The client, a CEO at a European company, was offered a role leading the Spanish subsidiary with a salary above €400,000 a year. Under Spain’s standard progressive income tax scale (up to 47%), this would have meant a significant loss of income.
We confirmed the client’s eligibility for the special impatriate tax regime (Article 93): he hadn’t been a Spanish tax resident for the past 5 years and was relocating under an employment contract. We filed Form 149 within the required six-month window, and in parallel structured his foreign assets.
Result: the client’s Spanish income is taxed at a flat 24% (up to €600,000 a year), and his foreign dividends and rental income stay outside Spanish taxation for six years.
The takeaway: the Beckham Law is one of Europe’s most generous impatriate regimes, but eligibility is easily lost to a formal error in filing deadlines or foreign asset structure.


