The questions that follow are the ones that come up most often in conversations with people weighing a move to Spain under the inbound-expatriates regime —the Beckham Law—. I have grouped them by topic. Each answer is deliberately brief; where a nuance warrants a longer treatment, I link to the technical analysis elsewhere in this Spanish Tax Journal.
1. Basic questions
What exactly is this regime?
A special tax regime designed for professionals moving to live in Spain as a consequence of a labour situation. While it lasts, you pay a flat 24% on what you earn working in Spain (up to EUR 600,000 per year; anything above that threshold goes to 47%) and you pay nothing in Spain on what you earn abroad —dividends, rents, interest, capital gains on your investment portfolio—. The logic of the regime is to attract international talent and, in particular, to ensure that Spanish taxation does not act as an obstacle for you to come.
Why is it called the “Beckham Law”?
The informal name comes from the footballer David Beckham, who was one of the first to apply when the regime was introduced in 2005, on signing for Real Madrid. The technical name is special tax regime applicable to workers, professionals, entrepreneurs and investors moved to Spanish territory. It is governed by article 93 of the Personal Income Tax Act.
For how long can I enjoy it?
Six years in total: the year you move to Spain and acquire tax residence and the five following years. It is not renewable. When it ends, you are taxed like any Spanish tax resident: on your worldwide income and under the general progressive scale of the LIRPF.
What taxes does it actually save me?
Three things, above all:
- Flat rate under the LIRPF: 24% on your employment income up to EUR 600,000 (above that amount, taxation is at 47%). The normal progressive LIRPF scale would apply 47% from around EUR 300,000.
- Foreign income outside the LIRPF: dividends, interest, rents and capital gains generated outside Spain do not enter your Spanish LIRPF tax base.
- Forms 720 and 721 not filed: the regime exempts you from the obligation to report your foreign assets and rights, which does apply to the common resident.
The Net Wealth Tax and the Temporary Solidarity Tax on Large Wealth continue to apply, but only by in rem obligation: that is, you are only taxed by reference to the value of your assets and rights located or exercisable in Spain.
Who decides whether I am entitled to apply the regime?
The Tax Agency, by Form 149, when you apply. But effective control comes later, in any eventual inspection. It is frequent for complex profiles to file consultations with the Directorate-General for Taxes (DGT) prior to the move to Spain in order to obtain a binding response and reduce uncertainty.
If I am self-employed, can I access the regime?
Not directly. The regime is designed for employees, company administrators and the specific cases of paragraphs 93.1.b).3 (entrepreneur with innovative activity and favourable report from ENISA or equivalent) and 93.1.b).4 (highly qualified professional providing services to start-ups, or training, research, development and innovation activity with employment remuneration > 40% of income).
The ordinary self-employed person who comes to Spain to carry out his or her individual professional activity —doctor, lawyer, architect, independent consultant— does not fit directly into the regime. The two indirect routes are: to incorporate an operating company and enter as its administrator (with evidenced causation and the asset-holding filter); or, if the activity is genuinely innovative, to obtain the ENISA report and enter as an entrepreneur.
Am I entitled to family, child or housing deductions under the regime?
No. Under the regime you are taxed under the rules of the Non-Resident Income Tax, not those of the common resident. The deductions of the general LIRPF tax base —personal and family minimum, deduction for investment in habitual residence, maternity deduction, etc.— do not apply. The rate is a flat 24% on the Spanish-source income base (47% in the tranche above EUR 600,000), with no reductions for personal or family circumstances.
This is the trade-off of the regime: you save a great deal on the rate (24% against the 47% marginal of the progressive scale of the common resident) but you lose the deduction system of the resident. For profiles with high employment income and family burden, the regime still comes out clearly favourable. For more moderate income profiles with a high family burden, the comparison tightens and it is worth calculating before electing.
2. Do I meet the requirement of not having lived here before?
How is “non-residence” measured in the previous five years?
You must not have been a Spanish tax resident during the five calendar years immediately preceding the year you move. The calculation is done year by year, not by rolling periods. If you move in 2026, the years examined are 2021, 2022, 2023, 2024 and 2025: you must have been a non-resident in each of the five.
I did a master’s in Madrid four years ago, does that block the regime?
It depends on whether in that year you were a tax resident or not. A twelve-month stay for a master’s with more than 183 days of presence in Spanish territory may have generated tax residence in that year, even if you did not declare it. Where there is reasonable doubt, an evidential file is prepared: municipal census registration in and out, lease agreement, dates of entry and exit, returns filed (or not) in the country of origin, tax-residence certificate of that country. If in that year you were clearly a tax resident of another country and can evidence it, the regime is not closed to you.
