1. Background: What Is the Beckham Law?

Introduced in 2005 to attract foreign professional athletes, the Beckham Law (formally the Tax Regime for Foreign Workers Dispatched to Spain) has evolved into a broad incentive for international talent. It allows eligible workers who transfer their tax residence to Spain to be taxed as non-residents, at a flat rate of 24% on income up to €600,000 (47% above that threshold), rather than under the standard progressive IRPF scale — which can reach 47%. The regime applies for six years: the year of arrival plus five subsequent years.

Key qualifying conditions (prior to 2023 reforms):

• Transfer of tax residence to Spain.
• No tax residency in Spain in the preceding 10 years (now reduced to 5).
• Income derived from an employment contract with a Spanish entity.

2. Key Changes Introduced by the 2023 Start-ups Act

Expanded scope of eligible persons

The reform significantly widened the range of profiles that can access the regime beyond salaried employees:

• Digital nomads – remote workers employed by a foreign company who carry out their activities exclusively through digital means.
• Entrepreneurs – individuals establishing a business in Spain within the start-up ecosystem.
• Highly qualified professionals providing services to start-ups or conducting R&D activities, provided this income represents more than 40% of their total income.

Extension to family members

Spouses and children under 25 (or with disabilities) who relocate to Spain alongside the primary beneficiary may now also benefit from the regime, provided they have not been Spanish tax residents in the past five years.

Reduced prior residency exclusion period

The waiting period — during which applicants must not have been tax residents in Spain — was halved from 10 to 5 years, making the regime accessible to a broader pool of returning and first-time expatriates.

Administrative simplification

Procedures for company formation and international hiring have been streamlined. Work permit and visa processing for entrepreneurs and skilled workers is faster, and access to the Beckham Law benefits has been simplified. Beneficiaries are also exempt from filing Form 720 (declaration of foreign assets).

3. Summary of Tax Benefits

• Flat 24% IRNR rate on Spanish-source income up to €600,000 (vs. up to 47% under the standard resident scale).
• Foreign-source income (excluding employment income) is generally exempt from Spanish taxation.
• Capital gains and passive income (dividends, interest) generated abroad are exempt; Spanish-source gains are taxed at 21–28%.
• Wealth tax applies only to assets located in Spain, and only above €1 million.
• Duration: 6 years (year of arrival + 5 subsequent years).

4. Impact on Spain’s Start-up & Innovation Ecosystem

The updated regime strengthens Spain’s position as a European hub for international talent and venture capital. By welcoming digital nomads, start-up founders and key innovation profiles under a single, simplified framework, Spain now competes more effectively with the Netherlands, Portugal and other talent-friendly jurisdictions. Additional incentives for green and social-impact start-ups further enhance the appeal for sustainability-focused professionals and investors.

Alex Martinez Comín – Managing Partner

Martinez Comín - Spain