Pre-arrival opinion · Spain

The six years are the easy part. Year seven is the bill.

Under the article 93 regime you pay Spanish wealth tax and the solidarity tax on Spanish assets only. Not worldwide. For six years. Then the regime ends, everything you own enters the base at once, and the planning that would have worked had to happen before you arrived. This is an opinion delivered before you move, not a form-filling service after.

Request the opinion ↗ See the arithmetic first ↗ Scope and fee agreed before any work
Before you talk to anybody What the two regimes actually cost you

Verified scales: the state and regional income tax scales for all seventeen jurisdictions, the state wealth tax scale in article 30 of Ley 19/1991, and the solidarity tax in article 3 of Ley 38/2022. Nothing is sent anywhere and nothing is stored.

Assets less debts. Business assets may qualify for exemptions this model does not apply.
Spanish property, Spanish company shares, assets held here. This is the number the article 93 regime turns on.
Income the regime taxes. Foreign income is outside it altogether.
Ordinary residence
Worldwide income and worldwide assets.
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Total for the first year
Income tax— Wealth tax, state scale— Solidarity tax—
Article 93 regime
Spanish-source income, Spanish assets only.
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Total for the first year
Income tax at 24 then 47 per cent— Wealth tax, Spanish assets— Solidarity tax—
Six-year difference
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Enter your figures.
And then year seven

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Pre-arrival opinionA written opinion before you become resident
from 5,000 EURFixed on scope, agreed in advance
01
Residence date modellingWhen you become resident, on the 183-day count and the centre-of-interests test, and what the arrival date does to the first year.
02
Article 93 eligibilityWhich of the five routes you qualify under, whether the five-year prior non-residence holds, and whether your family can come in with you.
03
Wealth and solidarity tax positionYour Spanish base against your worldwide base, the regional election, and the interaction with the solidarity tax.
04
The year-seven planWhat the position becomes when the regime ends, and which decisions have to be taken before arrival rather than after.
The fee depends on the number of jurisdictions your assets sit in and whether a departure-side analysis is needed. We quote it before starting and we do not bill on the outcome. Tax return preparation, if you want it, is quoted separately and is not part of this.
01 · What this is not

An article 93 application is a form. This is the decision behind it.

Filing the modelo 149 takes an afternoon. Whether you should, when you should arrive, in which region, holding what, and what happens in year seven — those are the questions that move real money, and they are all decided before you land.

01
The wealth side dominatesMost people evaluate the regime on the 24 per cent income tax rate. On any substantial balance sheet the larger number is that wealth tax and the solidarity tax reach Spanish assets only. That is the lever, and it is invisible on a rate card.
02
You stop being a treaty residentThe Agencia Tributaria is explicit: an article 93 taxpayer is not treated as resident for the purposes of a double tax treaty, because they are taxed only on Spanish-source income. People plan around treaty protection they do not have.
03
The region is an election, taken wholeAn article 93 taxpayer may apply the wealth tax rules of their region, but if they do they must apply all of them. Six regions rewrote those rules around the solidarity tax. Picking correctly is arithmetic, not preference.
04
Arrival date is a variableResidence attaches for a whole tax year. Whether you arrive in June or in December changes which year is your first, and therefore when the six years end. It is the cheapest decision on this page and the one most often already spent.
02 · The clock

Six years, counted in tax years, not birthdays.

The regime applies for the tax period in which you change residence and the five following periods. If you arrive in November 2026, 2026 is your first year and 2031 is your last. Arriving in January 2027 instead buys you almost a full extra year of the regime, for the price of two months.

Before arrivalEverything that can be done is done here

The composition of your balance sheet, where assets sit, whether to realise gains under the old residence, the arrival date itself, and the departure-side consequences in the country you are leaving. After you are resident, most of this is closed.

Within six monthsThe election

The modelo 149 has a deadline running from the start of the activity. Missing it is not curable by explaining that you meant to file. Family members elect separately and their bases have to stay below yours.

Years one to sixSpanish assets only

Modelo 151 for income and, where the thresholds are met, the wealth tax and the solidarity tax on the Spanish base. This is the window the whole plan exists to use.

