Beckham Law vs. Mbappé Law Compared by Experts: How to Save Taxes in Spain

Sep 14

When it comes to taxes in Spain, few topics create as much confusion among expats as the Beckham Law and the new Mbappé Law. Both offer significant tax advantages for foreigners relocating to Spain, but the rules, requirements, and long-term implications are very different.

The Beckham Law, introduced in 2005, and the brand-new Mbappé Law, launched in Madrid in 2024. Both can reduce your tax bill significantly, but they apply in very different ways. Choosing the wrong one, or missing the deadlines to apply, can cost you tens of thousands of euros every year.

To bring clarity, I hosted a webinar with María Canudas and Júlia Carré, private client lawyers at EY, and Rob, a cross-border financial advisor at SJB US. Between them, they’ve guided hundreds of international families through Spanish relocation, from Fortune 500 executives to retirees with US retirement accounts. What follows is a practical breakdown of what each regime offers, who qualifies, and how they compare.

The Beckham Law: Spain’s original expat regime

The Beckham Law was Spain’s first attempt to attract international talent. Originally created to lure footballers like David Beckham, it now applies more broadly to foreign employees relocating for work.

To qualify, you must not have been a Spanish tax resident in the last five years, and your move must be tied to an employment contract or appointment as a director of a Spanish company. Freelancers and autónomos are excluded, although digital nomads under Spain’s new visa can sometimes qualify.

The main benefit is taxation. Instead of paying progressive rates that can reach 50% in Catalonia or 54% in Valencia, your employment income is taxed at a flat 24% up to €600,000, and 47% on anything above. On wealth tax, only your Spanish assets are subject — foreign accounts and properties are ignored. And unlike ordinary residents, you don’t need to file Spain’s notorious Modelo 720 foreign asset declaration.

Beckham Law — High Earner on Contract

A professional relocating to Barcelona with a €400,000 salary would pay around €96,000 under Beckham, instead of €150,000+ under the standard Catalan progressive rates.

Quick math: Under Beckham, income is taxed at 24% up to €600,000 → €400,000 × 24% = €96,000. Under Catalonia’s general regime, top rates can approach 50%, raising the liability well above €150,000.

But the regime comes with restrictions. It lasts for only six years (your arrival year plus five), and you cannot claim relief under double tax treaties because Spain won’t issue you a residency certificate. For Americans and Brits, this complicates how income is recognized back home.

As María from EY explained during our session:

“The Beckham regime is fantastic for high earners, but remember you cannot use double tax treaties. For Americans, this means the US–Spain interaction gets tricky.”

The Mbappé Law: Madrid’s new answer for investors

From January 2024, Madrid launched its own special regime, nicknamed the Mbappé Law, to attract wealthy individuals even without employment contracts. Unlike Beckham, which is tied to work, the Mbappé regime is tied to investment.

To qualify, you must not have been a Spanish resident in the past five years and you must invest in shares, bonds, or funds — either Spanish or foreign — during the year you arrive or the following year.

The tax benefits are striking. The regime grants a 20% allowance on the amount invested, which reduces your tax base. Salaries are taxed at 24.5%, and savings income like dividends, interest, and capital gains are taxed at just 15%. If your income is modest and you can’t use the full allowance, you can carry it forward for up to six years.

Crucially, Mbappé keeps access to double tax treaties, making it much easier for Americans to coordinate with IRS rules.

Mbappé Law — Investor/Retiree in Madrid

A US retiree moving to Madrid with €1M to invest in Apple stock could reduce their taxable base by €200,000. If they later generate dividends, those would be taxed at 15% instead of the standard 19–30% nationwide.

Key detail: The 20% allowance applies to the investment amount, and any unused allowance can carry forward up to six years. Mbappé also retains access to double tax treaties, unlike Beckham, which makes it especially valuable for US expats.

But there are strings attached. To benefit, you must remain a tax resident in Madrid for six years, and you must maintain the investment (though reinvesting is allowed).

As Júlia from EY noted:

“The Mbappé regime is very attractive for retirees and investors. Even if your income is modest, the 20% allowance can carry forward for years, giving flexibility.”

Beckham vs. Mbappé: how they stack up

While both regimes last six years, they target very different people. Beckham favors employees, Mbappé favors investors.

  
        Feature
        Beckham Law
        Mbappé Law
      
        Availability
        Nationwide (Spain)
        Madrid only
      
        Who it favors
        Employees/directors moving with a job contract
        Investors, retirees, HNWIs (no job required)
      
        Eligibility basics
        Non-resident last 5 years; employment or director role; not for freelancers
        Non-resident last 5 years; must invest in shares/bonds/funds in arrival year or next
      
        Income tax under regime
        24% up to €600k; 47% above
        Salaries ~24.5%; savings income 15%
      
        Wealth tax exposure
        Only Spanish assets
        Worldwide (mitigated by 20% allowance)
      
        Double tax treaties
        No (no Spanish residency certificate issued)
        Yes (treaty access retained)
      
        Duration
        6 years (arrival year + 5)
        6 years (with Madrid residency + investment maintenance)
      
        Freelancers eligible?
        ❌ Not eligible
        ✅ Eligible (as investors)
      
        Admin notes
        Apply within 6 months of social security registration; no Modelo 720
        Carry forward unused allowance up to 6 years; reinvestment allowed within rules
      
        Best fit
        High-earning professionals
        Investors & retirees in Madrid

Which one is right for you?

You’re moving with a job in Spain → Beckham Law is often the best fit.
You’re retiring or relocating with significant assets but no employment → Mbappé Law could be more beneficial — but only if you settle in Madrid.
You don’t qualify for either → You’ll fall under Spain’s general tax regime, which taxes worldwide income and assets progressively.

📞 Book Your Free Call with a Vetted Cross-Border Financial Advisor or Tax Advisor

Ready to get personalized advice on managing your 401(k), avoiding wealth tax, or planning your income as a US expat in Spain? Schedule a no-obligation call with one of our trusted financial experts today.

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Expert insights: why planning matters

During our webinar, María and Júlia from EY highlighted that the most common mistake expats make is missing deadlines. Applications for both regimes must be submitted within months of registering in Spain.

Rob added that for Americans, the choice isn’t just about Spanish tax savings:

“The US will still tax worldwide income, so the real question is how Spain and the US interact. Choosing Beckham vs. Mbappé can impact not just your Spanish bill, but also how much relief you get on the US side.”

Key Takeaways

The Beckham Law favors employees and offers simplicity, but limits treaty benefits.
The Mbappé Law favors investors and can slash taxes on portfolios — but ties you to Madrid.
Both require careful planning and early action.

As with wealth tax, two expats with similar backgrounds can end up with very different outcomes depending on where they live and which regime they choose.