Beckham Law Spain | Euroaccounts Madrid

The special regime for workers posted to Spain, known as the Beckham Law, is regulated under Article 93 of Law 35/2006 (Personal Income Tax Act) and allows professionals who transfer their tax residence to Spain to be taxed as non-residents during the year of arrival and the following five years, paying a flat rate of 24% on the first EUR 600,000 of employment income (47% on the excess), versus the standard progressive scale that reaches 47% from EUR 300,000. Euroaccounts, since 1996 in Madrid and with over 500 international companies advised, has managed the application and maintenance of this regime for hundreds of posted executives and professionals. As members of INPACT Global, we coordinate tax planning in both origin and destination countries to maximise savings during the regime's 6-year duration.

Flat rate of 24% on the first EUR 600,000 of employment income (47% on the excess)
Duration: year of arrival + 5 following years = 6 years total
Exemption from Wealth Tax on assets located outside Spain
Requirement: must not have been Spanish tax resident in the 5 preceding years (reduced from 10 by the Startup Law)
Application via Form 149 to the AEAT within 6 months of Social Security registration
Expanded by Law 28/2022 (Startup Law): now includes entrepreneurs, directors and digital nomads

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Specialised Beckham Law Services

From eligibility analysis to annual tax returns and exit strategy

Eligibility Analysis and Tax Simulation

We verify whether the professional meets all requirements under Article 93 LIRPF and the RIRPF (Articles 113-120 of RD 439/2007). We produce a detailed comparative simulation between the Beckham regime and the standard IRPF regime to determine the real savings based on total compensation, including base salary, bonuses, stock options and investment income.

Application and Filing of Form 149

We prepare and file Form 149 (election notification) with the Tax Agency within the legal 6-month deadline from Spanish Social Security registration. We manage the favourable resolution and the special tax residency certificate that evidences taxation under Article 93 LIRPF to third countries and paying entities.

Annual Tax Return (Form 150)

Beckham Law taxpayers do not file the standard Form 100 (IRPF) but rather Form 150 (NRIT return for posted workers). Euroaccounts prepares and files this return each year, calculating the tax base under the regime's special rules: only income obtained in Spanish territory is taxed (with exceptions for employment income).

Exit Strategy and Transition to the Standard Regime

We plan well in advance the transition to the standard IRPF regime once the 6 years expire or if the taxpayer decides to renounce early. We assess the impact on Wealth Tax (shifts to worldwide assets), IRPF (progressive rates) and the obligation to declare overseas assets (Form 720). Exit planning should begin at least 12-18 months beforehand.

Beckham Law Application Process

Steps from arrival in Spain to obtaining the special regime

1

We verify that the professional meets the 5 requirements under Article 93 LIRPF: (1) not having been Spanish tax resident in the 5 preceding years, (2) that the posting results from an employment contract, appointment as director, entrepreneurial activity, or remote work, (3) no income through a PE in Spain, (4) that foreseeable employment income is not exempt from NRIT. We gather supporting documentation and verify compliance with the home-country adviser.

2

Social Security registration triggers the 6-month deadline for applying. The registration date is critical and must be coordinated with the date of entry into Spain and employment contract signing. Euroaccounts coordinates with the company and the labour consultant to ensure registration occurs on the optimal date from a tax perspective.

3

We file Form 149 (election, approval or renunciation of the special regime) with the AEAT. This form is filed electronically and must include taxpayer identification, date of entry into Spain, Social Security registration date and the employing entity. The AEAT issues a resolution in approximately 1-2 months. Meanwhile, the employer can already apply the reduced 24% withholding.

4

Once the favourable resolution is obtained, the taxpayer is registered under the special regime. A tax residency certificate can be requested with express reference to Article 93 LIRPF, needed for applying double tax treaties as a non-resident (the applicability of DTTs under Beckham has nuances that must be analysed case by case).

5

Each year, during the filing period, we file Form 150 instead of Form 100. This form applies NRIT rules: flat 24% on the first EUR 600,000 of employment income (47% on the excess). Savings income (dividends, interest, capital gains from Spanish sources) is taxed at 19%-28% in brackets. Foreign-source income other than employment is exempt.

6

Before the regime ends (year of arrival + 5), we analyse options: asset restructuring prior to entering the standard regime, planning the Wealth Tax return on worldwide assets, evaluating Form 720 (informative declaration of overseas assets), and possible change of tax residence if the executive is being relocated by the company.

COMPARATIVE ANALYSIS

Beckham Law vs. Standard IRPF — Complete Comparison

The difference between being taxed under the Beckham Law and the standard IRPF regime can amount to tens of thousands of euros annually for an executive with compensation from EUR 100,000 upwards. Below is a rigorous comparison based on legislation in force in 2026.

