Moving from the US to Spain: How Much Tax Will You Pay and Can You Qualify for Spain’s Beckham Law?

A practical tax guide for US citizens, executives, remote workers, founders and investors relocating to Spain

Moving to Spain can significantly change the amount of tax you pay on your salary, investments, real estate and business income.

Most people considering a move from the United States do not begin by asking which Spanish tax form they will need to file. Their concern is much more direct:

A second question usually follows very quickly:

The answer depends mainly on three issues:

• Whether you will become a Spanish tax resident.
• Whether you will be taxed under Spain’s standard personal income tax rules for residents or can elect for the special expat tax regime commonly known as the Beckham Law.
• The type of income you receive: salary, business profits, dividends, rental income, capital gains, or a combination of these.

Two Americans with the same total income can pay very different amounts of Spanish tax. One may live mainly from salary, another from dividends and investment gains, and one may qualify for the Beckham Law while the other does not.

That is why the analysis should be carried out before the move—not after the first Spanish tax year has already ended.

At a glance: the three possible starting points

• If you are not a Spanish tax resident, Spain will normally tax only certain Spanish-source income.
• If you become a Spanish tax resident under the standard rules that apply to most residents, Spain may tax your worldwide income.
• If you qualify for the Beckham Law, certain foreign-source income may fall outside Spanish taxation and employment income may benefit from a 24% rate up to €600,000.

1. Will you become a Spanish tax resident?

Before estimating how much tax you may pay, you must first determine whether Spain will treat you as a tax resident.

As a general rule, you may be considered a Spanish tax resident when:

• You spend more than 183 days in Spain during the calendar year.
• Spain is the main centre or base of your economic activities or interests.
• The legal presumption applies because your non-legally separated spouse and dependent minor children habitually live in Spain.

Temporary or sporadic absences may count as days spent in Spain unless you can prove tax residence in another country.

Example: arriving in February

A person arrives in Spain on 1 February 2027 and remains in Spain for the rest of the year. They will exceed 183 days and will normally be a Spanish tax resident for 2027.

If they are taxed under Spain’s standard personal income tax rules for residents, Spain may require them to report worldwide income for the tax year, not only income received after the date of arrival.

Example: arriving in September

A person arrives on 1 September and had not previously been in Spain during that calendar year. They will probably not exceed 183 days. However, they must still examine:

• Whether their centre of economic interests has moved to Spain.
• Where their family lives.
• Whether earlier stays or sporadic absences affect the calculation.
• Whether the Spain–United States tax treaty must resolve a dual-residence situation.

Spain does not generally apply an automatic split-year system that divides the year into a resident period and a non-resident period. The timing of your move can therefore materially affect the tax cost of your first year in Spain.

2. What happens under Spain’s standard income tax rules for residents?

A Spanish tax resident who is not covered by a special regime is generally taxed in Spain on worldwide income. In this guide, this is referred to as Spain’s standard personal income tax system for residents.

Worldwide income may include:

• Salary paid by a Spanish employer.
• Salary paid by a US employer.
• Dividends from US shares.
• Bank interest.
• Rental income from US real estate.
• Pensions.
• Gains from the sale of shares.
• Cryptocurrency gains.
• Business profits or company distributions.
• Certain income connected with a US LLC.

Salary and other general-income items are taxed at progressive national and regional rates. The same rate is not applied to your entire income: lower bands are taxed at lower rates, while the upper bands are taxed at higher marginal rates.

Dividends, interest and many capital gains are generally included in the savings tax base, which is taxed separately by bands.

3. What is Spain’s Beckham Law and why should you review it before moving?

Spain’s Beckham Law is the commonly used name for a special expat tax regime available to certain individuals who become Spanish tax residents because they relocate to Spain.

Although qualifying individuals remain Spanish personal income tax taxpayers, their tax is calculated using certain rules derived from the Spanish non-resident income tax system.

The regime applies during:

• The tax year in which Spanish tax residence begins.
• The following five tax years.

The election is generally notified to the Spanish Tax Agency using Form 149, and the annual tax return is filed using Form 151.

