The special regime for impatriates, commonly known as the ‘Beckham Law’, allows certain taxpayers who have relocated to Spain to be taxed for up to six years under the rules governing Non-Resident Income Tax (IRNR), despite having acquired tax residence in Spain. This peculiarity creates a paradox with unjustifiable practical consequences which, in light of recent rulings, seems unlikely to be maintained for much longer. This is particularly the case following the guidance provided by the Directorate-General for Taxation in its Binding Ruling V2467-25 of 11 December 2025.

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Fuente: Andersen