Tax rates — Employment income:

Beckham Law: flat 24% on the first EUR 600,000 of employment income. The excess is taxed at 47%. No personal or family allowances apply, but neither are complex deductions required.
Standard IRPF: progressive scale (state + regional) from 19% (first EUR 12,450) to 47% (above EUR 300,000). In the Community of Madrid, the combined maximum marginal rate is 45.5% above EUR 300,000.

Practical example with gross salary of EUR 200,000/year:

Beckham: 200,000 x 24% = EUR 48,000 gross tax.
Standard regime (Madrid): approximately EUR 72,900 (after standard personal allowances).
Annual saving: approximately EUR 24,900, which over 6 years amounts to nearly EUR 150,000 cumulative savings.

Example with gross salary of EUR 400,000/year:

Beckham: 400,000 x 24% = EUR 96,000.
Standard regime (Madrid): approximately EUR 165,800.
Annual saving: approximately EUR 69,800, which over 6 years exceeds EUR 418,000.

Wealth Tax (Impuesto sobre el Patrimonio): Under the Beckham Law, the taxpayer is treated as a non-resident for Wealth Tax purposes, meaning they are only taxed on assets located in Spain. Under the standard regime, a tax resident is taxed on worldwide assets. For executives with significant assets outside Spain (property, accounts, investments), this difference can be even more significant than the IRPF saving.

Solidarity Tax on Large Fortunes (ISGF): Although the Community of Madrid provides a 100% relief on Wealth Tax, the ISGF (Law 38/2022, indefinite validity since RDL 8/2023) is a supplementary state tax on net assets exceeding EUR 3,000,000. Beckham taxpayers are taxed on a real obligation basis (Spanish assets only), but if their Spanish assets — for example, a luxury residence, company shares or bank accounts — exceed EUR 3M, they will be subject to the ISGF. This nuance is especially relevant for senior executives with compensation packages that include shares in the Spanish entity.

Form 720 — Overseas Asset Declaration: Those under the Beckham regime, being taxed as non-residents, are not required to file Form 720. When transitioning to the standard regime, this obligation activates if thresholds are exceeded (EUR 50,000 per asset category). The transition must be carefully planned.

Savings income: Under both Beckham and the standard regime, Spanish-source savings income is taxed in brackets: 19% up to EUR 6,000, 21% from EUR 6,000 to EUR 50,000, 23% from EUR 50,000 to EUR 200,000, 27% from EUR 200,000 to EUR 300,000, and 28% above EUR 300,000. The difference is that under Beckham, foreign-source savings income is exempt.

Savings of up to EUR 69,800/year for EUR 400,000 salaries (Beckham vs. standard in Madrid)
Wealth Tax exemption on assets outside Spain during the 6 years
No Form 720 obligation while the regime lasts
Foreign-source savings income exempt under Beckham
Cumulative savings over 6 years can exceed EUR 400,000 for senior executives

REQUIREMENTS AND ELIGIBILITY

Detailed Requirements for Electing the Beckham Law in 2026

Law 28/2022 of 21 December on the promotion of the emerging company ecosystem (known as the Startup Law) substantially amended Article 93 of Law 35/2006, broadening the grounds for access to the Beckham regime. The updated requirements, in force in 2026, are as follows:

1. Must not have been tax resident in Spain in the 5 preceding fiscal years. The Startup Law reduced this period from 10 to 5 years, facilitating access for people who previously lived in Spain over five years ago. It is calculated by complete fiscal years (calendar years). The burden of proof lies with the taxpayer, who must be able to evidence their tax residence in another country during those 5 years (tax residency certificates issued by the home country’s tax authority).

2. The posting to Spain must be due to one of the following grounds:

a) Employment contract with a Spanish employer or with a foreign company posting the individual to a PE in Spain. This is the classic Beckham Law scenario, designed for posted executives and employees.
b) Appointment as director of a Spanish entity, provided participation in the share capital does not exceed 25% (this limit excludes majority shareholders who appoint themselves as directors).
c) Entrepreneurial activity — introduced by the Startup Law. Applies to individuals developing an innovative economic activity or one of special economic interest to Spain, subject to obtaining a favourable report from ENISA.
d) Highly-qualified professional providing services to emerging companies or to companies engaged in R&D activities, subject to accreditation.
e) Remote work — the so-called “digital nomad visa.” Professionals who work for a foreign company from Spain using digital means. They must evidence their employment or professional relationship with the foreign company and that the company permits remote work.

3. Must not obtain income qualifying as obtained through a permanent establishment in Spanish territory, except in the case of ground (b) (directors).

4. Application deadline: The election notification (Form 149) must be filed within 6 months from the date of Spanish Social Security registration or, where applicable, from the date of commencement of the activity shown in the taxpayer census. Missing this deadline results in exclusion and does not admit rectification. Euroaccounts rigorously monitors this calendar.