The three main potential advantages

1. Employment income may be taxed at 24% up to €600,000

Income subject to the special general scale is taxed at:

• 24% up to €600,000.
• 47% on the amount exceeding €600,000.

This can be valuable because, under Spain’s standard progressive income tax rules for residents, part of a high salary may be taxed at marginal rates close to or above 45%, depending on the autonomous region.

2. Certain foreign-source income may fall outside Spanish tax

A person taxed under Spain’s standard resident rules generally reports worldwide income. Under the Beckham Law, territorial rules similar to those applying to non-residents may mean that certain foreign-source dividends, interest, rental income or capital gains are not taxed in Spain.

However, one point is essential:

Employment income earned while the regime applies is generally treated as Spanish-source income.

Therefore, salary paid by a US company does not escape Spanish tax merely because the employer or the bank account is located in the United States.

3. It may reduce exposure to Spanish wealth taxation on foreign assets

A person taxed under Spain’s standard resident rules may be exposed to Spanish wealth taxation on assets and rights located worldwide.

A taxpayer covered by the Beckham Law is generally subject to Spanish Wealth Tax on a limited, real-obligation basis, focused mainly on assets and rights located in Spain.

This distinction may be particularly important for someone who owns:

• A substantial US investment portfolio.
• US real estate.
• Shares in private businesses.
• A significant amount of financial wealth outside Spain.

4. Who can qualify for the Beckham Law?

Not everyone who moves to Spain can elect for the regime.

In broad terms, the applicant must:

• Become a Spanish tax resident as a result of moving to Spain.
• Not have been a Spanish tax resident during the previous five tax years.
• Move to Spain for one of the permitted employment, professional or business reasons.
• Meet the detailed conditions for the relevant category.
• Submit the election within the applicable deadline.

Employees

Individuals who move to Spain as a consequence of an employment contract or employment relationship may qualify.

International remote workers

Employees who move to Spain to work remotely for a foreign company using computer and telecommunications systems may fall within the expanded regime.

Spanish law expressly addresses certain holders of an international teleworking visa.

Company directors

Certain company directors may qualify, but the analysis should review:

• The nature of the company.
• The director’s ownership percentage.
• Whether the parties are related.
• The remuneration arrangements.
• The genuine reason for the move.

Entrepreneurs

Individuals moving to Spain to carry out an activity that is officially recognised as entrepreneurial under the applicable legal procedure may qualify. Simply incorporating a company or describing a project as innovative is not enough.

Highly qualified professionals

Certain highly qualified professionals providing services to certified startups, or carrying out training, research, development or innovation activities, may qualify if all specific requirements are met.

Who will normally not qualify?

The following circumstances are not normally sufficient on their own:

• Moving to Spain to retire.
• Living solely from investments.
• Buying a home in Spain.
• Owning a US LLC without an eligible professional reason for the move.
• Continuing as a traditional self-employed professional serving multiple clients, unless the activity fits one of the special statutory categories.

5. How much could you pay under the standard Spanish resident system and the Beckham Law?

The following calculations are illustrative estimates designed to show the approximate scale of the difference.

They assume, in simplified terms, an individual who is:

• Single.
• Without children.
• Resident in Andalusia.
• Not entitled to special deductions.
• Receiving employment income.
• Shown before Social Security contributions.

The actual result will depend on the autonomous region, deductible expenses, family circumstances, Social Security position, remuneration structure and other factors.

Illustrative comparison based on salary only

At what salary level may the Beckham Law become attractive?

There is no universal threshold. As a broad guide:

• Below €50,000, Spain’s standard resident income tax system may produce a lower result.
• Between €50,000 and €70,000, the salary-only difference is often limited.
• Between €70,000 and €100,000, a detailed comparison becomes worthwhile.
• Above €100,000, the salary tax saving may be significant.
• Where the individual also has foreign investments, rental income or capital gains, the Beckham Law may be attractive even at a lower salary.

The decision should not be based on salary alone. The total tax cost over the full six-year period should be compared.

6. Five practical examples

Case 1: US remote worker earning €60,000

Situation

Emily works for a US company and moves to Spain while keeping her existing employment contract. She performs all her work from her home in Spain and earns €60,000 per year, paid into a US bank account. She has no significant investments.

