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LIRPF Art. 93 · Modelo 149 · 24% IRPF Rate
Three Mandatory Conditions
The Beckham Regime requires meeting three key criteria simultaneously. Failing to satisfy even one of these conditions makes applying impossible:
1. Prior Tax Residency
Less than 5 years of Spanish tax residence over the last 10 years preceding relocation to Spanish territory.
2. Specific Residence Authorisation
Holding an authorisation under Law 28/2022 — typically a Digital Nomad Visa (DNV) or Startup Visa. Critical point: a standard autónomo without a DNV does NOT qualify for the Beckham Regime.
3. Income Structure & Origin
At least 80% of income must come from foreign clients or an employer, and there must be no permanent establishment (PE) in Spain.
An IT developer earning €80,000/year under the standard progressive tax scale would pay ~€40,000–45,000, whereas under the Beckham Regime they pay just €19,200 (savings of up to €25,000 in the first year).
Filing Modelo 149 and Key Risks
The application is submitted using Modelo 149 to the Spanish Tax Agency (AEAT). The preclusive deadline is 6 months from the date of first registration with Social Security (Seguridad Social).
The status is granted for a period of 6 years. The flat 24% rate applies to income up to €600,000 per year (with any excess amount taxed at 47%).
Main Risk: if during the validity of the regime the share of Spanish clients exceeds 20%, the regime is revoked with retroactive tax reassessment for the previous year.
Frequently Asked Questions (FAQ)
Can Modelo 149 be filed retrospectively?
No. The 6-month deadline from Social Security registration is preclusive and cannot be extended or reinstated.
Does the regime work with 70% foreign and 30% Spanish clients?
No. The minimum foreign income share is strictly 80%. The client portfolio must be restructured or alternative tax tools considered.
What is considered a ‘permanent establishment’ (PE)?
The existence of an office, warehouse, director, or any fixed place of business activity on Spanish territory.
Book a consultation with our tax lawyer:
📞 +34 696 85 95 47 | 🌐 igorlapchynskyi.com
