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

Article 93 of Spain’s personal income tax law is the regime everyone calls the Beckham law, built for people who become tax residents by moving to Spain. It is the state regime; the Basque territories run their own, such as Gipuzkoa’s, which this guide skips. The upside: you are taxed under non-resident rules, at 24 percent on employment income up to 600,000 euros and only on income obtained in Spain beyond the salary, for the year you become resident and the 5 years after. 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?

The regime is worth real money, and it is surprisingly easy to lose. Article 93 of the income tax law is an option you have to claim, and its regulation, Royal Decree 439/2007, sets the terms; Law 28/2022 and Law 7/2024 shaped the current text. These six points are where people lose it, or lose most of what it is worth.

• The 6-month clock. The option goes on Modelo 149, filed within 6 months of the start date on your Spanish Social Security registration (the alta), on the document that keeps you under your home country’s Social Security, or, if the alta is not mandatory, on the document that proves the start date of your activity. The regulation calls that a maximum period, and none of the pages read for this guide describes a late option.
• A Spanish tax residence in the last 5 years. A single year of Spanish tax residence in any of the 5 prior tax periods shuts the door.
• A director’s stake in a holding company. Directors of an ordinary company qualify at any shareholding. The catch is the entidad patrimonial, a holding or asset company: there your stake has to sit 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 disqualifies you, unless you are on the entrepreneur or highly qualified route. The regulation also limits your business activities under the regime to the entrepreneurial activity, services to startups, or training, research, development and innovation, and the Agencia Tributaria’s manual applies that limit to activities through a permanent establishment. Any side freelancing is red tape worth clearing with an adviser first.
• Family arriving too late. A spouse or child who moves after your first regime year ends misses out.
• Treaty residence. According to the Agencia Tributaria’s manual for non-residents, regime taxpayers are not residents for double tax treaty purposes, because Spain taxes them only on Spanish-source income. If your plan leans on the U.S.-Spain treaty, take that to an adviser before you opt.

From job offer to your first Modelo 151

The steps run in this order. The current Modelo 149 and Modelo 151 come from Order HFP/1338/2023, which retired the 2015 versions.

1. Before you accept. Confirm the move falls in your first regime year or the year before, and that none of the 5 tax periods before it was a year of Spanish tax residence. The law counts back from the year of the move, the Agencia Tributaria’s manual from the year you acquire residence, so make sure you clear both windows. Until January 1, 2023, the lookback was 10 years.
2. Before you move. Founders need two things in hand before the move: a favorable report on the business from ENISA, the state innovation company, and the entrepreneur residence permit of Law 14/2013. Likewise, a highly qualified permit held before the move proves that status, and a research permit held before the move proves research work. The details sit in the entrepreneur visa guide and the highly qualified professional guide.
3. Your first day of work. The 6-month window opens on the start date of your activity, usually the one printed on your Social Security registration. If no registration is mandatory, it is the date on the document proving the activity began.
4. Your tax number. Modelo 149 will not go through without a Spanish tax ID (NIF) and a place in the tax census. The documents get uploaded first in a separate procedure, and its registry number goes on the form.
5. Modelo 149. File online inside the 6 months, and before any family member files theirs. One trap to dodge: if you already used Modelo 147, the special withholding procedure for workers who move to Spain, article 116.3 of the IRPF regulation bars the option.
6. Within 10 business days. With the option in order, the Agencia Tributaria issues a document proving it. Your employer needs a copy to withhold at the regime rate.
7. Family members. Each has 6 months from entering Spain, or until your own deadline if that falls later.
8. Your first return. Modelo 151 takes the place of the ordinary return and is filed online during the ordinary campaign: for 2025, it ran from April 8 to June 30, 2026; each later year uses the dates set for the general income tax return.
9. Every November and December. Your one window each year to renounce for the next.
10. The last year. The regime ends with the fifth tax period after the year you became resident.

Your year of residence is the first calendar year, the year of the move included, in which you spend more than 183 days in Spain. Land on September 1, 2026, and that year falls short of 183 days, so the regime covers 2027 to 2032. Bottom line: the arrival date decides which six years you get.

Four routes into the regime

Pick the route that matches how you will actually earn your money, then gather what it asks for. Article 93 lets you in when the move comes from one of four circumstances, and the first three rows below all sit on the employment route. Whatever the route, the file also carries proof of your Social Security registration and of any residence permit.

The law names employees holding the international telework visa as meeting the employment condition; the digital nomad visa guide covers that visa. Ordinary client freelancing fits none of the four routes, and only startup or research work opens the highly qualified one. One more point in your favor: the current article sets no pay ceiling. At 600,000 euros the rate changes, and nobody is shut out for earning more.

What Spain taxes, and at what rates

Here is how it works: you stay an income tax (IRPF) taxpayer, but the bill is worked out under the non-resident rules for income earned without a permanent establishment. Spain taxes only income obtained in Spain, added together over the calendar year in two bases (dividends, interest and gains, and everything else), with no offsetting between them. The twist sits on the salary side. During the regime, all your employment income counts as obtained in Spain wherever you do the work, and the same goes for income from a qualifying entrepreneurial activity.

