Spain's Beckham Law for Americans: The 24 Percent Regime Explained

Spain’s Beckham law is the nickname of article 93 of the personal income tax law, a special regime for people who become tax residents by moving to Spain. You pay under non-resident rules: 24 percent on employment income up to 600,000 euros, and tax only on income obtained in Spain beyond the salary, for the year you become resident and the 5 years after. The current text, shaped by Law 28/2022 and Law 7/2024, covers remote employees, company directors, founders and highly qualified startup staff as well as ordinary hires. This article is for informational purposes only and is not immigration, tax or legal advice; verify current requirements with the relevant Spanish authority or a licensed professional.

What makes Americans lose the Beckham regime?

Article 93 of the income tax law is an option, and its regulation, Royal Decree 439/2007, sets the terms. Six points cost people the regime or much of its value.

• The 6-month clock. You opt on Modelo 149 within 6 months of the start date on your Spanish Social Security registration (the alta), or on the document that keeps you under your home country’s Social Security. The regulation calls it a maximum period, and no page read for this guide describes a late option.
• A Spanish tax residence in the last 5 years. Residence in any one of the 5 prior tax periods rules you out.
• A director’s stake in a holding company. A director of an ordinary company qualifies whatever the shareholding. In an entidad patrimonial, a holding or asset company, the stake must stay below the related-entity line, which the Agencia Tributaria, Spain’s tax agency, reads as under 25 percent.
• Income through a permanent establishment. Income that would count as earned through a permanent establishment in Spain excludes you, except on the entrepreneur and highly qualified routes. The regulation adds that your only business activities under the regime may be the entrepreneurial activity, services to startups, or training, research, development and innovation; the Agencia Tributaria’s manual applies that limit to activities through a permanent establishment. Clear any side freelancing with an adviser first.
• Family arriving too late. A spouse or child must move before your first regime year ends.
• Treaty residence. The Agencia Tributaria’s manual for non-residents says regime taxpayers are not residents for double tax treaty purposes, since they are taxed only on Spanish-source income. If your plan relies on the U.S.-Spain treaty, raise it with an adviser before you opt.

From job offer to your first Modelo 151

Order HFP/1338/2023 approved the current Modelo 149 and Modelo 151, replacing the 2015 versions.

1. Before you accept. Check that the move falls in your first regime year or the year before, and that you were not a Spanish tax resident in the 5 tax periods before it. The law counts them back from the year of the move and the Agencia Tributaria’s manual from the year you acquire residence, so clear both windows. The lookback was 10 years until January 1, 2023.
2. Before you move. Founders need a favorable report on the business from ENISA, the state innovation company, and the entrepreneur residence permit of Law 14/2013 before the move. Holding the highly qualified permit before the move counts as proof of that status, and holding the research permit before the move counts as proof of research work. See the entrepreneur visa guide and the highly qualified professional guide.
3. Your first day of work. The start date on your Social Security registration opens the 6-month window.
4. Your tax number. Modelo 149 needs a Spanish tax ID (NIF) and registration in the tax census. You first upload the documents in a separate procedure, whose registry number goes on the form.
5. Modelo 149. File it online within the 6 months, before any family member files.
6. Within 10 business days. If the option is in order, the Agencia Tributaria issues a document proving it. Hand a copy to your employer so it withholds at the regime rate.
7. Family members. Each files within 6 months of entering Spain, or by your deadline if that is later.
8. Your first return. Modelo 151 replaces the ordinary return and is filed online in the ordinary campaign: for 2025, from April 8 to June 30, 2026.
9. Every November and December. The only window to renounce for the following year.
10. The last year. The fifth tax period after the year you became resident.

The year you become resident is the first calendar year, counting the year of the move, in which you spend more than 183 days in Spain. Arrive on September 1, 2026, and that year holds fewer than 183 days, so your regime runs from 2027 to 2032.

Four routes into the regime

Article 93 accepts a move caused by one of four circumstances; the first three rows below are all the employment route. Every file also carries proof of your Social Security registration and any residence permit.

Employees with the international telework visa are named in the law as meeting the employment condition; the visa is explained in the digital nomad visa guide. Freelancing for ordinary clients fits none of the four routes; only startup or research work opens the highly qualified one. The current article sets no ceiling on pay: 600,000 euros is where the rate changes, not a limit on who qualifies.