5. That foreseeable employment income is not exempt from Non-Resident Income Tax.

Eligibility checklist applied by Euroaccounts:

Tax residency certificates for the 5 preceding fiscal years (issued by the home country’s tax authority)
Employment contract in Spain or posting letter from the parent company with start date
Date of Spanish Social Security registration (or census registration for entrepreneurs)
Verification that shareholding does not exceed 25% in the Spanish entity (if director)
For entrepreneurs: favourable ENISA report on the innovative nature of the activity
For digital nomads: evidence of foreign company relationship and remote work authorisation
Deadline calendar: Form 149 deadline marked from day one

Prior non-residency period reduced from 10 to 5 years by the Startup Law (Law 28/2022)
5 grounds for access: employment contract, director (<25%), entrepreneur, qualified professional, remote work
Application deadline: 6 months from SS registration — non-extendable and non-rectifiable
For directors: 25% shareholding limit in the Spanish entity
Euroaccounts applies a 7-point checklist before filing Form 149

ADVANCED ISSUES

Advanced Beckham Law Issues: DTTs, Stock Options, Exit and Common Mistakes

The practical application of the Beckham Law presents complexities that go beyond the basic access requirements. Below we address the advanced issues that Euroaccounts regularly manages for executives and their companies.

Double Tax Treaties (DTTs) under Beckham: One of the most debated questions is whether a Beckham taxpayer can invoke the double tax treaties signed by Spain. By being taxed “as a non-resident” for domestic purposes, are they considered resident for DTT purposes? The General Tax Directorate (DGT) has maintained a changing position, but the majority doctrine and recent case law from the TEAC hold that a Beckham taxpayer is tax resident in Spain for all purposes (including DTTs), since Article 93 only modifies the tax calculation method, not the tax residence. This means they can request a Spanish tax residency certificate and benefit from reduced DTT rates for foreign-source income (dividends, interest, royalties). However, practical application depends on the specific DTT and the position of the other contracting state. Euroaccounts analyses each case individually.

Stock options, RSUs and long-term incentive plans: The tax treatment of stock options under Beckham requires careful analysis of the generation moment vs. the exercise moment. If options were granted before arriving in Spain but are exercised during the Beckham period, only the portion proportionate to the period worked in Spain is subject to Spanish tax. Quantification requires applying the proportionality rule under Article 14.1.c of the RIRPF (RD 439/2007) and, where applicable, the relevant DTT provisions. RSUs (Restricted Stock Units) raise a similar issue. Euroaccounts prepares the proportionality calculation and coordinates with the home-country adviser on the taxation of the portion not subject to tax in Spain.

Common mistakes that cause loss of the regime:

Late filing of Form 149. The 6-month deadline from Social Security registration is non-extendable. If missed, there is no recourse and the taxpayer remains in the standard regime for their entire stay. We have seen companies that were unaware of this deadline and lost tens of thousands of euros in tax savings for their executive.
Having been tax resident in Spain in the 5 preceding years. Extended stays, a former Erasmus scholarship with local registration, or having filed a Spanish IRPF return by mistake can cause rejection. It is essential to verify the complete tax history with the AEAT.
Failing to notify a change of employer. If the taxpayer changes companies during the Beckham period, they must verify that the new contract meets the requirements and notify the AEAT. A poorly managed change can result in exclusion from the regime.
Shareholding exceeding 25% in the Spanish entity. Directors who acquire or increase their stake above 25% are excluded.
Failing to plan the exit. When the 6 years end, the taxpayer automatically moves to the standard regime. Without planning, the first year under the standard regime can produce a brutal tax impact: worldwide wealth taxation, Form 720 obligation, and progressive IRPF rates on all worldwide income.

Early renunciation: The taxpayer may renounce the regime at any time by filing a new Form 149. This may make sense in situations where the standard regime is more favourable (e.g., if employment income is low but foreign savings income is high and deductions are desired). Euroaccounts annually evaluates whether the regime remains the optimal option.

Compatibility with the Startup Law (Law 28/2022): The Startup Law not only expanded access grounds but introduced the digital nomad visa and allowed entrepreneurs to elect the regime. However, entrepreneurs must first obtain a favourable ENISA report and meet additional innovation requirements. For professionals who work remotely from Spain for foreign companies, the Law establishes an additional requirement that remote work income must not exceed 20% of total income when partially providing services to a Spanish company.