Tax under Spain’s standard resident rules

Her Spanish income tax could be approximately €15,000–€16,500.

Beckham Law

€60,000 × 24% = €14,400.

Potential saving

Approximately €600–€2,100 per year.

Could she qualify?

Potentially, provided that:

• The move is correctly linked to her remote employment.
• She meets the prior non-residence requirement.
• The employment relationship is properly documented.
• She files the election within the deadline.

Is it worthwhile?

It is worth reviewing, although the salary-only saving may not be substantial. The regime may become more valuable if she expects salary increases, bonuses, stock options, dividends or investment gains.

Case 2: Executive earning €150,000

Situation

Robert moves to Spain to take up an executive role. He will receive an annual salary of €150,000 and has no other major income.

Tax under Spain’s standard resident rules

Approximately €54,000–€57,000.

Beckham Law

€150,000 × 24% = €36,000.

Potential saving

Approximately €18,000–€21,000 per year.

If a similar difference continued for six tax years, the cumulative saving could exceed €100,000.

Could he qualify?

Probably, provided the move results from the employment position and all other statutory requirements are met.

Practical conclusion

This is the classic profile in which the Beckham Law should be analysed before the final employment and remuneration structure is signed.

Case 3: €120,000 salary, US dividends and a share sale

Situation

Laura moves to Spain to work as an employee of a technology company. She receives:

• Salary: €120,000.
• Dividends from US shares: €30,000.
• Gain on the sale of US shares: €100,000.

Tax under Spain’s standard resident rules

Approximate tax on salary: €42,000–€44,000.

Savings income and gains: €30,000 + €100,000 = €130,000.

• First €6,000 at 19%: €1,140.
• Next €44,000 at 21%: €9,240.
• Next €80,000 at 23%: €18,400.

Approximate tax on savings income: €28,780.

Approximate total Spanish tax: €70,000–€73,000, before any available credit for US tax.

Beckham Law

Salary: €120,000 × 24% = €28,800.

If the dividends and share-sale gain are US-source income and no rule converts them into Spanish-source income, they may fall outside Spanish tax while the regime applies.

Approximate Spanish tax: €28,800.

Potential Spanish tax difference: approximately €41,000–€44,000 in that year.

Could she qualify?

Potentially yes, because she is moving as an employee, provided all remaining requirements are met.

Where does the real benefit come from?

The main saving does not arise only from the 24% salary rate. It may also arise from the territorial treatment of US dividends and the US capital gain.

Case 4: Salary, US rental property and investments

Situation

James moves to Spain as an employee and receives:

• Salary: €90,000.
• Net rent from a Florida property: €25,000.
• Dividends: €20,000.
• Interest: €5,000.

Tax under Spain’s standard resident rules

Approximate tax on salary: €28,000–€30,000.

The US rental income would be calculated under Spanish rules. The taxable amount would depend on deductible expenses, depreciation, exchange rates and US taxes.

For illustration, assume an approximate gross Spanish tax cost of €8,000 on the rental income.

Dividends and interest total €25,000:

• €6,000 at 19%: €1,140.
• €19,000 at 21%: €3,990.

Approximate tax on dividends and interest: €5,130.

Approximate total Spanish tax: €41,000–€43,000, before double-tax relief.

Beckham Law

Salary: €90,000 × 24% = €21,600.

The US rental income, dividends and interest may fall outside Spanish tax if they retain foreign-source status.

Potential Spanish tax difference: approximately €19,000–€21,000 per year.

Could he qualify?

Potentially yes, if the move results from an eligible employment relationship.

Case 5: Owner of a US LLC

Situation

Daniel owns a US consulting LLC. The LLC earns €180,000 in annual profit. Daniel moves to Spain and continues working, negotiating with clients and managing the business from his Spanish home.

How much tax will he pay?

In this situation, you cannot simply apply the formula:

€180,000 × 24%.

