Spain After Beckham Law 6 Years Holding Structure Long Term Tax Planning

Last updated in April 2026

In one paragraph: This page provides straightforward, fluff-free answers for new Spanish tax residents—typically relocating executives and investors—who have elected or wish to elect the impatriate regime. Every figure presented is sourced directly from current BOE publications or strictly verified with the relevant consulate, AEAT, or autonomous-community tax authority handling your matter.

Language notice: Costaluz Lawyers offers legal services in English and Spanish only. Informational content in other languages does not imply consultation in those languages.

Overview

Spain’s special impatriate tax regime — known popularly as the Beckham Law — lets qualifying new tax residents be taxed like non-residents on their Spanish income for up to 6 tax years. This page is for readers who already know they want (or already elected) the regime and now need clarity on what happens after year 6, or how to combine Beckham with international holding structures.

After year 6 — the exit cliff

  • Income scope widens: foreign-source income (dividends, interest, gains) re-enters the Spanish tax base at the progressive PIT scale.
  • Wealth tax trigger: worldwide assets become reportable. Regional bonifications in your autonomous community become decisive.
  • Exit planning window: disposals, restructurings, and treaty elections are best executed before the Beckham window closes — typically 12 months ahead.
  • Residence-change option: some clients move tax residence to a treaty jurisdiction at year 5. Viability depends on substance requirements.

Next step

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Frequently asked questions

What is Spain’s Beckham Law (special tax regime for impatriates)?

The Beckham regime (Régimen Especial para Trabajadores Desplazados) lets certain new tax residents in Spain be taxed like non-residents on their Spanish-source income for up to 6 tax years — a flat rate instead of the progressive scale, and a narrow tax base that generally excludes foreign-source income.

What happens after the 6-year Beckham window closes?

You revert to ordinary Spanish tax residence: worldwide income under the progressive PIT scale, plus wealth tax and the large-fortunes levy (Impuesto Temporal de Solidaridad de las Grandes Fortunas) where applicable. Post-Beckham planning is about sequencing asset disposals, restructuring holdings, and pre-emptive treaty use — ideally started 12 months before the window closes.

Can I combine Beckham Law with a holding structure abroad?

In the Beckham window, yes — foreign-source dividends and capital gains generally sit outside the Spanish tax base. Post-window, the holding structure must be reassessed against Spain’s anti-avoidance rules (CFC, imputed-income, beneficial-ownership tests). A plan that worked year 1 may fail year 7.

Does the Digital Nomad Visa give me access to the Beckham regime?

Under the 2023 reform, certain DNV holders can elect the impatriate regime — subject to strict qualifying conditions. Whether the election is advantageous depends on your income mix and source country. We assess side-by-side before you elect.

What does Costaluz charge for Beckham Law structuring advice?

personalised quote by scope. Send a summary of your situation to marialuisa@costaluzlawyers.es and we’ll confirm a fixed-price quote within 24 hours.

This content has been prepared with the assistance of artificial intelligence and reviewed by María Luisa de Castro, a lawyer specialising in Real Estate Law and founder of CostaLuz Lawyers.

The information provided is general and indicative in nature. It should not be used as the sole basis for making professional, legal or investment decisions, and CostaLuz Lawyers assumes no responsibility for decisions taken solely on the basis of this content.

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