The Beckham Law: Spain's impatriate regime for relocating founders.
A flat 24% on Spanish employment income up to €600,000, for up to six tax years, taxed broadly as a non-resident while living in Spain. It is one of Europe's more attractive relocation regimes — and one of the easiest to lose through a missed deadline or the wrong shareholding.
Spain's special regime for workers posted to Spanish territory — universally called the Ley Beckham after the footballer whose move made it famous — allows a person who becomes Spanish tax resident to be taxed under non-resident income tax rules instead of the ordinary progressive system, for the year of arrival and the five following years.
For a founder relocating to Spain, the appeal is straightforward: a flat 24% on employment income up to €600,000 rather than a progressive scale that reaches materially higher rates at much lower income, and — usually more valuable — foreign-source income other than employment income generally falling outside the Spanish net during the period.
The regime was substantially widened by the Startups Law (Ley 28/2022) with effect from 2023, which cut the prior non-residence requirement from ten years to five, and extended eligibility beyond posted employees to remote workers, entrepreneurs, certain company directors, highly qualified professionals and qualifying family members.
Who can apply.
Director status combined with a substantial shareholding.
Being a director of a Spanish company is a qualifying route, but historically the regime excluded directors holding a significant stake in the company where the entity is an asset-holding vehicle. The interaction between your role, your shareholding percentage and the nature of the company is precisely where eligibility is won or lost — and it is a question to settle before you incorporate, not after.
What the regime does and does not cover.
| Income | Under the impatriate regime | Under ordinary residence |
|---|---|---|
| Spanish employment income | 24% up to €600,000; 47% above | Progressive scale, reaching high marginal rates well below that level |
| Worldwide employment income | Treated as Spanish-source and taxed here | Taxed as part of worldwide income |
| Foreign dividends, interest, rents | Generally outside the Spanish net during the regime | Taxed on a worldwide basis |
| Spanish-source investment income | Taxed under non-resident rules | Taxed under the savings scale |
| Capital gains on foreign assets | Generally outside scope | Taxed on a worldwide basis |
| Wealth tax | Generally limited to Spanish-situs assets | Worldwide assets, subject to regional rules |
| Foreign asset reporting | Generally not required while the regime applies | Modelo 720 and related reporting obligations |
That last pair of rows is frequently worth more than the headline rate. Ordinary Spanish tax residence brings worldwide taxation, potential wealth tax exposure and foreign asset reporting obligations with significant penalties for error. The impatriate regime narrows all three for its duration, which for a founder with assets and interests outside Spain can be the decisive factor.
Where it does not help.
Salaried founder or executive with foreign assets
High Spanish employment income, investment and business interests outside Spain, no Spanish tax history, and a clean qualifying route into the country.
Income taken as dividends from a Spanish company
The headline advantage attaches to employment income. If your compensation comes largely as Spanish dividends, or your wealth is Spanish-situs, the benefit narrows considerably and ordinary residence with proper planning may serve you better.
Two further limitations matter in practice. Access to double tax treaty benefits can be affected, because a person taxed under non-resident rules may not obtain a Spanish residence certificate for treaty purposes in the usual way — which can create friction with the country you left. And the regime interacts with foreign systems unevenly: US citizens, taxed on citizenship, need the analysis done on both sides before assuming a benefit exists at all.
The application, and the deadline that ends the conversation.
The six-month window is the single most common way this benefit is lost.
People relocate, deal with housing, schools and the business, and address personal tax in the spring when the first return is due. By then the election period has usually closed, and the regime is unavailable for the entire six years. The application belongs in the first weeks, not the first filing season.
Your company structure and your personal position are one decision.
How you are engaged, what you own and when you file all interact. We look at the corporate structure and the relocation together, before either is fixed.
- Regimen de impatriados
- The formal name of the regime — the special tax regime for workers posted to Spanish territory.
- Ley Beckham
- The colloquial name, after the first high-profile beneficiary.
- IRPF
- Impuesto sobre la Renta de las Personas Fisicas — Spanish personal income tax.
- IRNR
- Non-resident income tax, the rules applied to impatriates under the regime.
- Ley de Startups
- Ley 28/2022, which widened eligibility and cut the prior non-residence period to five years.
- Modelo 149
- The form by which the regime is elected, and by which waiver or exclusion is communicated.
- Modelo 151
- The annual return filed by taxpayers under the impatriate regime.
- Modelo 720
- Foreign asset reporting under ordinary residence — generally not required while the regime applies.
Can a founder who owns their Spanish company use the Beckham Law?
Does the regime cover my foreign dividends and capital gains?
What happens after six years?
Is it useful for US citizens?
Can my spouse and children be included?
Can I apply late if I only just heard about it?
Moving yourself and the business.
Six years at a flat rate. Decided in the first six months.
Book a free call ↗Alexander Baranov
Seventeen years designing and delivering cross-border corporate structures — incorporation, tax, holding, banking and market entry — for founders and companies expanding into Spain and the EU. Author of professional books on entering the Spanish market.
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