Security registration in Spain, or in the documentation that allows maintaining the Social Security legislation of origin.
Specific Tax Forms
The management of the regime requires the use of specific tax forms:
- Form 149: To communicate the option for the regime, as well as any eventual renunciation, exclusion, or end of displacement.
- Form 151: For the annual tax declaration by taxpayers under the regime.
These forms must be submitted electronically through the Tax Agency’s electronic headquarters.
Duration, Renunciation, and Exclusion from the Regime
Temporal Application Period
The regime applies during the tax period in which the taxpayer acquires tax residency in Spain and the five following tax periods. In total, a maximum of six fiscal years.
The tax period of residence acquisition is considered to be the first calendar year in which, after relocation, the stay in Spanish territory exceeds 183 days.
Voluntary Renunciation Procedure
The taxpayer can voluntarily renounce the application of the regime. The renunciation must be communicated during November and December prior to the start of the calendar year in which it should take effect, by submitting Form 149.
Causes for Forced Exclusion
Exclusion from the regime occurs due to non-compliance with any of the conditions that determined its application. The taxpayer must notify the Tax Administration of this circumstance within one month of the non-compliance.
Practical Cases of the Expatriate Regime
Case 1: Professional with Contract in Spain
A German engineer who has never resided in Spain accepts a job offer in Madrid with an annual salary of 90,000 euros. By joining the expatriate regime, they will pay tax at 24% instead of the 37-45% that would correspond in the general regime, resulting in savings of approximately 12,000-18,000 euros annually.
Case 2: Digital Nomad
A Brazilian programmer decides to establish herself in Barcelona while continuing to work remotely for an American company. She obtains the international teleworking visa and joins the expatriate regime. She will only pay tax on her employment income (at 24%) and not on capital gains obtained outside of Spain, such as dividends from investments in Brazil or the United States.
Case 3: Entrepreneur
A Canadian entrepreneur establishes a technology startup in Valencia. His activity is classified as entrepreneurial according to Law 14/2013. With annual income of 150,000 euros, thanks to the expatriate regime, he will pay tax at 24% instead of the 45% that would correspond in the general regime, saving approximately 31,500 euros annually.
Conclusions
The expatriate tax regime represents an exceptional opportunity for foreign professionals and Spanish nationals returning after a stay abroad. The modifications introduced by Law 28/2022 have significantly expanded its scope of application, now including diverse professional profiles such as digital nomads, entrepreneurs, and qualified professionals, in addition to extending to their immediate family members.
The tax advantages are especially relevant for middle-high incomes, with savings that can exceed 20% for incomes between 60,000 and 600,000 euros. Additionally, taxation limited to income obtained in Spain (with the exception of employment income) makes it particularly attractive for individuals with international assets or income sources.
However, it is essential to carefully analyze compliance with the requirements and assess the suitability of the regime based on the specific personal and professional situation.
Frequently Asked Questions about the Expatriate Regime
1. Can Spanish citizens benefit from the expatriate regime?
Yes, Spanish citizens who have been non-tax residents in Spain for at least five tax periods prior to relocation can join the regime, provided they meet all other requirements established in the regulations.
2. What happens with Social Security contributions under the expatriate regime?
The expatriate regime exclusively affects taxation, not Social Security contributions, which follow the general rules according to the type of employment or professional relationship maintained in Spain.
3. Can digital nomads under the regime combine work for Spanish and foreign companies?
Yes, digital nomads under the regime can provide services to Spanish companies, as long as this work does not exceed 20% of their total professional activity.
4. What happens if one of the requirements is no longer met during the application of the regime?
If a requirement is not met, exclusion from the regime occurs with effects from the tax period in which the non-compliance takes place. The taxpayer must communicate this to the Tax Administration within one month and will then be taxed according to the general IRPF regime.
5. Is it possible to rejoin the regime after having renounced it or having been excluded?
Once you have renounced the regime or have been excluded from it, it is not possible to rejoin it, even if you meet all requirements again after a new period of non-residence in Spain.