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The end of the UK non-dom regime: why Spain is emerging as a leading relocation jurisdiction

The abolition of the UK non-dom regime is prompting a growing number of high-net-worth individuals, executives and founders to reassess their tax residence strategies.


This shift is not simply about headline tax rates. Increasingly, relocation decisions are being driven by legal certainty, regulatory stability, EU access and predictable tax treatment. In this context, Spain is consolidating its position as one of the most compelling alternatives within Europe.


Spain’s Special Inbound Workers Regime (“Beckham Law”)


Spain’s so-called Beckham Law is not a discretionary incentive or a negotiated arrangement. It is a rules-based tax regime embedded in domestic legislation, offering a high degree of certainty for qualifying individuals.


Legal basis

Article 93 of the Spanish Personal Income Tax Law (Law 35/2006 – IRPF), coordinated with the Spanish Non-Resident Income Tax framework.

Under this regime, individuals who become tax resident in Spain may elect to be taxed as non-residents for income tax purposes, subject to strict eligibility and timing requirements.


Eligibility: structured and time-bound

Access to the regime requires careful coordination between immigration, employment and tax positions. In broad terms:


  • The individual must not have been tax resident in Spain during the previous five tax years.


  • The relocation must be linked to:

    • an employment relationship,

    • a senior executive appointment,

    • or qualifying professional or entrepreneurial activity


  • Spanish tax residence must be effectively acquired (generally more than 183 days)


  • A formal election (Modelo 149) must be filed within six months of registration with Spanish Social Security


The regime is not automatic. Documentation, timing and consistency are critical.


Key tax advantages


  • Predictable flat taxation on Spanish employment income

    Spanish-source employment income is taxed at a flat 24% rate up to €600,000, with the excess taxed at 47%. This compares favourably to the progressive rates applicable to ordinary Spanish residents, which can exceed 45% depending on the region.

  • Exclusion of foreign-source income

    For up to six tax years (year of arrival plus five additional years), beneficiaries are generally not taxed in Spain on foreign-source income, including dividends, interest, capital gains, foreign business income and, in many cases, crypto-related income generated outside Spain.For former UK non-dom individuals with international portfolios, this feature is particularly relevant.

  • Wealth tax exposure

    Individuals under the Beckham Law are not subject to Spanish wealth tax on assets located outside Spain, providing additional certainty for internationally diversified profiles.


    How Spain compares to other destinations


    Italy

    Italy’s flat-tax and impatriate regimes can be attractive for ultra-HNW individuals with predominantly passive income. However, they often involve higher implementation complexity, less flexibility for mixed income profiles, and greater reliance on interpretative guidance.


    Dubai

    Dubai remains attractive from a zero-tax perspective, but it does not provide EU legal or regulatory integration. Banking, substance and long-term family or succession planning considerations can also be limiting.


    Spain’s strategic positioning

    Spain is not positioning itself as the lowest-tax jurisdiction in Europe. Instead, it is emerging as one of the most balanced:


    • a clearly codified tax regime,

    • predictable administrative processes,

    • access to the EU single market and banking system,

    • a strong treaty network, and

    • a high quality of life at a competitive cost.


    For UK HNW individuals exiting the non-dom regime and seeking compliant, medium- to long-term relocation solutions, Spain’s Beckham Law is increasingly a first-tier option — provided the structuring is done correctly from day one.


How Business Expats can support

If you are reassessing your tax residence, investment structure or relocation strategy after the end of the UK non-dom regime, Business Expats can help you design and execute a compliant move to Spain from day one.


Schedule a confidential consultation and let our team structure your relocation with clarity, certainty and long-term vision.


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