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A flat rate, with its way in and its yearly return

What happens in the year after the regime ends?

In the first year outside article 93 you are taxed on your worldwide income on the ordinary scale, you review Modelo 720 and wealth tax becomes personal. All of it is prepared beforehand.

Astrid is in her last year and does not know it yet

Astrid Lindqvist is Swedish, chief operating officer of a renewable energy company in Madrid. She arrived on 1 March 2021, so that same year she spent more than 183 days in Spain. She filed Modelo 149, the form used to opt into the special regime for workers moving to Spain, and since then she has been taxed under the regime of article 93, commonly called the Beckham regime. She earns 200,000 € a year. In Stockholm she keeps a portfolio of shares and funds worth 900,000 €, with an unrealised gain of 300,000 €, which pays her about 25,000 € of dividends a year.

When she wrote to us in September 2026 she thought she had two years of the regime left. She had three and a half months.

How the six years are counted

Article 93.1 of the IRPF Law (Spanish personal income tax) applies the regime during the tax period in which the change of residence takes place and the following five. Article 115 of the IRPF Regulations specifies which year counts as the year of the change: the first calendar year in which, once the move has happened, the stay in Spain exceeds 183 days.

ArrivalDays in Spain in the year of arrivalFirst year of the regimeLast year of the regimeFirst ordinary year
1 March 2021More than 183202120262027
1 October 2021Fewer than 183202220272028

Astrid's case is the first row. Someone who arrives in the autumn gains a few months in practice, because the first year of the regime is the next one. Nothing has to be notified to leave when the period runs out: the regime simply stops applying.

What changes on 1 January 2027

Worldwide income. Astrid becomes an ordinary IRPF taxpayer. She is taxed on all her income, wherever it arises: her salary, the Swedish dividends and the gains on her portfolio if she sells.

Progressive scale. Her salary is no longer taxed at a flat 24 %. With 200,000 € and, let us say, 5,000 € of Social Security contributions:

  1. Net income: 200,000 − 5,000 − 2,000 = 193,000 €.
  2. State scale: 8,950.75 € up to 60,000 € plus 133,000 € at 22.5 %, which is 29,925 €. Total 38,875.75 €, less 527.25 € for the personal allowance: 38,348.50 €.
  3. The regional portion depends on the Community of Madrid's scale, which we do not reproduce here. With a scale identical to the state one, purely as an assumption, the total would be 76,697 €.
  4. In the regime she paid 200,000 × 24 % = 48,000 €.

Foreign dividends. The 25,000 € from Sweden goes into her Spanish savings base. The IRPF Law's savings scale, adding together the state portion and the regional portion that the law itself sets, runs from 19 % to 30 %. The tax Sweden withholds can be deducted within the limits of the deduction for international double taxation. How much Sweden withholds, and on what terms, must be confirmed by Astrid's adviser there.

Personal liability to wealth tax. Article 5 of the Spanish Wealth Tax Law makes residents liable on a personal basis, on the whole of their wealth. The Stockholm portfolio, which was outside, comes in.

Modelo 720. For the first time, Astrid will have to check whether her assets abroad at 31 December 2027 exceed the thresholds of Modelo 720, the return declaring assets held abroad: 50,000 € per block.

The first Modelo 720 leaves no room for slips

The 900,000 € of the Swedish portfolio comfortably exceeds the threshold for the securities and funds block, and the account where she receives the dividends may exceed the one for accounts. The special penalty regime for Modelo 720 was struck down by the Court of Justice of the European Union in its judgment of 27 January 2022 (C-788/19), but filing late or incorrectly still has consequences under the general regime.

The unrealised gain: selling inside or outside

This is the decision that moves the most money, and it has to be taken before the regime ends. While the regime lasts, the sale of securities issued by non-resident entities is not Spanish-source income under article 13.1.i of the IRNR Law (the Spanish non-resident income tax), and it does not go into Modelo 151, the regime's annual return. From the first ordinary year, it does.

If Astrid sold in 2027 with the same 300,000 € of gain, the ordinary savings scale would give:

  1. First 6,000 € at 19 %: 1,140 €.
  2. Next 44,000 € at 21 %: 9,240 €.
  3. Next 150,000 € at 23 %: 34,500 €.
  4. Last 100,000 € at 27 %: 27,000 €.
  5. Total: 71,880 €.

If she sells in 2026, inside the regime, that gain is not taxed in Spain. If she wants to keep the investment, she can buy back, and her new acquisition value will be the repurchase price.

This possibility has limits that have to be looked at before acting on it. Sweden may tax the sale under its own rules, and that must be confirmed by Astrid's adviser there. There are transaction costs, and effects on funds that cannot always be sold and bought back without a penalty. And any transaction made solely for its tax effect must have a defensible economic rationale. It is not a general recommendation: it is a decision worked out case by case.

The timetable for leaving the regime properly

WhenWhat to review
Second-to-last year of the regimeInventory of assets abroad, unrealised gains and acquisition values
Last year, before the summerA simulation of the first ordinary year: salary, savings income and wealth tax
Last year, before 31 DecemberDecisions to sell, reorganising portfolios and documents
First ordinary yearPayroll withholding adjusted, first Modelo 720 and first wealth tax return on a personal basis

There is one point worth not forgetting: on moving to ordinary IRPF, the company must withhold tax using the general procedure. If payroll is not adjusted from January, the first ordinary return may bring a substantial amount to pay.

If you are thinking of leaving rather than staying

Some taxpayers use the end of the regime to move country. If you leave before it ends, the rules are different, and we explain them in leaving Spain while in the regime. If you are thinking of staying many more years, bear in mind that article 95 bis of the IRPF Law governs the taxation of unrealised gains on shares when you change residence, with requirements as to length of residence and value. Taxpayers in the regime keep their status as IRPF taxpayers; whether those years count towards that requirement is something worth having studied if your stay grows longer. The guide on the exit tax explains it.

If you have one or two years of the regime left and want to plan your exit, you can send us the details through the Beckham form. For the technical detail of each change, see the guide on leaving the article 93 regime, and for the first 720, when it has to be filed with the regime.

We cannot guarantee the tax outcome of a reorganisation or how another country will treat it. We can calculate the alternatives with Spanish law in front of us and warn you of the risks of each.

The transition from the regime to ordinary IRPF, with its timetable, is one of the stages described on the Salama Tax page on article 93.

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