International Tax Advisory.

The Beckham Law, formally the "Special Regime Applicable to Workers, Professionals, Entrepreneurs and Investors Relocated to Spanish Territory" (Art. 93 of Law 35/2006 on Personal Income Tax), allows certain individuals who acquire Spanish tax residence to be taxed under the rules of the Non-Resident Income Tax (IRNR) during the year of relocation and the following five years.

The main advantage: a flat 24% rate on Spanish-source employment income up to €600,000 per year (47% on the excess), exemption from Form 720, and exemption from Wealth Tax on foreign assets.

The main requirements, following the 2023 reform:

• Not having been a Spanish tax resident during the 5 years prior to the relocation (previously 10).
• The relocation must be for employment reasons: a contract with a Spanish company, intra-group assignment, remote work for a foreign company under the digital nomad visa, appointment as a director, or entrepreneurship with a favourable ENISA report.
• Not obtaining income through a permanent establishment in Spain.
• Application via Form 149 within 6 months of registration with the Spanish Social Security system.

It depends on the DTT. Some treaties contain clauses that exclude or limit the application of the DTT to taxpayers under special regimes such as the Beckham Law. This is the case with the DTT with the Netherlands and, partly, with France.

Before opting for the Beckham Law, we review the DTT with the taxpayer's country of origin to verify that there are no treaty losses that would offset the tax savings of the regime.

Year 7 marks a complete tax shift: the taxpayer moves to the general IRPF (progressive scale 19%-47%), is taxed on worldwide income, regains the Form 720 obligation, and becomes subject to Wealth Tax on worldwide assets.

That is why we recommend planning the "exit" from the regime one or two years in advance: realisation of latent capital gains during the regime, asset restructuring, evaluation of a change of residence, etc.

It depends on the income and wealth profile:

• Beckham wins when income is high (above €200,000 per year) and most of the wealth is outside Spain. The exemption from Form 720 and worldwide Wealth Tax carry significant weight.
• Impatriati wins when income is medium-high and the taxpayer wants to maintain an economic life in Italy. The 50%-60% exemption on the taxable base can be more efficient under Italy's progressive rates.

The comparative analysis is done case by case, not as a general rule.

IMMEX (Manufacturing, Maquiladora and Export Services Industry) is a Mexican programme that allows goods to be imported temporarily without payment of VAT or customs duties, provided the goods are transformed, repaired or used to produce exports.

For Spanish companies that produce in Mexico for re-export (typically to the United States or back to Europe) it is highly advantageous. It makes no sense if the final destination of the product is the Mexican domestic market.

Yes. Form 720 (information return on assets and rights held abroad) and Form 721 (information return on crypto asset balances held abroad) are mandatory for Spanish tax residents who meet the relevant thresholds.

We handle both regular filings and the regularisation of undeclared years or late filings. Following the CJEU judgment of January 2022, the penalties under Form 720 are very different from before, but the risk of audit remains active.

Yes. When double taxation arises that is not eliminated through the mechanisms of the DTT or domestic law, Mutual Agreement Procedures (MAP) are the formal route for the tax authorities of the two States to negotiate a solution.

Avenor represents clients in MAPs between Spain and Italy, Spain and Mexico, and Italy and Mexico.