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The Beckham Law in 2026: Spain's Special Tax Regime for Relocators Buying in Marbella
The Beckham Law lets qualifying relocators pay a flat 24% on Spanish income up to EUR 600,000 for six years, keeping foreign earnings exempt. The 2026 position.
Photo by Michal Balog on Unsplash
The Beckham Law in 2026: Spain’s Special Tax Regime for Relocators Buying in Marbella
A flat 24% tax rate for high earners moving to Spain, with foreign income kept outside the Spanish tax net for six years.
The Beckham Law (formally the Regimen Especial para Trabajadores Desplazados) allows qualifying individuals moving to Spain to pay a flat 24% tax on Spanish employment income up to EUR 600,000 for six years, while keeping foreign income exempt from Spanish taxation. The regime, codified at Article 93 of the Ley del IRPF, was expanded by Ley 28/2022 (the Startup Law) with effect from 1 January 2023 and remains live in 2026, according to the Agencia Tributaria’s guidance page (updated 1 July 2026).
How does the Beckham Law work in 2026?
The Beckham Law allows new residents to be taxed as non-residents for a fixed period. Instead of the standard progressive Spanish income tax (IRPF), which can reach 47%, eligible taxpayers pay a flat 24% on their Spanish-sourced employment or professional income. This regime lasts for the year of relocation and the five subsequent tax years, giving six tax periods in total. The taxpayer keeps IRPF taxpayer status but pays through the IRNR (non-resident income tax) mechanism, filing annually on Modelo 151 rather than the standard Modelo 100.
Who is eligible for the special tax regime?
Eligibility was broadened significantly by Ley 28/2022. To qualify, you must not have been a tax resident in Spain for the five tax years immediately preceding your move. (Before 1 January 2023 the threshold was ten years; the reform halved it.) The move must be triggered by a professional displacement, and the current qualifying routes are:
- Employment contracts: Being hired by a Spanish company or transferred by a foreign employer. Remote workers holding the international telework visa under Ley 14/2013 now also qualify, which is the route most digital nomads use.
- Entrepreneurship: Starting an “innovative” business activity classified as an actividad emprendedora under Article 70 of Ley 14/2013.
- Company administration: Becoming a director or administrator of a Spanish entity, provided it is not a patrimonial entity in which you hold a linking interest.
- Highly qualified professionals: Providing services to emerging companies (as defined in Article 3 of Ley 28/2022) or carrying out training, research, development and innovation, provided this represents more than 40% of your total professional, business and employment income.
A notable 2023 addition is that the spouse and children (under 25, or any age if disabled) of the principal qualifying taxpayer may also opt into the regime, provided they move to Spain within the principal’s first tax period and their combined taxable base stays below the principal’s. This family extension was not available under the pre-2023 rules.
What are the tax savings for a high-earner in Marbella?
For a professional earning EUR 200,000 per year, the difference is substantial. Under the standard regime, a significant portion of that income would be taxed at 45% or 47%. Under the Beckham Law, the entire amount (up to the EUR 600,000 cap) is taxed at 24%.
Tax comparison example: EUR 200,000 annual income
| Tax component | Standard regime (approx.) | Beckham Law regime |
|---|---|---|
| Tax rate | Progressive (up to 47%) | Flat 24% |
| Taxable base | Global income | Spanish sourced only |
| Estimated tax | ~EUR 75,000 to 85,000 | EUR 48,000 |
| Annual saving | - | ~EUR 27,000 to 37,000 |
The saving compounds for property owners who also hold foreign rental portfolios or investment income, because that foreign income sits outside the Spanish tax base entirely during the six-year window.
What happens to income above EUR 600,000?
The 24% flat rate is capped. Any Spanish employment income exceeding EUR 600,000 in a single tax year is taxed at the standard progressive rates, which peak at 47% for the year of devengo 2021 and onwards, per the Agencia Tributaria’s retention table. This ensures the regime targets high-value talent rather than acting as a total tax shield for ultra-high earners. The same 47% marginal rate applies to the excess whether the taxpayer is a standard resident or a Beckham Law elector; the flat rate is the benefit, not a different top band.
How is foreign income treated under this regime?
This is the most significant advantage for high-net-worth individuals. Under the Beckham Law, you are only taxed on income obtained within Spain. Your global dividends, rental income from properties in the UK or US, and capital gains from foreign assets are generally not subject to Spanish income tax during the six-year window. This is the structural difference between the Beckham Law and standard IRPF residency: a standard resident pays Spanish tax on worldwide income, while a Beckham Law elector pays only on Spanish-sourced income.
There is one subtlety for remote workers and entrepreneurs. All employment and entrepreneurial-activity income earned during the regime is treated as Spanish-sourced, even if the work is physically done abroad, so a double-taxation deduction is available to prevent being taxed twice on the same income. Income from activities carried out before the relocation date or after the end of the displacement (as communicated via Modelo 149) is not treated as Spanish-sourced.
