Beckham Law in Spain: Tax Regime for Expats and Impatriates

The Beckham Law (Ley Beckham) is the colloquial name for Spain's Régimen Especial de Trabajadores Desplazados a Territorio Español — a special tax regime that lets workers relocating to Spain pay a flat 24% tax rate on Spanish employment income instead of the progressive IRPF scale (19%–47%). Named after footballer David Beckham, who benefited from it when joining Real Madrid, the regime is now one of Spain's key tools for attracting international talent.

What Is the Beckham Law?

The Beckham Law is not a standalone statute but a set of provisions within Spain's personal income tax law (Ley del IRPF), originally introduced by Real Decreto 687/2005 and significantly expanded by Ley 28/2022 (the Ley de Startups).

The core mechanism: although you physically reside in Spain, you are treated as a non-resident for tax purposes, following the rules of the IRNR (Impuesto sobre la Renta de No Residentes). This produces three major consequences:

1. Flat tax rate on employment income (24% up to 600,000 EUR)
2. Exemption from tax on most foreign-source non-employment income
3. No obligation to declare foreign assets (Modelo 720/721)

Before 2015, these provisions were housed under the IRNR law itself, which explains why many of the regime's rules follow non-resident taxation logic.

Eligibility Requirements

1. Not a Spanish Tax Resident in the Previous 5 Years

You must not have been a tax resident of Spain during the 5 tax years preceding your relocation. Before the 2023 reform, this look-back period was 10 years.

Note that Spain determines tax residency using multiple criteria beyond the 183-day rule — centre of vital interests and family ties are also considered. However, for Beckham Law purposes, the relevant criterion is specifically the 183-day rule as established in Article 115 of the IRPF Regulations.

2. Relocation Linked to a Qualifying Activity

Your move to Spain must result from one of the following:

• Employment contract with a Spanish company or a permanent establishment in Spain
• Company directorship with less than 25% ownership in the case of entidades patrimoniales (no ownership limit for certified startups)
• Any of the expanded categories under the Ley de Startups (see below)

Critically, the employment relationship must exist before the physical relocation to Spain. The common assumption that you can move first, find work, and then apply is a legally questionable grey area. The law was designed for trabajadores desplazados — workers displaced (effectively "seconded") to Spain — and the causal link between the job and the move is a fundamental requirement.

3. Work Performed Mainly in or for Spain

The employment income must derive from work carried out effectively in Spain or for entities residing in Spain. A limited portion of work performed abroad is tolerated without losing the regime.

4. Application Deadline

You must file Modelo 149 with the AEAT within 6 months of your Seguridad Social registration date.

Expanded Categories Since the Ley de Startups (2023)

Ley 28/2022 significantly broadened who can access the regime. Since 2023, the following categories also qualify:

• Startup founders and directors — even with ownership exceeding 25%, if the company holds ENISA certification as an innovative startup
• Digital nomads — holding a nómada digital visa (NLV) under Ley 14/2013, working remotely for foreign employers
• International remote workers — with a permanent employment contract with a foreign company and the corresponding residence authorization
• Entrepreneurs — relocating under the emprendedor category of Ley 14/2013
• Highly qualified professionals — in R&D and innovation roles at emerging companies or recognized entities
• Family members — spouse (or domestic partner) and children under 25 (or any age if disabled) who relocate with or after the main applicant, provided their income does not exceed that of the primary beneficiary

These additions reflect Spain's effort to compete for international talent, though practical application remains limited by the lack of established case law and administrative guidance.

Duration

The Beckham Law applies for the tax year of relocation plus the following 5 tax years — up to 6 consecutive tax periods.

A strategic note: the first applicable period is the tax year in which you accumulate 183+ days of presence in Spain. If you arrive in January, your first full calendar year counts. If you arrive in September, you may not reach 183 days that year, pushing the start to the following January. This is not necessarily a disadvantage — during the gap, your employer withholds at the 24% non-resident rate (IRNR) anyway — but it affects your overall timeline.

Tax Rates and How They Work

Employment Income

Income bracket	Beckham Law rate	Standard IRPF rate
Up to 600,000 EUR	24%	19%–47% (progressive)
Above 600,000 EUR	47%	47%

The 24% rate applies to all employment income (rendimientos del trabajo) considered obtained in Spain. Under the regime, all income from work or economic activity — regardless of where the employer is based — is deemed Spanish-source.

Foreign Non-Employment Income

Income from foreign sources other than employment is exempt from Spanish taxation. This includes:

• Dividends from foreign companies
• Rental income from property outside Spain
• Capital gains on sale of foreign assets
• Interest from foreign bank accounts

However, if any such income qualifies as Spanish-source under the IRNR law (e.g., rent from a property located in Spain), it will be taxed.

Savings Income

Spanish-source savings income (dividends from Spanish companies, interest, capital gains) is taxed at the progressive savings scale: 19% up to 6,000 EUR, 21% from 6,000 to 50,000 EUR, 23% from 50,000 to 200,000 EUR, 27% from 200,000 to 300,000 EUR, and 30% above 300,000 EUR.