DTTs applicable under Beckham: the taxpayer is a Spanish tax resident for treaty purposes
Stock options and RSUs: proportionality rule based on period worked in Spain vs. abroad
Most frequent mistake: filing Form 149 past the 6-month deadline — no rectification possible
Shareholding exceeding 25% in Spanish entity excludes directors
Exit planning essential: impact on Wealth Tax, Form 720 and IRPF when the 6 years end
Startup Law (28/2022): digital nomads with 20% cap on services to Spanish companies

Frequently Asked Questions

About the Beckham Law and the special regime for inbound workers in Spain

The Beckham Law is the colloquial name for the special tax regime for workers posted to Spain, regulated under Article 93 of Law 35/2006 (IRPF). It is named after David Beckham, who was one of the first high-profile beneficiaries when he signed for Real Madrid in 2003. The regime allows taxation at a flat 24% on employment income (up to EUR 600,000) for 6 years, versus the progressive standard rate that can reach 47%. Since the Startup Law reform in 2023, it was expanded to entrepreneurs, directors and remote workers.

The main requirements are: (1) not having been Spanish tax resident in the 5 fiscal years preceding the transfer, (2) that the posting results from an employment contract, appointment as director with shareholding below 25%, entrepreneurial activity with an ENISA report, or remote work for a foreign company, (3) no income through a PE in Spain, and (4) filing Form 149 within 6 months of Social Security registration. Euroaccounts verifies each requirement with supporting documentation before filing the application.

Savings depend on the compensation level. For a salary of EUR 150,000/year, the annual saving is approximately EUR 18,000 (EUR 108,000 over 6 years). For EUR 300,000/year, approximately EUR 45,000 annually (EUR 270,000 over 6 years). For EUR 500,000/year, savings exceed EUR 70,000 per year (EUR 420,000 cumulative). Additionally, Wealth Tax exemption on assets outside Spain can deliver significant additional savings for high-net-worth individuals. Euroaccounts produces a complete tax simulation before applying for the regime.

The application is made by filing Form 149 (election notification for the special regime) with the Tax Agency (AEAT) electronically. The deadline is 6 months from the date of Spanish Social Security registration. The form requires identification data, date of entry into Spain, SS registration date, employer details and a declaration of compliance with requirements. The AEAT issues a resolution in 1-2 months. Meanwhile, the employer can apply the 24% withholding. It is essential not to miss the deadline: it does not admit rectification or appeal.

Yes, since Law 28/2022 (Startup Law) came into force, the Beckham regime was expanded to three new categories: entrepreneurs with innovative activity (subject to a favourable ENISA report), highly-qualified professionals in emerging companies or R&D activities, and remote workers providing services from Spain to foreign companies via digital means. For the latter, services provided to Spanish companies cannot exceed 20% of total activity. Euroaccounts assesses the viability of each category and manages the specific documentation required.

Beckham taxpayers are treated as non-residents for Wealth Tax purposes, meaning they are only subject to tax on assets and rights located in Spain (property, Spanish bank accounts, shares in Spanish entities). Assets outside Spain are exempt. However, the Solidarity Tax on Large Fortunes (ISGF, Law 38/2022, indefinite validity) is a supplementary state tax on net assets exceeding EUR 3,000,000 that is not relieved by Madrid. If the Beckham executive’s Spanish assets — for example, shares in the subsidiary or property — exceed EUR 3M, they will be subject to the ISGF. Euroaccounts evaluates both taxes in the executive’s comprehensive planning.

This is a complex question. Although under Beckham the taxpayer is taxed “as a non-resident” for domestic purposes, the majority view of the DGT and the TEAC is that the taxpayer remains tax resident in Spain for DTT purposes. Therefore, they can request a Spanish tax residency certificate and apply reduced DTT rates for foreign-source dividends, interest and royalties. However, the position of the other contracting state may differ, and some DTTs have specific clauses. Euroaccounts analyses each situation individually and coordinates with the home-country adviser through INPACT Global.

When the 6 years expire (year of arrival + 5 following), the taxpayer automatically transitions to the standard IRPF regime. This entails three significant changes: (1) worldwide income taxation at progressive rates of 19%-47%, (2) worldwide wealth taxation under the Wealth Tax, and (3) obligation to declare overseas assets via Form 720 if thresholds of EUR 50,000 per asset category are exceeded. Euroaccounts recommends beginning exit planning at least 12-18 months beforehand, evaluating options such as asset restructuring or international relocation of the executive.

Insights

International Specialist Team

The international tax team at Euroaccounts, led by David Bua (ex-Big Four), has managed hundreds of Beckham Law applications for executives, qualified professionals and, since the 2023 reform, entrepreneurs and corporate digital nomads. Our trilingual team (Spanish, English and French) communicates directly with the head office HR department and home-country advisers through our INPACT Global network, ensuring coordinated tax planning at both ends of the posting. With over 500 international companies advised, we know the deadlines, common mistakes and strategies that maximise savings during the regime's 6 years and minimise the impact of transitioning to the standard regime.

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Assess Whether the Beckham Law Applies to Your Case

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Beckham Law Spain — Special Tax Regime for Inbound Workers

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