How does the Beckham Law interact with Spanish wealth tax?
Taxpayers under the Beckham Law are subject to Spanish wealth tax (Impuesto sobre el Patrimonio) only under obligacion real, meaning they pay wealth tax only on assets physically located in Spain. Foreign assets, including overseas property, foreign investment accounts and international shareholdings, fall outside the Spanish wealth tax base during the regime. For a property owner relocating to Marbella, this means the Spanish home is within scope but a UK buy-to-let portfolio or a US brokerage account is not. The Agencia Tributaria confirms this obligacion real treatment explicitly.
How do you apply for the Beckham Law?
Application is not automatic. You must proactively notify the Spanish Tax Agency (Agencia Tributaria) using Modelo 149, which was redesigned by Orden HFP/1338/2023 (in force from 16 December 2023).
The critical deadline is six months. You must file Modelo 149 within the later of six months from your entry into Spain or six months from the start of your qualifying activity, as recorded in your Social Security registration or equivalent documentation. Missing this window typically results in an irrevocable loss of eligibility for that relocation event. The Agencia Tributaria issues a resolution within 10 working days, and the annual return is then filed on Modelo 151 rather than the standard Modelo 100.
Each qualifying family member must file their own individual Modelo 149, and must communicate the end of the displacement within one month of it occurring.
Interaction with other Spanish residency routes
The Beckham Law is a tax regime, not a residency visa. It is frequently used in conjunction with:
- Digital Nomad Visas: Remote workers qualifying for the international telework visa under Ley 14/2013 can apply for the Beckham Law if they meet the displacement criteria. This pairing is now one of the most common routes for relocating professionals, and the Ley 28/2022 reform explicitly cross-references the telework visa as a qualifying entry route.
- Non-Lucrative Visas: NLV holders who later start a qualifying activity can apply, provided they were not Spanish tax residents in the preceding five years.
- Golden Visa (legacy): The Golden Visa was terminated on 3 April 2025 by Ley Organica 1/2025. Those who already hold residency through that route may still apply for the Beckham Law if they move their tax residency to Spain and meet the professional requirements, but the route is closed to new applicants.
For those planning a move, it is essential to coordinate the timing of the Social Security registration and the Modelo 149 filing to avoid the six-month trap. The 183-day tax residency rule determines when you become a Spanish tax resident in the first place, and the non-resident income tax (IRNR) regime is the mechanism the Beckham Law uses to calculate your liability. Property owners should also read the Spanish property tax calendar and the wealth tax for non-residents guide to understand the full holding-cost picture.
This guide is general information, not legal or tax advice. Rules change and individual circumstances differ. Verify current requirements with an independent lawyer (abogado) or tax advisor (gestor/asesor fiscal) before acting.
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Frequently asked questions
- Who is eligible for the Beckham Law in 2026?
- Individuals who move their tax residence to Spain and have not been tax residents for the previous five tax years. You must be moving for a job contract, as a company administrator, to start an entrepreneurial activity, as a highly qualified professional serving emerging companies, or as a remote worker on the international telework visa. Spouses and children under 25 (or any age if disabled) may also apply.
- What happens to income above EUR 600,000?
- The flat 24% rate only applies to the first EUR 600,000 of Spanish employment income. Any amount exceeding this threshold is taxed at the standard progressive Spanish rates, which peak at 47% for the year of devengo 2021 and onwards.
- Does the Beckham Law cover rental income from properties in the UK or US?
- Yes. One of the primary advantages is that under this regime, you are taxed only on income sourced in Spain. Foreign rental income, dividends, and capital gains from outside Spain are generally not taxable in Spain during the six-year window.
- What is the deadline to apply for the special tax regime?
- You must submit Modelo 149 to the Agencia Tributaria within six months. The deadline is the later of six months from your entry into Spain or six months from the start of your qualifying activity, as recorded in your Social Security registration or equivalent documentation. Missing this window is irrevocable.
- How does the Beckham Law interact with Spanish wealth tax?
- Taxpayers under the Beckham Law are subject to wealth tax (Impuesto sobre el Patrimonio) only under obligacion real, meaning they pay only on assets located in Spain. Foreign assets are outside the scope of Spanish wealth tax during the regime, which matters for property owners holding overseas investments.
Sources and data
- Regimen especial impatriados art. 93 Ley IRPF · Agencia Tributaria
- Form 149: Special regime applicable to workers, professionals, entrepreneurs and investors · Agencia Tributaria
- Ley 28/2022, de 21 de diciembre, de fomento del ecosistema de las empresas emergentes (Ley de Startups) · BOE
- Orden HFP/1338/2023, de 13 de diciembre, por la que se aprueban los modelos 151 y 149 · BOE