My family moved to Spain before me, does that affect me?
It is a delicate point. Article 9.1 of the LIRPF presumes, unless evidence to the contrary, that you are a Spanish tax resident where your non-legally-separated spouse and your minor children habitually reside here. The presumption is iuris tantum: you can rebut it, but the burden of proof is on you. If your family came before you for personal reasons (refuge, change of school for the children, supervening decision), it is necessary to document well that your centre of life —labour, social, economic— remained outside Spain during the years in which your family was already here. Typical case: the Ukrainian of DGT consultation V1209-25.
I am registered on the municipal census in Spain even though I have not lived here, does that count as residence?
Not directly. The municipal census registration is a municipal register; it does not by itself determine tax residence. But in an inspection it is an adverse indicator that the Administration will use together with others (ownership of dwelling, vehicles, bank accounts, consumption, health card, etc.). A well-built indicator chart can overcome it, but it makes the defence more expensive. If you are going to plan Beckham, it is advisable to review the municipal census registration in good time and, where applicable, to de-register.
I am a Spanish national who has lived abroad for ten years or more and is returning, can I apply?
Yes. The regime does not discriminate by nationality: the Spaniard returning to Spain after at least five years of non-residence may apply on equal terms with the foreigner. The 2022 reform (Law 28/2022) expressly recognised this route and confirmed it as a criterion. The profile of the “returning Spaniard” is increasingly common: executives who, after an international professional stage, return to Spain with the regime on the table.
[ÁLVARO: nuance missing here — add the operative nuance of the returning Spaniard: home owned in Spain from before, parents already resident, recovery of family roots, specific risk of the residence presumption under art. 9.1 LIRPF that affects them more than the "clean" foreigner, and how to build the non-residence evidential file for those cases]
3. For what reason do I have to come to Spain?
What reasons allow me to enter the regime?
Article 93.1.b) of the LIRPF recognises four triggering circumstances, any of which is sufficient:
- Employment contract with an employer in Spain, or move ordered by a foreign employer, or remote work from Spain through exclusive telematic means (with or without a Law 14/2013 visa).
- Acquisition of the status of administrator of an entity.
- Innovative entrepreneurial activity with a favourable report from ENISA or from the competent body.
- Highly qualified professional providing services to start-ups, or training / research / development / innovation activity with employment remuneration > 40% of income.
The first two are the most common. The latter two are niches with specific requirements.
I work remotely for a foreign company, does that work for the regime?
Yes. The 2022 reform expressly introduced international remote work as a triggering circumstance: it is enough that you perform the work activity remotely from Spain through computer, telematic and telecommunication means and systems, exclusively. The DGT has confirmed it in consultations V0476-26 (Swedish) and V1115-25 (British).
[ÁLVARO: nuance missing here — add what practical documentation sustains "work activity exclusively at a distance through telematic means" before an inspection (written contract, HR policy, A1 certificate, absence of Spanish office of the employer), and under what scenarios the Inspection re-characterises to a commercial relationship with loss of the regime]
Do I need the international remote-work visa of Law 14/2013?
It is not mandatory. The provision says “in particular” when referring to the visa, which means that it is a specific subsumption case —direct evidence that you meet the requirement— but not the only one. V0476-26 (Swede without Law 14/2013 visa) confirmed this: the regime is accessible even without the visa, provided you evidence the remote performance.
That said, the visa enormously simplifies the evidential stage. If you can obtain it, do so.
I come as administrator of a Spanish company, does that suit?
Yes, this is the route of article 93.1.b).2. There are two conditions:
- Causation between your move to Spain and the acquisition of the post. It is not enough that the appointment is much earlier than your move, or that it appears disconnected from it. The DGT has been clear in V1209-25 and V1622-24: causation is a question of fact and the Inspection will examine it.
- Asset-holding filter: if the administered company qualifies as an asset-holding entity under article 5.2 of the LIS, you cannot hold a participation —individual or aggregated with spouse, ascendants and descendants— that turns it into a related-party entity (25% threshold under article 18 of the LIS). If the company is operating, the participation is irrelevant.
[ÁLVARO: nuance missing here — add the critical case of the quasi-shareholder (>25%) in a FOREIGN company: via a Spanish subsidiary dependent with substance or as the group's cost centre, requirements for the subsidiary to qualify, case law/doctrine that supports this planning]
I come as trustee and general director of a Spanish foundation, does that also count?
