🇪🇸Spain: visas, Beckham Law and taxes — cluster map

Spain attracts one of the largest flows of private relocations in Europe while operating one of the heaviest general tax regimes on the continent: IRPF progression of around 47% at the top, a wealth tax, a solidarity tax and foreign-asset reporting all switch on automatically at the moment of tax residency. Set against that stand the Beckham regime with a flat 24% for six years and fast migration routes. The planning order follows: the tax scenario is calculated first, and the visa, insurance, school and bank are assembled after it.

Concept

The Spanish decision is always a fork. The same relocation produces three different outcomes: a resident under the Beckham regime pays 24% on employment income and almost nothing on foreign capital; a resident under the general regime hands over up to half of worldwide income plus the patrimonial taxes; a non-resident with Spanish property pays only targeted taxes on in-country assets. Which of the three scenarios applies is determined by the facts of the calendar year and a correctly executed entry, so the order of steps matters more than speed: immigration status and tax status run on different rules and are designed as a pair.

Tax residency: three tests

Article 9 LIRPF offers three independent routes into residency. First, 183 days in a calendar year — sporadic absences count towards the Spanish tally until tax residency in another country is evidenced by a certificate. Second, the centre of economic interests: contracts, a business, principal assets and cash flows in Spain create residency even on a lower day count. Third, the family presumption: where a spouse (absent a divorce) and minor children habitually live in Spain, the other spouse's residency is presumed, and rebutting the presumption is that spouse's burden. The mechanics of the tests and the evidence are covered in the guide to Spanish tax residency.

The family presumption is the principal trap of partial relocations: the family settles in "for the children's school year", the breadwinner keeps working from Dubai or London, and a year or two later an AEAT request arrives covering worldwide income. The second recurring conflict is the year of the move: the Spanish tax year equals the calendar year and does not split, so moving in the first half of the year all but guarantees residency for that entire year. Treaty tie-breakers work, but only where residency on the other side is real and documented.

The Beckham regime: six years at a flat rate

Article 93 LIRPF lets a new resident spend six tax periods paying under IRNR rules: 24% on employment and qualifying entrepreneurial income up to €600,000 a year, 47% above, with all worldwide employment income deemed obtained in Spain. Spanish-source savings income runs on the 19–30% scale, foreign dividends, interest and capital gains stay outside the Spanish base; wealth tax and solidarity tax attach only to Spanish assets, and under DGT criteria no Modelo 720 obligation arises for the years of the regime. The full mechanics, case practice and pitfalls are in the Beckham Law guide.

Entry is narrow. Spanish residency in the previous five years disqualifies, and a ground from a closed list is required: an employment relationship, including international telework — digital nomad visa holders qualify precisely here — a directorship, qualifying entrepreneurial activity, or work as a highly qualified professional for a startup or in R&D; the list was widened by the Startups Law, Ley 28/2022. Autónomo registration by itself creates no ground, and professional athletes are expressly excluded. The regime also extends to the family: the spouse and children under 25 join with the main applicant. The option is exercised through Modelo 149 within six months of social security registration, and the annual return is filed on Modelo 151.

The six-year horizon ends for everyone: from year seven the general regime applies — worldwide IRPF, the full wealth tax, Modelo 720 — together with the Spanish CFC rules. Both horizons have to be modelled at once; timing, the exit cost and the scenarios (leave, stay, restructure) are covered in exiting the Beckham regime.

Taxes on capital: IP, ITSGF and Modelo 720

The state framework of the wealth tax (IP): a €700,000 allowance plus €300,000 for the primary residence, then a progressive scale; the regions may alter minimums, scales and rebates, so the actual burden is set by the autonomous community. The position of the three key regions for 2026 looks like this:

Madrid and Andalusia fixed the variable rebates in regional statutes (Madrid, Andalusia), while the Balearics took a third route and raised their own IP allowance to €3 million. The solidarity tax (ITSGF) was introduced by Ley 38/2022 as temporary, and Real Decreto-ley 8/2023 extended it indefinitely — until "the revision of patrimonial taxation"; the Constitutional Court upheld the tax back in 2023.

