Beckham Law in Spain: The Complete 2026 Guide to the Impatriate Regime

The Beckham Law is the popular name for the special regime in Article 93 of Law 35/2006 of 28 November on Personal Income Tax (IRPF). It allows anyone who becomes tax resident in Spain because they relocate here to pay tax under Non-Resident Income Tax rules (IRNR) in their year of arrival and the five following years, while remaining an IRPF taxpayer.

The nickname comes from David Beckham, who signed for Real Madrid in 2003 and was among the first to benefit; the regime was first developed in Royal Decree 687/2005 of 10 June. Today’s framework is:

• Statute: Article 93 of the IRPF Act, as worded by Law 28/2022 of 21 December on the promotion of the start-up ecosystem. Law 7/2024 adjusted the savings scale from 2025.
• Regulations: Articles 113 to 120 of the IRPF Regulations (Royal Decree 439/2007), amended by Royal Decree 1008/2023 of 5 December.
• Forms: Modelo 149 (opting in, waiver and exclusion) and Modelo 151 (annual return), approved by Order HFP/1338/2023 of 13 December.

At present, no amendment to these provisions has been approved: Article 93 was last amended on 21 December 2024, and the regulations on 6 December 2023. The only development this autumn touches the regime indirectly, through the deemed income on Spanish property. We cover it below.

There is a paradox at the heart of the system. You are a Spanish tax resident, yet you are taxed as if you were not. That explains almost all of its advantages, and most of its weak spots too.

You qualify if you become tax resident in Spain because you moved here, were not resident in the previous five years, arrive through one of the four routes set by law and do not earn income through a permanent establishment in Spain. Nationality is irrelevant: a Spaniard returning after five years abroad can also opt in.

The Article 93.1 requirements are cumulative:

1. No prior residence: you must not have been Spanish tax resident in the five tax years before the year you relocate. Before 2023 it was ten.
2. Timely relocation: the move must take place in the first year the regime applies or in the year before.
3. A qualifying route, from those in the table below.
4. No permanent establishment: you must not obtain income that would count as earned through a permanent establishment in Spain, except under the entrepreneur and highly qualified professional routes.

Two points the table leaves out. The international telework visa (the so-called digital nomad visa) helps as evidence, but it is not essential: in binding ruling V2460-25 of 11 December 2025, the Directorate General of Taxes (DGT) accepted a Spanish national who could not apply for it precisely because he was Spanish. And whichever route you use, the only business activities you can carry on afterwards are the entrepreneurial or highly qualified ones.

Employment income, wherever it is earned, and other Spanish-source income that is not savings income is taxed at 24% up to €600,000 and 47% above that. Spanish-source dividends, interest and capital gains follow a separate scale from 19% to 30%. Everything else you earn abroad stays outside Spanish tax.

That is what Article 93.2 provides. The savings scale in force since 2025 is:

Keep five rules in mind before running numbers:

• Tax is charged on gross income. Because non-resident rules apply, you cannot deduct Social Security contributions, expenses or a personal allowance.
• No offsetting between types of income. A loss does not reduce a gain.
• Withholding on salary is 24%, rising to 47% on anything a single payer pays above €600,000.
• If your foreign salary was already taxed abroad, the double taxation credit is capped at 30% of the tax due on that income.
• Wealth Tax and Modelo 720. You pay Wealth Tax as a non-resident (obligación real), that is, only on what you hold in Spain. And the Spanish Tax Agency (AEAT) states in its Modelo 720 FAQs that you do not have to file the foreign assets return. See our guide to Wealth Tax for non-residents.

An example at the top end. On a salary of €800,000 you would pay €144,000 on the first €600,000 (at 24%) and €94,000 on the remaining €200,000 (at 47%). That is €238,000 in total, an effective rate of 29.75%.

It pays off with high salaries and wealth held outside Spain. With mid-range income, children, significant deductions or income from treaty countries, ordinary income tax can be cheaper or safer. And the choice matters, because anyone who waives the regime or is excluded can never opt in again.

Where is the break-even point? We ran the numbers for a single person with no children living in Madrid, with no other income or deductions, using the state scale, the Madrid regional scale and approximate Social Security contributions. The regime starts to beat ordinary income tax at around €65,000 gross a year. Below that, it costs more. In regions with higher regional rates the threshold is somewhat lower, and if you have substantial dividends or income abroad, the balance tips towards the regime much earlier.