Yes. The DGT confirmed it in consultation V2095-24, consolidating a doctrine that goes back to V3283-17. The post of trustee of a Spanish foundation is assimilated to “administrator” for the purposes of 93.1.b).2. If you also take on the post of general director with remuneration (authorised by the Board of Trustees and the Protectorate, in accordance with article 15.4 of Law 50/2002), that remuneration is characterised as employment income and is taxed at 24% under the regime.
Compatibility with foreign boards of directors: V2095-24 itself confirms that keeping them does not exclude the regime, provided they do not generate income characterisable as obtained through a permanent establishment in Spain.
[ÁLVARO: nuance missing here — add the operating substance that the foundation must evidence to avoid re-characterisation as an instrumental vehicle, and how to dimension the general director's remuneration without losing the foundational nature]
I come to set up my own company in Spain, do I qualify?
Two possible routes here:
- Via article 93.1.b).2: you come as administrator of the company you incorporate. The causation and asset-holding filter described above apply. It is the most-used route.
- Via article 93.1.b).3 (entrepreneurial activity): if your project has an innovative character and you obtain a favourable report from ENISA (or the equivalent body), you access as entrepreneur. It is a less travelled route but with fewer restrictions on the shareholding composition.
[ÁLVARO: nuance missing here — add a practical comparison between the two routes for the typical founder in your portfolio (when the ENISA report is worth pursuing, its timing, its cost, its rigidity vs the administrator route)]
I am administrator of a company, do I go to the general Social Security regime or to RETA as a “corporate self-employed”?
It depends on the participation percentage. The administrator with effective control of the company —typically, direct or indirect participation of 25% or more, or 50% in concurrence with relatives— is required to register with the Special Regime for Self-Employed Workers (RETA) as a “corporate self-employed”. Below those thresholds, he or she goes to the general regime. The choice is not free: it depends on the facts.
The RETA contribution is relevant for two reasons. The first, it is the basis on which the future Spanish pension is built. The second, under the Beckham regime the RETA contribution is borne without right to deduction from the LIRPF tax base (because you are taxed at a flat 24% without the reductions of the common resident). The total calculation —net income after LIRPF + RETA contribution, capitalised at the retirement horizon— is what decides whether it is preferable to elect the maximum or minimum contribution.
[ÁLVARO: nuance missing here — add what practical planning you have seen to optimise the RETA contribution of the administrator moved under Beckham (criteria to maximise or minimise the contribution base, coordination with the A1 of the country of origin where applicable, delaying retirement)]
4. Risks and critical zones
Does my foreign employer run the risk that the Tax Agency says it has a “permanent establishment” in Spain?
It is one of the most relevant risks and, paradoxically, one of the least covered by the FAQs in circulation. The DGT, in V0476-26 and V1115-25, ruled on your access to the Beckham regime but expressly excluded the question of the employer’s permanent establishment. That is: you can be inside the regime and, at the same time, your foreign employer can be generating a PE in Spain through your activity —especially if you hold an executive post with decision-making content—.
The Commentaries to the OECD Model Convention consider that the worker’s residence may qualify as the employer’s home office where the activity carried out there is habitual, functionally dependent on the business and not merely preparatory. If the Inspection concludes that there is a PE, the employer is subject to taxation in Spain on the income attributable, with all the associated formal and substantive obligations.
[ÁLVARO: nuance missing here — add mitigation measures you apply with clients (functional redesign of the post, limitation of presence in Spain, designation of local representatives, due diligence on the applicable tax treaty). And practical note: the tax cost of the employer's PE may neutralise or invert the aggregated economics of the move of the worker]
I have a significant participation in my company, can I still apply?
[ÁLVARO: initial draft uncertain after correction 12-may. Correct framing: distinguish 4 cases — (a) Spanish operating company with >25% participation: V1983-24 confirms access with no limit; (b) Spanish asset-holding company 5.2 LIS with >25%: blocks; (c) foreign company with >25%: does NOT qualify via art. 93.1.b).2 — requires incorporating a Spanish dependent subsidiary with operating substance or as the group's cost centre; (d) Spanish subsidiary recently incorporated: requirements of substance, operating justification, absence of simulation. Draft yourself, with your experience, case (c)+(d), which is where the STJ value shows]
My family are shareholders of the company, are the participations aggregated for the filter?