The threshold is €3 million of net assets with a general €700,000 allowance, the scale runs 1.7% up to €5.35m, 2.1% up to €10.7m and 3.5% above; the return is Modelo 718, filed in July. A 2026 detail: following the TEAC ruling of December 2025, the 60% combined IRPF+IP+ITSGF cap was extended to non-residents, with the form updated by Orden HAC/652/2026. Regional calculations are in the Spanish wealth tax guide.

Foreign-asset reporting remains mandatory for residents under the general regime: accounts, securities and real estate are declared in three categories once €50,000 is exceeded. The former penalty block — fines up to 150% and attribution without a limitation period — was held incompatible with the free movement of capital by the CJEU in C-788/19 of 27 January 2022, Ley 5/2022 removed it from the statute, and late filing is now penalised under the general Articles 198–199 LGT: hundreds of euros instead of confiscatory percentages. The obligation itself survives, and the AEAT matches the returns against automatic exchange data; thresholds and practice are in the Modelo 720 guide.

Migration routes in 2026

The main entry is the international remote worker permit (Ley 14/2013 as amended by the Startups Law): filing from inside the country through the UGE gives a card for up to three years at once, while the consular route gives a visa for up to one year. The income threshold is tied to the SMI: in 2026 it is 200% of SMI, from €2,849 per month for the main applicant, with family supplements; the contract, track-record and insurance requirements are in the digital nomad visa guide. A DNV holder usually pairs the visa with the Beckham regime: the "international telework" ground covers exactly this case.

The golden visa is closed: from 3 April 2025, Articles 63–67 of Ley 14/2013 were left without content (Ley Orgánica 1/2025). Applications filed before that date are processed under the former rules, and issued cards remain valid and are renewed under the transitional provisions, but there have been no new investor applications for a second year, and investor demand has moved to other European routes. The tax side of the old investor cards is separate — golden visa and tax residency.

One purely Spanish formality: where entry into Schengen ran through another country and the passport carries no Spanish stamp, the entry date is fixed by the declaración de entrada — in person, within three working days (Art. 13 of Real Decreto 1155/2024); without it, a dispute over the date surfaces at the TIE application, as covered in the entry declaration guide.

The fallback route is the student one: estancia por estudios under the RD 1155/2024 regulation, in force since May 2025, carries the right to work up to 30 hours a week and to switch into residence without leaving the country; it serves those short of the track record or income for the DNV — mechanics in the student route guide.

Real estate: purchase, holding, exit

A resale purchase attracts the regional ITP — from 6% in Madrid and 7% in Andalusia to a progressive 10–13% in Catalonia (Decret llei 5/2025, in force since 27.06.2025; 20% for large holders and for whole residential buildings); in Valencia the rate fell to 9% on 01.06.2026, with 11% above €1m and AJD at 1.4% (Ley 5/2025); a new build carries 10% IVA plus stamp duty (AJD). The transaction requires an NIE; a non-resident mortgage is realistic at an LTV of around 60–70% with a readable income file — bank terms are compared in the non-resident mortgage guide, the step-by-step mechanics are in buying property in Spain, and the bank's review rests on a documented source of funds.

Holding and exit are taxed as well. A non-resident owner declares imputed income annually — 1.1% or 2% of cadastral value — at 19% for EU/EEA residents and 24% for the rest (Modelo 210), plus the municipal IBI. On a sale, the buyer withholds 3% of the price against the non-resident seller's tax, with the final settlement based on the actual gain.

The much-discussed "100% tax" on non-EU buyers has remained a headline: the prime minister announced the measure on 13 January 2025, the bill on a state surcharge on the ITP base was registered in May 2025, and by August 2026 it had passed no vote and was left out of the January 2026 housing package; new builds under IVA were outside its reach in any event. Purchases by third-country non-residents proceed under the ordinary rules.

Succession and family

Two bodies of rules meet in Spanish succession: civil law with its forced share (legítima) and the foral regimes of the autonomous communities — and the ISD, which every community discounts in its own way.

For Groups I–II (spouse, children, parents) the tax is effectively reduced to nil in Madrid, Andalusia, Murcia, La Rioja and Castilla y León (a 99% rebate), in the Balearics and Cantabria (100%), in the Canaries (99.9%), and in Valencia and Extremadura (99%). Galicia works differently: a €1,000,000 base reduction per heir for Groups I–II against a regional 5–18% scale, with the 99% quota deduction available only to Group I — descendants under 21 (Decreto Legislativo 1/2011 as amended by Article 60 of Ley 7/2022).