There is also a less visible cost. For the AEAT, anyone who opts in is not resident for double tax treaty purposes; its Non-Resident Taxation Manual says so in its October 2026 edition. If you receive income from a treaty country, that country may refuse you treaty benefits.

You apply by notifying the Spanish Tax Agency that you opt in, no later than six months after the activity start date shown on your Spanish Social Security registration, or on the document that keeps you in your home country’s system. Miss that deadline and the regime is gone.

The process, in the order we handle it at the firm:

1. Work out which year you become resident. The regime starts in the first calendar year in which, after relocating, you spend more than 183 days in Spain.
2. Pin down the date that starts the clock. It is the activity start date on your Social Security registration, not your arrival date.
3. Gather the documents for your route: Social Security registration or certificate, a residence permit if you need one, and the supporting document from your employer, company or ENISA.
4. File on the AEAT e-office within the six months.
5. Give your payer the certificate the Tax Agency issues, so that it withholds at 24%. The rules allow ten working days to issue it; in practice we see waits of two weeks to four months, depending on the tax office.
6. Annual return on Modelo 151.

The mistake we see most often is in step 2: counting the six months from landing in Spain, or from signing the contract. Once you are registered with Social Security, the clock is running.

It covers the year you become tax resident and the following five: six tax returns at most. You lose it by waiver, filed in November or December for the following year, or by exclusion, when you stop meeting a requirement. Either way, you can never come back.

A sample timeline: if you arrive in September 2026, you will usually not exceed 183 days that year. Your first year of residence will be 2027, and the regime will run from 2027 to 2032.

The rules and the DGT give fairly clear guidance on losing it:

• Waiver: voluntary, in November or December of the year before you want to return to ordinary income tax.
• Exclusion: takes effect in the same year as the breach, and you must report it within one month.
• Going self-employed: ruling V2248-24 excludes, from that same year, anyone who leaves their job and invoices through a permanent establishment outside the entrepreneur or highly qualified routes.
• Changing employer: not in itself a ground for exclusion, provided you keep meeting the conditions.
• Sole shareholder and director: the director route is accepted even if you hold 100% of a non-holding company. But be careful: if what you earn for carrying out the activity yourself is classed as business income obtained through a permanent establishment, you breach Article 93.1.c). We analyse it in Beckham Law and setting up a company in Spain.

Since 2023 your spouse and children can opt in too, subject to strict conditions. There are also three issues worth knowing before you arrive: the deemed income the Tax Agency charges on your main home, your residence for treaty purposes, and Inheritance and Gift Tax, which follows its own rules.

Spouse and children

Article 93.3 allows your spouse and children under 25 (or of any age, if disabled) to opt in. They must move with the main taxpayer or later, before the end of his or her first year under the regime; become tax resident; meet the no-prior-residence and no-permanent-establishment requirements; and, every year, their combined tax bases must be lower than the main taxpayer’s. Each files their own form, within six months of entering Spain or within the main taxpayer’s deadline, if later. Divorce does not trigger exclusion.

Main residence: TEAC versus the Madrid High Court

In its resolution of 17 July 2025 (RG 00/03697/2025), issued to unify criteria, the Central Economic-Administrative Court (TEAC) holds that impatriates must declare deemed income on their urban properties in Spain, including their main home. The High Court of Justice of Madrid disagrees and said so again in judgment 665/2025 of 17 September.

In figures: a home with a cadastral value of €400,000, revised within the last ten years, generates deemed income of 1.1% in 2026 (€4,400), which at 24% means around €1,056 of tax a year. Watch 2027. Royal Decree-law 29/2026 replaces that rate with a scale from 1.1% to 3% on the combined cadastral values; since the non-resident tax rules refer to that provision, the same home would generate €5,600 of deemed income (€1,344 of tax). When we closed this guide, the decree-law was awaiting parliamentary validation.