Yes, where the company qualifies as asset-holding. The computation of article 18 of the LIS (related parties) aggregates your participation with that of spouse, ascendants and descendants in direct line. In the case of the family quasi-shareholder —you at 50%, your spouse at 50%— the aggregated participation is 100%, well above the 25% threshold. If the entity is asset-holding, the regime is blocked. If it is operating, the filter does not apply.
[ÁLVARO: nuance missing here — add typical practical cases of family companies and pre-move restructuring options (separation of operating/asset-holding branches, intermediate holding, etc.) that have worked in your practice]
What if my company only has real estate, or only manages investments?
It is probably an asset-holding entity under article 5.2 of the LIS. The rule is: where more than 50% of the assets consists of securities or items not assigned to an economic activity, the company is asset-holding. The most relevant exceptions are the holding of active management of subsidiaries with at least 5% and the allocation of means (article 5.2.d of the LIS), and the real-estate leasing company with a full-time employee (article 5.1 of the LIS).
If your company is asset-holding, the 25% limit with family aggregation operates.
[ÁLVARO: nuance missing here — add which pre-move restructurings you have seen work to take a real-estate company out of the asset-holding perimeter (effective allocation, hiring a manager, mixed holding) and which have failed for lack of substance]
I keep boards of directors in other countries, is that a problem for the regime?
Not by itself. V2095-24 expressly confirmed that holding administration posts abroad —remunerated or not— is not an obstacle to the regime nor a cause of exclusion, provided the income derived is not characterised as obtained through a permanent establishment in Spain.
[ÁLVARO: nuance missing here — add the typical case in your portfolio: client with boards in a foreign holding + executive in a Spanish subsidiary under Beckham. There is a fine point on the place of business decision-making that warrants noting for the reader]
What happens if I change jobs within the six years?
The regime survives the change. V1208-25 consolidated the doctrine of V0432-17 and V1739-17: if the relationship that originated the move ceases and, after a brief period of unemployment or inactivity —even an overlap of a few days— a new employment or administration relationship begins that meets the requirements of article 93, the regime continues.
It is not necessary for the new relationship to be with the same entity, nor for the original modality to be preserved. One can transit from employment to the post of administrator, or vice versa.
[ÁLVARO: nuance missing here — add how long an "unemployment period" is "brief" enough to defend in practice (weeks, months) and what documentation is prepared to evidence continuity of the original purpose]
If the new company does not fit the requirements, do I lose the regime?
Yes, if the new relationship does not meet the requirements of article 93. The exclusion takes effect in the tax period in which the breach occurs, not retroactively. You lose the regime going forward and are taxed as a common tax resident on your worldwide income from that year.
[ÁLVARO: nuance missing here — add what "borderline" cases you have seen in practice (new post in an asset-holding company, transition to self-employed professional, merely nominal post with no activity) and how they were managed]
What consequences does losing a requirement subsequently entail?
You are obliged to communicate it to the tax Administration within one month of the breach (article 118 of the RIRPF, Form 149). The loss has prospective effect: in that tax period you are already taxed as a common resident. There is no retroactive regularisation for the years in which you did meet the requirements. But the very obligation to communicate is binding and its omission is sanctionable.
5. Wealth and money outside Spain
Under the regime, do I have to be taxed in Spain on my wealth and income from abroad?
Not on most. Under the LIRPF, during the six years of the regime you are taxed only on income obtained in Spain (employment income from your Spanish employer/company, real-estate income from real estate in Spain, etc.). Your foreign income —dividends, rents, interest, capital gains— remains outside the Spanish LIRPF.
For the Net Wealth Tax and the ITSGF, you are taxed only by in rem obligation, that is, on your assets located in Spain.
[ÁLVARO: nuance missing here — add the case of employment income whose work is performed outside Spain (planning of business travel, temporary assignments, performance of functions from abroad) and how the "non-obtention in Spain" is documented to keep it outside the LIRPF]
Do I have to file the famous Form 720 on foreign assets?
No, while you are under the regime. The rules expressly exempt the person availing himself or herself of article 93 of the LIRPF from the obligation to file Form 720 (information return on assets and rights abroad) and, since 2024, also Form 721 (crypto-assets abroad).
This exemption ends when the regime ends. The year following the sixth, as a common resident, you are again obliged by both forms with respect to your assets as at 31 December.
What about my trusts or family foundations outside Spain?