When Does the Beckham Law Make Sense?

There is no universal income threshold, but as a rough guide:

• Below 60,000 EUR/year in employment income with no significant foreign income: the advantage is marginal. The effective IRPF rate at this level (around 24-26%) is comparable to the flat 24%, and you lose access to standard deductions and allowances.
• Above 60,000-80,000 EUR/year, the gap widens progressively. At 100,000 EUR, the standard effective rate approaches 30-35%, while Beckham stays at 24%.
• The real value often lies in the foreign income exemption and no Modelo 720/721 obligations, especially for those with investments, property, or business interests abroad.

A personalized calculation must factor in: family situation (joint filing is not available under Beckham), foreign assets, plans beyond the 6-year window, and the loss of double taxation treaty benefits.

Key Tax Implications

Double Taxation Treaties

A frequently overlooked issue: Beckham Law beneficiaries cannot fully benefit from Spain's double taxation treaties (CDI). The AEAT has clarified (binding consultation V2918-17) that while a Spanish tax residency certificate can be obtained, it is not valid for treaty purposes.

This can create real double taxation: your country of origin taxes certain income, and Spain does not allow the treaty-based credit. This risk must be evaluated individually, especially if you maintain income sources in other countries.

Wealth Tax

Under Beckham, you are subject to Spain's Impuesto sobre el Patrimonio (Wealth Tax) only on assets located in Spain, not on your worldwide wealth. For those with significant foreign assets, this can represent substantial savings.

No Standard IRPF Deductions

You cannot apply the personal and family minimums, deductions for housing, donations, or other allowances available under the general IRPF regime. Joint filing with a spouse is not possible.

What Happens After 6 Years

When the regime expires, you transition to the general IRPF regime:

• Progressive rates up to 47% on worldwide income
• Mandatory filing of Modelo 720 and Modelo 721 for foreign assets
• All standard deductions and allowances become available
• Full access to double taxation treaty benefits is restored

Planning for this transition should begin well before year 6. It is worth considering whether the tax savings during the Beckham period offset the potential burden afterward, and whether remaining in Spain long-term is part of your plan.

Application Process

Step 1: Modelo 149

File Modelo 149 with the AEAT within 6 months of your Seguridad Social registration. The form requires:

• Personal data and NIF/NIE
• Date of entry into Spain
• Employer details or nature of activity
• Election to apply the special regime

Step 2: Annual Return via Modelo 151

Once under the regime, your annual income tax return is filed using Modelo 151 (not the standard Modelo 100). The filing deadline aligns with the standard Renta campaign (typically April–June).

In some cases, you may also need to file Modelo 210 for certain Spanish-source income taxed under IRNR rules.

Step 3: Opting Out or Exclusion

You can voluntarily renounce the regime by filing a new Modelo 149. The AEAT can also revoke it retroactively if conditions are found to have been violated, potentially resulting in back taxes, interest, and penalties.

Basque Country Variant

Beyond the national regime, the Basque Country (País Vasco) — specifically Bizkaia, Gipuzkoa, and Araba/Álava — offers its own version of the displaced workers regime under its autonomous fiscal framework (Derecho Foral).

Key differences from the national Beckham Law:

• Duration: up to 11 years (vs. 6 nationally)
• 30% reduction of qualifying income before applying the progressive scale (instead of a flat 24% rate)
• Relocation expense deduction of up to 20% of qualifying income (rent, moving costs, up to 2 return trips per year)
• Stricter qualification requirements: must correspond to Grupo de Cotización 1 (engineers, graduates, senior management)
• Autónomos welcome without special restrictions, provided they use estimación directa normal
• Foreign asset declarations required: unlike the national regime, Modelo 720 must be filed
• The Basque progressive scale is more favorable up to 150,000-200,000 EUR/year; above that, the national flat 24% wins

The Basque variant suits highly qualified professionals working in companies based in the País Vasco, but its complexity and strict qualification criteria limit its accessibility.

Official Sources

• Article 93, Ley 35/2006 del IRPF — special regime provisions
• Real Decreto 687/2005 — régimen especial impatriados — BOE
• Ley 28/2022 (Ley de Startups) — ampliación del régimen — BOE
• Real Decreto 1008/2023 — desarrollo reglamentario — BOE
• Ley 14/2013 — entrepreneur visas and residency
• Régimen especial de trabajadores desplazados — AEAT
• Gravamen de la base liquidable del ahorro — AEAT
• Modelo 149 — comunicación de la opción — AEAT
• Modelo 151 — declaración del IRNR — AEAT
• Binding consultation V2918-17 — on tax residency certificates and treaties

Related Guides

• Tax Residency in Spain — criteria for becoming a Spanish tax resident
• Double Taxation Treaties — bilateral agreements and how they interact with the regime
• Modelo 100: Annual Income Tax Return — the standard IRPF return
• Tax Obligations for autónomos — filing calendar and forms
• Autónomo Social Security Contributions — Seguridad Social payments