Asturias, where the deduction is capped at €300,000 per heir, and Catalonia, with curtailed rebates, remain expensive. The connecting factor is the deceased's region of residence over the last five years, and after the CJEU case law non-residents may apply the regional rules.

Intestacy is covered in the guide to intestate succession; a will over Spanish assets is drawn up together with the purchase, where useful electing the law of nationality under EU Regulation 650/2012. The matrimonial regime is regional too: community of acquisitions (gananciales) applies by default, while Catalonia and the Balearics run separation of property; for a couple with assets in several countries this choice pre-determines both the split on divorce and the estate.

Athletes and content creators

For professional athletes the Beckham regime is closed twice over. First, the Ley 26/2009 amendment restricted entry for relocations from 2010 with a €600,000 remuneration cap; then Ley 26/2014, effective 1 January 2015, excluded the category itself from Article 93 — the "relación laboral especial" of professional athletes under Real Decreto 1006/1985. The exclusion survived the Startups Law and stands in 2026, while €600,000 now works only as the boundary between the 24% and 47% rates for the remaining categories. A La Liga footballer pays IRPF on the general progression from year one; the remaining field is income structuring, covered in the Spanish athletes profile.

The second topic is image rights. The classic structure, where the club pays the athlete a salary and separately pays his company for use of the image, runs into Article 92 LIRPF: the payment to a third party is attributed to the athlete personally. The single pass-through is the 85/15 rule of Article 92.2: no attribution arises while employment income holds at least 85% of the "salary + image" package, meaning at most 15% can be routed to the image company.

On top sit the operaciones vinculadas rules: the assignment price must be at arm's length, or the adjustment arrives through transfer pricing; the international practice of such structures is in the image rights guide. For performers and streamers the logic is identical: a fee for a performance in Spain is taxed at source regardless of residency, and the remaining revenue follows the tax domicile.

Daily life: insurance, school, bank

The migration file needs a policy from an insurer on the DGSFP register, equivalent to state healthcare, in the sin copagos / sin carencias format — tourist policies and reimbursement schemes are screened out, and in 2026 the UGE objects even to symbolic co-payments. The working options are ASISA and DKV; the choice is made on the clinic network of the city of actual residence. School is booked before the visa: places in strong international schools go six months to a year ahead through waiting lists. A resident account at CaixaBank opens after the NIE/TIE and a local address; remote HolaBank onboarding is unavailable to citizens of Russia and Belarus, and the source of funds must be readable from documents.

Path to citizenship

Naturalisation requires ten years of residency and shortens the term to two for nationals of Ibero-American countries, Andorra, the Philippines, Equatorial Guinea and Portugal; the Sephardic route (Ley 12/2015) has been closed to new applications since 1 October 2019. Almost the entire term requires actually living in the country — around 183 days a year, which after the end of the Beckham regime means the general tax regime for all the years of waiting for the passport. The intermediate step is permanent residence after five years. For Ibero-American passports Spain remains one of the short routes to EU citizenship; for everyone else the horizon is long, and its tax price is calculated in advance.

Typical combinations

• A remote employee of a foreign company. DNV through the UGE, the Modelo 149 option within the first six months, six years at 24% without Modelo 720; by year five the exit decision is made — while there is still time to prepare asset sales or a change of residency.
• A family with capital. A home purchase in Madrid or Andalusia (low ITP, variable IP rebate), a will electing the applicable law under Regulation 650/2012, and an ISD calculation by region — before the deal, since the deceased's region of residence will set the heirs' tax.
• A rentier or pensioner. No Beckham ground exists, so the general regime applies from year one: IRPF on passive income, the region's IP and the ISD are calculated first, and Spain is then compared with the neighbouring jurisdictions.
• An athlete or creator. The Beckham regime is closed or risky; the work happens in income structuring (the 85/15 rule), the source of payments and a provable transfer of the centre of interests.

Risks

Spanish risks concentrate in four points — and all four are managed before relocation, with documents and timing.