It is a technically complex terrain and one not intuitive for those coming from a legal system that recognises the trust as a vehicle. Spain does not recognise the trust as a legal institution, so in tax matters the principle of tax transparency operates: the legal relations governing the contributors and the beneficiaries of the trust are considered as carried out directly between them, as if the trust did not exist.
In practice, two relevant consequences (DGT V0022-25 and V1700-25):
- The contributions to the trust have no effects: the settlor retains the ownership of the contributed assets.
- The transfer from the settlor to the Spanish-resident beneficiary is deemed direct, subject to the Inheritance and Gift Tax by personal obligation.
[ÁLVARO: nuance missing here — add when, under the Beckham regime, it is preferable to keep the trust intact vs to reorganise (direct inter vivos gift, substitution by a Spanish holding), and the Madrid play (99% abatement on inheritance) + Beckham that you mention in the Trust post]
How am I taxed on a Spanish property under the regime?
Real estate in Spain generates three basic taxes:
- LIRPF / IRNR: if you lease it, the rental income is taxed as real-estate income in Spain. If you do not lease it and it is the habitual residence, it does not generate imputed income. If you do not lease it and it is a second residence, it generates imputed income at the 24% rate.
- Net Wealth Tax and ITSGF: by in rem obligation. If your habitual residence is in a region with a high abatement (Madrid 100%), the practical effect is neutralised.
- IBI (Real-Estate Tax): municipal tax, annual, on the cadastral value.
[ÁLVARO: nuance missing here — add what title-holding planning you have seen work (Spanish company, foreign company, direct holding) depending on the client's profile and the time horizon of the real estate]
Does my country of origin still consider me a tax resident?
It is highly possible, and it is advisable to resolve it before the move. Each country has its own tax-residence rules and, in many cases, a clean exit does not automatically extinguish the status of resident. The United States by citizenship; the United Kingdom by SRT and temporary non-resident rules; Germany by Wegzugsbesteuerung; France by Article 4 B of the CGI; etc.
If both States consider you a resident, there is a conflict and the tax treaty applies: the tie-breaker rules of article 4.2 of the tax treaty (permanent home, centre of vital interests, habitual residence, nationality).
How is my Spanish tax residence under the Beckham regime evidenced?
The accreditation is made by means of a tax-residence certificate in Spain issued by AEAT. For the Beckham regime, the certificate has the peculiarity of not evidencing the status of “resident for the purposes of the tax treaty” because, although you are a Spanish tax resident, you are taxed as a non-resident and most tax treaties only cover full residents.
This can generate friction with foreign tax authorities that request a certificate for treaty purposes. For those cases, AEAT issues a specific certificate of access to the regime of article 93 of the LIRPF.
[ÁLVARO: nuance missing here — add when in practice this generates effective double taxation and how it is managed (mutual agreement procedure, treaty MAP, planning the use of foreign tax credit in the source country)]
Does the regime affect the pension I already receive from outside Spain?
Under the Beckham regime, pensions of foreign source do not enter your Spanish LIRPF tax base: you maintain non-resident treatment, so you are not taxed on them in Spain. The pension will continue to be taxed in the paying country according to its domestic rules, modulated by the tax treaty that applies.
There are nuances depending on the type of pension and on the specific bilateral tax treaty. As a general rule in treaties following the OECD Model, public pensions (those paid by a State for prior services rendered to that State) are taxed exclusively in the paying State; private pensions (private pension plans, annuities) are taxed exclusively in the State of residence of the beneficiary, save for treaty exceptions.
[ÁLVARO: nuance missing here — add which foreign pensions most frequently cause a problem under the regime (US 401(k) pensions, UK SIPP, German plans), how their coordination with the regime is planned and when it is preferable to delay receipt for post-Beckham]
What about my stock options or RSUs vested before, during or after the regime?
The rules of temporal imputation of income for equity compensation determine in which year the income is taxed. As a general rule:
- Vested before the move: the income is deemed obtained in the pre-Beckham period; it will be taxed under the rules of the prior country of residence, not in Spain.
- Vested during the regime: the income is employment income. If it is deemed obtained in Spain (because it corresponds to work performed here), it is taxed at 24% under the regime. If it is deemed obtained outside —because it corresponds to work performed abroad before or during the regime—, it is not taxed in Spain.
- Vested after the regime: you are already taxed as a common resident, with the progressive scale on the entirety.
The determination of “where” the income is obtained depends on the schedule of work performance during the vesting period, normally with a proration rule. It is one of the typical points where pre-move planning has the greatest absolute tax impact.