Law 7/2024 lifted the top savings rate to 30 percent from January 1, 2025, and the consolidated article 93 says 30. The Agencia Tributaria’s 2025 income tax manual still prints 28 percent for that bracket in 2025. The law wins, so budget at 30 percent.

On payroll, your employer withholds 24 percent, rising to 47 percent on pay above 600,000 euros from the same payer in a calendar year. The catch for remote staff: the pages read here say nothing about withholding by a foreign employer with no Spanish payroll, so get that sorted before the first payday. Foreign tax on employment income earned outside Spain is deductible, up to 30 percent of the share of Spanish gross tax that corresponds to that income.

There is also a newer cost. Since the TEAC, the central tax appeals board, issued a unification ruling on July 17, 2025, the Agencia Tributaria requires regime taxpayers to declare imputed rent on urban property in Spain, main home included. A Madrid appeals court (TSJ Madrid, judgment 665/2025 of September 17, 2025) is reported to have ruled the other way for a main home, so the point is contested. As for which dividends, interest and gains count as obtained in Spain, article 13 of the non-resident income tax law lists dividends of companies resident in Spain, interest and royalties paid by Spanish residents, and gains on securities issued by Spanish residents or tied to Spanish real estate. A binding ruling of October 2022, V2195-22, applied that list to shares of a UK company and held that the sale gain was not taxed in Spain under the regime. No ruling read covers a U.S. brokerage or retirement account, so take a U.S. portfolio to an adviser, and read the U.S. brokerage account guide.

Bringing your spouse and children

Your family can ride on the same deal, as long as the timing and the numbers line up. Since January 1, 2023, the option is open to your spouse, your children under 25 or of any age if disabled, and, if you are not married, the children’s other parent. Family tie, age and disability are judged on the day each person files the option. Under the law each must move with you or later, before your first regime year ends; the regulation also accepts an earlier move, provided 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.

One cap applies every single year: their combined taxable bases must stay below yours. Each files a separate Modelo 149 after yours, and their regime ends when yours does. According to the regulation, a divorce or annulment does not on its own break the conditions.

Renouncing, exclusion and a change of job

You can walk away from the regime, get pushed out of it, or change jobs and keep it, and each of those moves has its own filing.

Renouncing. The window is November and December only, effective the following January, on Modelo 149, and an employee first hands the employer the withholding data form. The cost is permanent: whoever renounces can never opt again.

Exclusion. Break a condition and you are out from the tax period of the breach. You report it on Modelo 149 within 1 month, and the option is gone for good.

End of the assignment. When the work that brought you to Spain ends and you keep Spanish tax residence that year, a Modelo 149 reporting it is due within 1 month. Pay for work done after the date you report is no longer treated as Spanish income under the regime, and neither is pay for work done before the move.

A new job. Per the Agencia Tributaria’s manual, losing the job that really brought you for reasons beyond your control, with only a temporary gap of unemployment or inactivity before a new job that meets article 93, does not exclude you. Hiring rules are covered in the Spanish employment contract guide.

What the regime changes for an American’s filings

The regime trims your Spanish reporting, but the IRS keeps its full claim on you.

Modelo 720. The Agencia Tributaria’s Modelo 720 questions and answers, updated in February 2025, say no for a regime taxpayer and, in the same answer, for the spouse and children, then add that the regime does not reach other family members, who may have to file as Spanish tax residents. That text predates the 2023 reform that opened the regime to family. The working assumption: the main taxpayer files no Modelo 720, while a family member who has not opted may have to.

Wealth tax. Only your assets in Spain are taxed, and you may pick your region’s rules. The Agencia Tributaria’s wealth tax manual says regime holders are taxed only on Spanish assets, as non-residents are, and that the 700,000 euro exempt amount applies to taxpayers in that position.

Residence certificate. Article 120 of the regulation still allows a request for the Spanish tax residence certificate of Order HAC/3626/2003, even though Order EHA/3316/2010 repealed that provision and now governs the certificate. A treaty certificate comes only in cases the Finance Minister sets, on reciprocity, and no official page found for this guide lists them. So do not build a plan on proving treaty residence while the regime applies.

The U.S. return. According to the IRS page for U.S. citizens abroad, you are taxed on worldwide income wherever you live, and the foreign earned income exclusion and foreign tax credit come only by filing a return. Americans living abroad get an automatic extension to file until June 15, though 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. Behind on past years? The streamlined procedure guide covers that.

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

Your to-do list here is short. Before accepting an offer, write down 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 a year of Spanish tax residence. On day one of the job, note the start date on your Social Security registration, put the date 6 months out in your calendar, and get the NIF and the document upload done well ahead of it.

The simple case: an employee of a Spanish employer, with no past residence in Spain and a family moving at the same time, can usually handle Modelo 149 alone. Bring in 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 counting on the U.S.-Spain treaty, and have the U.S. return done by someone who files in both countries.

The Spain Navigator puts every step of your move to Spain in order, from the visa to settling in.