Before calculating the tax, it is necessary to determine:

• Whether Spain treats the LLC as fiscally transparent or as a separate entity.
• Whether the LLC profit is attributed directly to Daniel.
• Whether Daniel is earning professional or business income.
• Whether the LLC has a permanent establishment in Spain.
• Whether the company may be regarded as effectively managed from Spain.
• Whether the amounts received are salary, dividends or distributions.

If the profit were treated as Daniel’s personal business income under Spain’s standard resident tax rules, the Spanish personal income tax bill could exceed approximately €65,000–€70,000, before Social Security and possible company-level obligations.

Can an LLC owner qualify for the Beckham Law?

Not automatically. Owning an LLC does not itself create eligibility.

Eligibility may need to be explored if Daniel:

• Becomes an employee under a valid structure.
• Moves as a company director while meeting the statutory requirements.
• Carries out an activity officially recognised as entrepreneurial.
• Qualifies as a highly skilled professional under one of the permitted categories.

What benefit could be available?

If, after advance analysis, Daniel could validly receive a €150,000 salary under a compatible structure:

• Approximate tax under standard resident rules: €54,000–€57,000.
• Beckham Law: €36,000.
• Potential salary-tax difference: €18,000–€21,000.

However, the Beckham Law would not by itself eliminate:

• Taxation of the LLC.
• Possible Spanish tax residence of the company.
• A Spanish permanent establishment.
• Taxation of company distributions.

The structure should be reviewed before the company is managed from Spain.

7. What if you live only from investments?

Assume an individual does not work and receives:

• Dividends: €60,000.
• Interest: €20,000.
• US rental income: €30,000.
• A planned share sale producing a €500,000 gain.

This may appear to be the ideal Beckham Law profile because the potential tax saving could be very large. However, there is a fundamental problem:

The individual must move to Spain for an eligible employment, professional or business reason. A person who moves solely to live from their wealth will normally not qualify.

Cost of selling shares under Spain’s standard resident rules

A €500,000 capital gain could generate approximately:

• €6,000 at 19%: €1,140.
• €44,000 at 21%: €9,240.
• €150,000 at 23%: €34,500.
• €100,000 at 27%: €27,000.
• €200,000 at 30%: €60,000.

Approximate Spanish tax: €131,880.

This shows why the timing of a share sale should be reviewed before Spanish tax residence begins.

This does not mean that every pre-move sale is automatically tax-free. US federal and state tax, the tax treaty, the true transfer date and the individual’s actual residence position must also be reviewed. Nevertheless, the timing difference can be extremely significant.

8. Spain’s Startup Law: what it is and who may benefit

Spain’s Startup Law is not a separate personal income tax regime and it does not automatically benefit every person who incorporates a company.

It is the common name for Law 28/2022, which was introduced to support emerging companies and attract talent, investment and entrepreneurship.

Its relevance to this guide is twofold.

It expanded access to the Beckham Law

The reform broadened the categories that may potentially qualify, including certain:

• International remote workers.
• Entrepreneurs.
• Company directors.
• Highly qualified professionals.
• Professionals carrying out research, development and innovation activities.

It also reduced the previous non-residence period from ten years to five years.

It may benefit a certified emerging company

A company that obtains certified startup status may, if all requirements are met, access benefits such as a reduced corporate income tax rate and certain incentives connected with investment and equity-based remuneration.

These advantages apply to a specific category of certified innovative company. They do not automatically apply to a consultancy, an asset-holding company or every small company created by a foreign individual.

Simple example

A US founder moves to Spain to develop an innovative technology project. The structure may require separate analysis of:

• Whether the company can obtain certified startup status.
• Whether the founder can qualify for the Beckham Law as an entrepreneur, director or highly qualified professional.
• How the founder’s salary will be taxed.
• How shares and stock options will be taxed.
• What happens when the company is sold.
• The correct order for the move, incorporation, appointment and start of activity.

The Startup Law may open the door to specific benefits, but it does not automatically make every founder eligible for the Beckham Law.

Suggested internal link: “Spanish Tax Agency Tightens Access to the Beckham Law for Entrepreneurs and Directors of New Companies: What Is Happening and How to Avoid a Rejection.”