[ÁLVARO: nuance missing here — add what pre-move planning you have applied for equity comp (accelerating vesting before the move, delaying grant, coordinated exercise of options, management of cliff dates), and how the country-period proration is documented in any eventual inspection]
6. Family, application and end of the regime
Can my partner also apply for the regime?
Yes, since the 2022 reform (article 93.3 of the LIRPF). The spouse may apply for the regime together with the main contributor, provided that:
- He or she moves to Spain together with the main contributor (or in the immediately following calendar year).
- Has not been a Spanish tax resident during the five preceding tax periods.
- His or her income during the regime does not exceed that of the main contributor.
The spouse’s application is filed within the same six-month period as the main contributor’s. If the main application is approved, the spouse’s is approved in cascade.
And my children?
Yes, same conditions as the spouse. The coverage extends to children under 25 (or with disability, with no age limit) who are dependent on the main contributor or on the spouse. The regime applies to the income they receive: if they work in Spain, their salary is taxed at 24%.
What about children over 25?
They are outside the 93.3 regime. If they wish to access the Beckham regime on their own, they will have to meet all the requirements of article 93.1 on their own account: five years without residing in Spain, their own triggering event (employment contract, administrator, etc.), independent application.
How do I apply for the regime?
By Form 149, addressed to the Tax Agency. The filing is electronic via the AEAT electronic site. Documentation to accompany:
- Identification of the contributor and, where applicable, of the employer / administered entity / entrepreneurial project.
- Documentation of the triggering event: employment contract, deed of appointment as administrator, ENISA report, etc.
- Registration with Social Security in Spain, or document evidencing the preservation of the Social Security of the country of origin (A1 certificate or equivalent).
- Where applicable, residence and work permit.
Within what time limit do I have to apply?
Six months from the date of commencement of the activity as recorded in the registration with Social Security in Spain (or in the equivalent documentation of the country of origin, if you keep its Social Security).
It is a lapsing period: once the period has passed, you cannot avail yourself of the regime even if you met all the substantive requirements. The preparation of the application must start in the days following the move.
Can I voluntarily renounce the regime?
Yes. The renunciation is communicated between 1 November and 31 December of the year before the year in which you wish to stop applying the regime, by Form 149. The renunciation is definitive: once renounced, you cannot return to the regime even if you maintained the requirements.
[ÁLVARO: nuance missing here — add the case in which renunciation is preferable: typically, tax periods with very high foreign income where the tax cost of being taxed as a common resident with double-taxation relief ends up being lower than 24% on Spanish income without compensation. And the warning: renunciation is for the WHOLE group (contributor + spouse + children covered under 93.3)]
What happens when the six years end?
You move on to be taxed as a common tax resident from the seventh year:
- LIRPF on worldwide income with the normal progressive scale (up to 47%, depending on the Autonomous Community).
- Net Wealth Tax and ITSGF by personal obligation (not only on assets in Spain).
- Form 720 and Form 721 (crypto-assets) annually.
- Possibility of double-taxation relief on foreign income already taxed at source.
It is advisable to prepare the change in anticipation: review of portfolios, restructuring of foreign holdings, relocation plan where applicable.
Once outside the regime, can I re-enter?
Not directly. To re-enter you would have to meet again the requirement of not having been a Spanish tax resident during the five preceding years —and the six years in which you enjoyed the regime count as residence, even if you were taxed as a non-resident—. In practice, that means that after the six years of Beckham + five years outside = eleven years of minimum horizon to re-enter the regime.
There are international profiles for whom that horizon is viable (consultants, itinerant expats); for most it is not.
Final notes
This page is informative; it does not constitute individualised legal or tax advice. Each move to Spain under the regime of article 93 of the LIRPF has nuances that require specific analysis. If you need advice for your specific case, write to me at [email protected].
If you want to go deeper into any of the topics covered here, I have published detailed technical analyses in this Spanish Tax Journal on:
- International remote work under the article 93 regime — DGT V0476-26 + V1115-25
- Access through the administrator status (causation, asset-holding filter, continuity) — DGT V1208-25 + V1209-25 + V1622-24
- 100% quasi-shareholder in a Spanish operating company — DGT V1983-24
- Trustee and general director of a Spanish foundation — DGT V2095-24
- Foreign tax-residence certificate under the tax treaty — STS 778/2023 + STS 971/2025
- Foreign trust and Beckham regime — DGT V1700-25 + V0022-25