Beckham Law in Spain 2026: the tax regime for impatriates at a fixed rate

What is Beckham Law?

The scheme was created in 2004 to attract international executives. It owes its nickname to David Beckham, one of its first famous beneficiaries when he arrived at Real Madrid – professional athletes have since been excluded, but the name has stuck.

Legally, the mechanism is subtle: the beneficiary remains an IRPF taxpayer (the Spanish personal income tax), but he is taxed according to non-resident tax rules (IRNR). Two concrete consequences arise from this hybrid status.

First consequence: all employment income is deemed to be of Spanish source, even the part possibly earned abroad. They are taxed at a flat rate, period. Second consequence: everything that is not employment income and that comes from abroad – dividends from your French holdings, interest, rent from property remaining in France, capital gains – is not taxed in Spain. This is where most of the economy comes into play for a manager who keeps assets in France.

The reform which entered into force in January 2023 (law 28/2022, known as the “Startups law”, supplemented by decree RD 1008/2023) expanded the system, renamed for the occasion “regime for displaced workers, professionals, entrepreneurs and investors”. We come back to this below.

The rate of 24%: what is taxed, what is not

Rate source: Article 93 of the IRPF Law, consolidated BOE version.

Two points in this table deserve clarification, because they are poorly covered in most online publications.

A flat rate does not guarantee savings. The ordinary regime depends, among other things, on the autonomous community and personal circumstances. Gross salary alone does not determine the better option.

Ordinary IRPF or Beckham Law: prepare a reliable comparison

No salary break-even point or standard savings amount is published here without a validated scenario. A simulation must cite its tax schedules, state its assumptions and compare total tax, rather than marginal rates alone.

See the simulation method and the information to gather

Eligibility conditions in 2026

Three cumulative conditions, without exception:

1. Prior non-residence. You must not have been tax resident in Spain during the 5 tax years preceding your installation. This deadline was 10 years before the 2023 reform. For a French person who has never lived in Spain, the condition is met by default - but a previous Spanish stay, even short, can block everything.
2. An accepted professional reason. Employment contract with a Spanish company, intra-group transfer, appointment as administrator of a Spanish company (excluding a heritage company held at 25% or more), international teleworking under a digital nomad visa, or entrepreneurship in a certified startup.
3. No income through a permanent establishment. You must not receive income obtained through a permanent establishment located in Spain, except for the entrepreneurial cases introduced by the 2023 reform.

A request on time. The option must be exercised through Modelo 149 within 6 months of registration with Spanish Social Security (or the actual start of the activity). This deadline is imperative: after this point, the regime is lost for the entire period concerned.

Who is eligible, who is not — the state of the law in 2026:

The case of freelancers deserves a word of caution: the temptation is great to structure yourself as a “false employee” to enter the regime. The Spanish administration and courts look at the reality of the relationship – who sets the schedules, who provides the tools, who bears the economic risk – and bluntly reclassify. If you are independent, the legitimate routes are ENISA certification or the digital nomad visa, not contractual arrangements.

To test your situation point by point, we have published a complete checklist: eligibility conditions for the Beckham law.

What the 2023 reform has changed

Law 28/2022 for the promotion of the ecosystem of emerging businesses — the “Startups law” — modernised the regime on four points:

• The non-residency period is reduced from 10 to 5 years. This is the most concrete change for the French: a previous stay in Spain is now “erased” after 5 years.
• International teleworkers enter the system, via the digital nomad visa. Main conditions: work for a foreign company, provide proof of approximately €2,600 in monthly income (200% of the inter-professional minimum wage); an activity for Spanish customers is tolerated within the limit of 20% of the total.
• Qualified entrepreneurs and professionals (ENISA certified startup, R&D, visas under articles 71 and 72 of Law 14/2013) become eligible, including without a traditional employment contract.
• The scheme extends to the family: the spouse and children under 25 years of age (or disabled, without age limit) can opt for the scheme if they settle at the same time as the main beneficiary or before the end of the first tax year, and if their income remains lower than theirs. They then benefit from the same rules, including the Modelo 720 exemption.

The application step by step (Modelo 149, Modelo 151)

The procedure takes place entirely with the AEAT, the Spanish tax agency. It does not tolerate approximation well: a delay or part error cannot be repaired.

1. 1
   Before or upon arrival
   Obtain the NIE, register with the Censo Fiscal (Modelo 030), then with the Spanish Social Security. It is this last date which causes the 6 month period to run.
2. 2
   Create the file
   Employment contract (or letter of secondment, visa, ENISA certification as applicable), proof of non-residence in Spain over the previous 5 years — in practice, a certificate of French tax residence issued by the DGFiP is taken as proof.
3. 3
   Remove Modelo 149
   Mandatory deadline — 6 months
   Electronically on the AEAT website. This is the only form that is an option; without it, you are taxed under the ordinary regime even if you meet all the basic conditions.
4. 4
   Wait for resolution
   The AEAT theoretically has 10 working days; Instead, allow 1 to 2 months in practice, and respond quickly to any request for additional information.
5. 5
   Once the regime has been granted
   The employer applies a withholding tax of 24% on pay. Each year, you declare via Modelo 151 (campaign from April to June) instead of Modelo 100 for ordinary residents.

The limits of the regime — what the Beckham law does not allow

• None of the ordinary IRPF deductions or reliefs: no personal and family allowance, pension contribution relief or regional allowances.Include these differences in the personalised comparison; they do not establish a universal salary threshold.
• No conventional protection. During the duration of the regime, you are not considered a Spanish tax resident within the meaning of international tax treaties. If the other State also taxes you, you cannot invoke the Franco-Spanish convention against double taxation to escape it. On income from secondments or pensions, this lack of a safety net can create genuine double taxation — worth analysing before you sign.
• Severance pay is not exempt, unlike the ordinary regime which exempts them within certain limits.
• Wealth tax remains due on Spanish property (only foreign assets are out of scope), and inheritance and gift tax is not affected by the regime.

After 6 years: anticipate leaving the tax regime

At the end of the sixth fiscal year, you automatically switch to the ordinary IRPF, without formality or possibility of renewal. The shift is brutal for high incomes: return to the progressive scale, taxation of global income, Modelo 720 obligation, deductions to be reconstructed.

Good practice consists of preparing for this exit from the fourth year: possible restructuring of capital income, use of reduction envelopes (pension plans, within their limits), arbitration on residence if your professional situation has changed. Your social rights accumulated during the period — retirement, unemployment, health — remain fully acquired; only the method of taxation changes.

Structuring your installation: Iter Advisors support

The Beckham law does not decide on a displayed rate: it is based on your retained French income, your status (employee, administrator, entrepreneur), the tax agreement and the timetable for your installation. This is exactly the type of fiscal and social structuring that our Fractional CFOs in Barcelona handle for French executives relocating to Spain — working with local tax advisers when the case calls for it.

To go further on Franco-Spanish taxation: the Spain-France Tax hub — tax residence, IRPF, double taxation, Modelo 720.