What Spain taxes, and at what rates

You remain an income tax (IRPF) taxpayer, but the tax follows the non-resident rules for income earned without a permanent establishment. Spain taxes only income obtained in Spain, added up over the calendar year with no offsetting between items. The exception: all your employment income during the regime counts as obtained in Spain, wherever you do the work, and so does income from a qualifying entrepreneurial activity.

Law 7/2024 set the top savings rate at 30 percent from January 1, 2025, and the consolidated article 93 shows 30. The Agencia Tributaria’s 2025 income tax manual prints 28 percent for that bracket in 2025. The law prevails: plan on 30 percent.

Your employer withholds 24 percent, and 47 percent on pay above 600,000 euros from the same payer in a calendar year. The pages read here do not cover withholding by a foreign employer with no Spanish payroll; settle it before the first payday. Foreign tax on employment income earned outside Spain can be deducted, capped at 30 percent of the part of the Spanish gross tax that corresponds to that income.

Since a unification ruling of the TEAC, the central tax appeals board, on July 17, 2025, the Agencia Tributaria requires regime taxpayers to declare imputed rent on urban property in Spain, even their main home. Which dividends, interest and gains count as obtained in Spain follows the non-resident rules, which the pages read here do not detail: take a U.S. portfolio to an adviser, and see the U.S. brokerage account guide.

Bringing your spouse and children

Since January 1, 2023, your spouse, your children under 25 or of any age if disabled, and, if you are not married, the children’s other parent can opt too. The law says each must move with you or later, before your first regime year ends; the regulation also accepts an earlier move if they do not become resident before your first regime year. Each must become a Spanish tax resident and meet the five-year and permanent establishment conditions. Their combined taxable bases must stay below yours every year.

Each files a separate Modelo 149 after yours, and their regime ends with yours. A divorce or annulment does not by itself break the conditions, the regulation says.

Renouncing, exclusion and a change of job

Renouncing. Only in November and December, with effect from the following January, on Modelo 149; an employee first gives the employer the withholding data form. Whoever renounces can never opt again.

Exclusion. Breaking a condition excludes you from the tax period of the breach. You report it on Modelo 149 within 1 month, and cannot opt again.

End of the assignment. If the work that brought you to Spain ends without you losing Spanish tax residence that year, you report it on Modelo 149 within 1 month.

A new job. The Agencia Tributaria’s manual says that losing the job that brought you, for reasons beyond your control, then starting a new job that meets article 93, does not exclude you. Hiring rules are in the Spanish employment contract guide.

What the regime changes for an American’s filings

Modelo 720. The Agencia Tributaria’s Modelo 720 questions and answers, updated September 8, 2026, answer no for a regime taxpayer and, in the same question, for the spouse and children, then explain that the regime does not extend to other family members, who may have to file as Spanish tax residents. That wording predates the 2023 reform that let the family opt. Plan on this: the main taxpayer files no Modelo 720; a family member who has not opted may have to.

Wealth tax. You pay it only on assets in Spain, and may choose your region’s rules. The Agencia Tributaria’s page on the regime gives no exempt amount.

Residence certificate. The regulation lets you request the Spanish tax residence certificate of Order HAC/3626/2003. A treaty certificate is issued only in cases the Finance Minister sets, on reciprocity, and no official page found for this guide lists them. Do not plan on proving treaty residence while the regime applies.

The U.S. return. The IRS page for U.S. citizens abroad says you are taxed on worldwide income wherever you live, and that the foreign earned income exclusion and foreign tax credit come only by filing a return, with an automatic extension to file until June 15 for those living abroad; interest still runs on tax unpaid after April 15. The pages read here do not say how a U.S. credit treats tax paid under the regime. For missed years, see the streamlined procedure guide.

Check your five years before you sign, then count six months

Before you accept an offer, list your years in Spain and confirm that none of the 5 tax periods before the year of your move, or before your first regime year, was one of Spanish tax residence. On your first day of work, note the start date on your Social Security registration, put the date 6 months later in your calendar, and finish the NIF and the document upload well before it.

An employee of a Spanish employer, with no past residence in Spain and a family moving at the same time, can usually file Modelo 149 alone. Get a tax adviser first if you are a director of a holding company, a founder, a startup or research hire, a remote worker without Spanish payroll, or relying on the U.S.-Spain treaty, and have the U.S. return prepared by someone who files in both countries.

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