The special regime for impatriate workers, commonly known as the “Beckham Law”, remains one of the most attractive tax tools for professionals and executives relocating their tax residence to Spain. This regime allows taxpayers to be taxed under the Non-Resident Income Tax during the year of relocation and the following five years, while formally retaining their status as Personal Income Tax (IRPF) taxpayers.
What is the Beckham Law and who can benefit?
The Beckham Law or impatriate regime is designed to attract international talent to Spain. It enables workers who move for professional reasons to be taxed more favorably than under the ordinary IRPF.
Key requirements to access the impatriate regime in 2026
To qualify for this special tax regime for expatriates in Spain, you must meet the following conditions:
Not have been a tax resident in Spain during the 5 tax years prior to the relocation.
Relocation justified by a qualified professional reason, such as:
Employment contract (including remote work);
- Appointment as director of a Spanish company (maximum 25% ownership if it is an asset-holding company);
- Innovative business activity with a favorable report from the competent authority;
- Provision of services as a highly qualified professional for startups or in R&D&i activities.
- No income derived through a permanent establishment in Spain, except for certain regulatory exceptions.
Common question: Can I hold shares in foreign companies under the Beckham Law?
One of the most frequently asked questions is whether maintaining shareholdings in foreign companies could affect eligibility or continued access to the impatriate regime in Spain.
Binding Ruling V1372-25: Spanish Tax Authority clarification on the Beckham Law
The Spanish Tax Agency’s Directorate General for Taxes (DGT) addressed this issue in Binding Ruling V1372-25, analyzing the case of a regime beneficiary who was a partner in a UK-based Limited Liability Partnership with no activity in Spain.
Tax Authority’s conclusion:
If the foreign entity has no physical structures, personnel, clients, or activity in Spain, the income allocated to the partner is not considered to be derived through a permanent establishment in Spanish territory.
What constitutes a permanent establishment in Spain?
For a permanent establishment to exist, tax regulations require:
- A fixed place of business in Spain;
- A stable operational presence;
- Or a person acting in Spain on behalf of and for the account of the foreign entity.
- If these elements are absent, a permanent establishment is not deemed to exist, and therefore the benefits of the impatriate regime are not lost.
Tax benefits for impatriates with foreign investments
This interpretation confirms that beneficiaries of the Beckham Law may:
- Hold shareholdings in foreign entities;
- Receive dividends and other income from those companies;
- Continue to be taxed under the special regime, provided the entity’s activity is carried out entirely outside Spain.