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 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 2026 Digital Nomad Visa threshold connect to the Beckham Law?

The most common Beckham Law entry route for relocating professionals is the Digital Nomad Visa (DNV) under Ley 14/2013. The DNV income threshold is indexed to the Spanish minimum wage (SMI), which RD 126/2026 of 18 February set at EUR 1,221 per month in 14 payments for 2026, a 3.1% increase on the 2025 figure. The DNV requires 200% of the monthly SMI for the principal applicant, producing a 2026 threshold of EUR 2,442 per month, as confirmed by the Spanish Consulate in Houston.

DNV applicant category	% of monthly SMI	2026 monthly threshold
Principal applicant	200%	EUR 2,442
First family member	75%	EUR 916
Each additional family member	25%	EUR 305

A DNV holder who moves their tax residence to Spain and meets the five-year non-residence condition can elect the Beckham Law via Modelo 149, combining the visa’s residency right with the regime’s flat tax. The two are separate instruments: the DNV grants the right to live and work remotely in Spain, while the Beckham Law determines how that resident’s income is taxed.

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.

Does the Beckham Law reduce the appeal of holding property through an SL?

A practical consequence for relocators weighing ownership structures is that the Beckham Law narrows the tax gap that makes corporate ownership attractive. A standard Spanish resident pays progressive IRPF up to 47% on personal income, which is one reason buyers route property through a sociedad limitada (SL) to access the 25% corporate tax rate. A Beckham Law elector already pays 24% on employment income, so the SL’s corporate-rate advantage largely disappears for qualifying expats on earned income.

The calculation is not symmetric, because an SL holding property generates rental income taxed at 25% under corporate tax (Impuesto sobre Sociedades), while a Beckham Law elector’s foreign rental income is exempt and their Spanish rental income is taxed under IRNR at 19% (EU residents) or 24% (non-EU). The SL route still matters for liability isolation and succession planning, but the income-tax motivation weakens. The ownership structure comparison guide sets out the full per-structure calculus, and the company purchase guide covers the SL mechanics.

How will the EU AMLR affect corporate property holding from 2027?

From 10 July 2027, Regulation (EU) 2024/1624 (the AMLR) makes real estate operators intermediating the buying, selling and letting of immovable property obliged entities for anti-money-laundering purposes. The regulation also introduces a Union-wide cash payment limit of EUR 10,000 and requires obliged entities to verify beneficial ownership information against central registers.

For a Beckham Law elector holding a Marbella property through an SL, the practical effect is enhanced know-your-customer checks at the estate agent, notary and bank level. The SL’s beneficial owner must be identifiable in the Spanish central register (Registro de Titularidades Reales), and discrepancies between the register and the transaction documentation must be reported. The AMLR does not change the Beckham Law’s tax treatment, but it increases the compliance surface for corporate structures, which is a factor for relocators deciding between individual and corporate ownership before the 2027 deadline.

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 exit tax guide to understand what happens if they later leave Spain.