Treaties, inheritance and Social Security

• Treaties: as seen above, the AEAT does not treat you as resident for treaty purposes, and the residence certificate you can request has limited scope.
• Inheritance and gifts: the regime does not extend to this tax. As a resident, you are taxed on everything you inherit or receive as a gift, wherever it is located. If your family holds assets abroad, plan ahead; our guide to inheriting assets abroad while living in Spain explains how.
• Social Security: unchanged. You contribute like any other worker.

In practice, the regime is won or lost on paperwork: the Modelo 149 deadline, a well-documented route and an activity that does not end up looking like a permanent establishment. These three anonymised cases reflect situations we see regularly.

Case 1. Executive relocated to Madrid on €200,000. María, a Mexican national, joins the Spanish subsidiary of a multinational. Under the regime she pays €48,000 a year. Under ordinary income tax, single and without children, she would have paid around €73,700 (indicative calculation). She saves about €25,700 a year, over €150,000 across the six years if her salary stays the same.

Case 2. Remote employee of a Canadian company. Carlos, a British national, works remotely as an employee and earns €120,000. The telework visa gives him legal residence and, at the same time, evidences his route. He pays €28,800, against around €39,400 under ordinary income tax in Madrid. His salary is taxed in Spain even though a foreign company pays it; his foreign dividends are not.

Case 3. Spaniard returning to launch a start-up. Juan had spent eight years in Singapore. He can opt in as an entrepreneur, but needs ENISA’s favourable report before he moves: if he arrives first and applies later, he loses that route. And if he will be sole director and provide the company’s services himself, his pay needs careful structuring in light of ruling V1200-26.

The mistakes we see most often:

• Counting the Modelo 149 six months from arrival instead of from Social Security registration.
• Starting to invoice as self-employed without fitting the entrepreneur or highly qualified routes.
• Failing to report an exclusion within one month.
• Buying a home without budgeting for the deemed income the TEAC requires.
• Assuming double tax treaties protect you as they would any other resident.

Can Spanish nationals returning to Spain use the Beckham Law?

Yes. What counts is tax residence, not nationality: you only need not to have been Spanish resident in the five years before relocating, and to meet the other requirements. The DGT confirmed this in ruling V2460-25 for a Spaniard working remotely from the United States who, because of his nationality, could not apply for the telework visa.

Is there a minimum salary for the Beckham Law?

No. The law sets no minimum salary. Whether it pays off is another matter: on our figures for Madrid, a single person with no children only starts saving from around €65,000 gross a year. Below that, ordinary income tax, with its deductions and allowances, is usually cheaper.

Can freelancers or the self-employed apply?

Only if their activity qualifies as entrepreneurial, with a favourable ENISA report, or if they are highly qualified professionals serving start-ups or working in training and R&D+i. An ordinary freelancer earns income through a permanent establishment and falls outside the regime.

Do I need to file Modelo 720 under the Beckham Law?

No. The AEAT considers that people under the regime are not required to file it, because they are not taxed on worldwide income. Family members who are resident and have not opted in should check their own obligation. We cover it in our Modelo 720 guide.

What happens if I file Modelo 149 late?

You can no longer apply the regime and will pay ordinary income tax like any other resident. The six-month period in Article 116 of the Regulations cannot be extended, which is why it pays to have your documents ready even before your Social Security registration.

Can I change jobs without losing the Beckham Law?

Yes, provided you still meet the requirements: changing employer is not, in itself, a ground for exclusion. What does take you out of the regime is starting to earn income through a permanent establishment outside the permitted routes, which you would have to report within one month.

How long does the Tax Agency take to confirm the regime?

The rules give it ten working days to issue the certificate, but in practice it takes longer, sometimes months. In the meantime, your employer may withhold tax under ordinary income tax rules. Those withholdings are deducted on Modelo 151 and, if there is an excess, the Tax Agency refunds the difference.

If you earn more than about €65,000 a year, hold wealth outside Spain or are coming to run a company, probably yes. If your income is moderate, you have children or income from treaty countries, run the numbers first: it is a one-shot decision. Either way, the calendar rules: six months from your Social Security registration.

At Martínez-Cardós Abogados we review your whole situation before the clock runs out: eligibility, comparison with ordinary income tax, Modelo 149, and the Wealth Tax, inheritance and corporate implications. Contact us or call +34 660 456 823.

Mario Martínez-Cardós Bada. View full profile.