Year five or sixThe review that has to happen early

Whether to leave before the regime ends, restructure while it still applies, or stay and accept the worldwide base. Each option needs a year of lead time, which is why we sell this as a separate engagement rather than an afterthought.

03 · Year seven

The second engagement, sold separately because it is a different question.

A year before the regime ends the arithmetic changes completely: your worldwide assets are about to enter the Spanish base. The options narrow as the date approaches, and two of the three need to be executed in the year before, not the year of.

What the review covers

  • The size of the step-up, computed on your actual balance sheet rather than a projection.
  • Whether the regional election still works once the worldwide base applies.
  • The exit tax position under article 95 bis if leaving is on the table, which it usually is.
  • Whether a change of region inside Spain does enough to be worth the move.
  • What the 60 per cent combined cap does for you, and what it does not.

Why it is not bundled

  • It happens five or six years after the first engagement, on a balance sheet that has changed.
  • Pricing it upfront would mean quoting for work whose inputs do not exist yet.
  • Plenty of clients will have left, or will have circumstances that make it moot.
  • Clients who took the first opinion get the second scoped against that file, which makes it cheaper than it would be cold.
05 · Honest limits

What we will tell you that a brochure will not.

Sometimes the answer is do not electWhere Spanish income is modest and your assets are largely in Spain already, the regime costs more than ordinary residence. The calculator above will show you that outcome rather than hide it.
Sometimes the answer is not SpainIf the decision is driven purely by tax on a large passive portfolio, other jurisdictions do better and we will say so. We would rather lose the engagement than write an opinion we do not believe.
We are not your investment adviserWe will tell you what a structure costs in tax. What it should hold, and whether the underlying assets are sensible, is not our call and we do not take a view on it.
The 60 per cent cap is real but narrowThe combined limit on income, wealth and solidarity tax helps a specific profile, mostly low-income high-asset. It is modelled in the engagement and deliberately left out of the calculator above, because half-modelling it misleads.
Departure-side advice needs local counselExit taxes and deemed disposals in the country you are leaving are not Spanish law. We coordinate with advisers there, and where you have none we will say that the opinion is incomplete without one.
Business assets change everythingShares in an active trading company can be exempt from wealth tax entirely if the conditions are met. Those conditions are strict, they are tested annually, and they are the single largest variable we look at.
06 · Questions

Asked before every engagement.

Is the solidarity tax not temporary?

It was introduced for two years and then extended indefinitely by Real Decreto-ley 8/2023, pending a review of wealth taxation as part of the reform of regional financing. It applied in 2026 and the only change this year was to the annex of the form, by Orden HAC/652/2026. Planning on the assumption that it will disappear is a position, not a forecast, and we will not write an opinion that rests on it.

I have heard Madrid has no wealth tax. Does that not solve it?

It did until 2022. Madrid relieved its wealth tax almost entirely, and then the solidarity tax arrived as a state tax that cannot be devolved and that allows a deduction only for wealth tax actually paid. If the region waives its tax, you pay the state instead. Madrid and five other regions have since restructured their relief around that, which is why the answer now depends on your specific numbers rather than on the region alone.

Does the regime cover my foreign investment income?

No, and that is the point of it. An article 93 taxpayer is taxed on Spanish-source income. Foreign dividends, interest and gains are outside the Spanish net during the regime. It also means you are not a treaty resident of Spain, so you cannot claim treaty relief as one, and the source country may tax you accordingly.

Can my spouse and children join the regime?

Since 2023, yes, on conditions. They must move with you or before the end of your first year under the regime, become Spanish resident, and the sum of their taxable bases must stay below yours. Their period is tied to yours. Where the wealth sits in the lower-earning spouse, this changes the answer materially and it is one of the first things we look at.

We are already resident. Is it too late?

For electing into the regime, if you have been resident for more than the permitted period, yes. For everything else, no. Region, structure, the wealth tax exemptions for business assets and the year-seven question are all still live, and a surprising amount of value sits in them. We will tell you honestly if there is nothing worth doing.

What does the opinion actually look like?

A written document addressed to you, setting out the facts we relied on, the analysis, the numbers, the options with their consequences, and what is uncertain and why. It is the kind of document you can hand to a bank, a co-investor or another adviser. It is not a slide deck and it is not a recommendation to buy anything.

Six years is long enough to forget it ends. It ends.

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