9. Quick guide: should you review the Beckham Law?

10. What should you review before leaving the United States?

Your arrival date

Determine whether you will exceed 183 days and in which tax year Spanish residence may begin.

Your salary and employment structure

Review:

• Who your employer will be.
• Where you will physically perform the work.
• Whether you will be placed on a Spanish payroll.
• Whether you will remain employed by a US company.
• Whether the structure supports a Beckham Law application.

Your investments

Review:

• Expected dividends.
• Shares with unrealised gains.
• Mutual funds and ETFs.
• Cryptocurrency.
• Stock options.
• Restricted Stock Units (RSUs).
• Planned sales of company interests.

Your real estate

Analyse:

• US rental income.
• A possible sale of your home.
• Deductible expenses.
• Depreciation.
• US taxes paid.

Your LLC or company

Examine:

• Its tax classification in Spain.
• The place of effective management.
• Possible permanent establishment exposure.
• Salary and distributions.
• Related-party transactions.
• Whether restructuring should take place before the move.

Your wealth

Review possible exposure to:

• Spanish Wealth Tax.
• Spain’s Temporary Solidarity Tax on Large Fortunes.
• Foreign-asset reporting obligations.
• Taxation after the Beckham Law period ends.

Year seven

The Beckham Law is temporary. When it ends, the taxpayer will normally move into Spain’s standard personal income tax system for residents, and Spain may begin taxing worldwide income and wealth.

A proper comparison should therefore consider not only the six years of potential savings, but also:

• Which assets you will own when the regime ends.
• Which investments you expect to sell.
• Whether you plan to remain in Spain.
• Whether any reorganisation may be needed before the regime ends.

11. Will US citizens still have to file in the United States?

US citizens generally remain subject to US federal tax filing obligations on worldwide income even while living in Spain.

This does not necessarily mean paying the full amount of tax twice. The following may be relevant:

• The Spain–United States tax treaty.
• The Foreign Tax Credit.
• The Foreign Earned Income Exclusion.
• Other relief mechanisms.

However, coordination is not always straightforward. Differences may arise in relation to:

• The treatment of a US LLC.
• The tax year in which income is recognised.
• The acquisition cost of shares.
• Pensions.
• Deductible expenses.
• Which country is responsible for relieving double taxation.

The examples in this guide focus mainly on the potential Spanish tax cost. The US position should be calculated in coordination with the professional preparing the US tax returns.

Conclusion: before moving, you need a comparison based on real numbers

The relevant question is not simply:

Will I be a Spanish tax resident?

The useful question is:

How much would I pay under Spain’s standard income tax rules for residents, how much would I pay under the Beckham Law, and what should I do before moving so that I do not lose an important tax-planning opportunity?

• A person earning €40,000 may pay less under Spain’s standard resident income tax system.
• A person earning €150,000 could save around €20,000 per year under the Beckham Law.
• A person with salary, US dividends and US capital gains may achieve a considerably larger saving.
• A person planning to sell shares or a business may face a tax difference of more than €100,000 depending on timing, residence and the applicable regime.

The Beckham Law can be extremely valuable, but:

• It is not automatic.
• It is not suitable for everyone.
• It has a filing deadline.
• It requires a valid reason for the move.

Tax planning for Americans moving to Spain

At Cervantes Alarcón Consulting, we analyse the tax cost of relocating before the taxpayer makes decisions that may be difficult or impossible to reverse.

The review may include:

• Determining the first Spanish tax-residence year.
• Estimating tax under Spain’s standard income tax rules for residents.
• Checking eligibility for the Beckham Law.
• Comparing the total tax cost over six tax years.
• Spanish and US salary arrangements.
• Dividends, interest and capital gains.
• US real estate.
• LLCs, corporations and startups.
• Foreign wealth and investments.
• Transactions planned before and after the move.
• Coordination with the taxpayer’s US tax adviser.

Two people with the same total income may pay completely different amounts of Spanish tax.

Before fixing the moving date, obtain a personalised answer to three questions:

• When will I become a Spanish tax resident?
• Can I qualify for the Beckham Law?
• How much would I actually pay under each alternative?