Oliver moves to Singapore in the middle of his fourth year
Oliver Hayes is Australian, chief financial officer of a payments company, and has lived in Madrid since 2024 under the regime of article 93, commonly called the Beckham regime. In 2027 his group offers him the job of running the Singapore office. He earns 135,000 € a year in Spain and in Singapore he would earn the equivalent of 180,000 €. He has two possible dates for the move: the end of April or mid-August. He asked us what he had to file when he left and whether the date changed anything.
It changes almost everything. Under Spanish law tax residence is decided by whole calendar years, and depending on the date Oliver chooses, 2027 will be a year as a resident in the regime or a year as a non-resident.
The first question: are you still resident that year?
Article 9 of the IRPF Law (Spanish personal income tax) treats as resident anyone who spends more than 183 days in Spain in the calendar year, or has the main centre or base of their activities or economic interests here, and presumes residence when the spouse from whom they are not separated and their dependent minor children live in Spain. With Oliver's two dates:
| Departure | Days in Spain in 2027 | Likely result, on days alone |
|---|---|---|
| 30 April | 120 | Non-resident, unless another criterion makes him resident |
| 15 August | 227 | Resident for the whole year |
The right-hand column says "likely" for a reason: days are not the only test. If Oliver's family stayed in Madrid until the end of the school year, the presumption in article 9 could make him resident even if he spends fewer than 183 days here. And Singapore may treat him as resident there at the same time; what its rules say will be confirmed by his adviser in Singapore. If both countries claim him, the treaty between the two states decides, and we explain it in the guide on dual residence conflicts.
If he leaves in August: a last Modelo 151 and a notice
If Oliver leaves on 15 August and is still resident in 2027, that year is still a regime year, and Modelo 151, the regime's annual return, has to be filed. The problem is what goes into it. Article 93.2.b of the Law says that all employment income obtained during the regime is treated as obtained in Spain, which in principle would include the Singapore salary from September to December.
The IRPF Regulations provide the tool to avoid that. Article 119.5 requires the taxpayer to report, within one month, that the posting has ended without losing residence in that year. And article 114.2.a establishes that income from an activity carried out after the date of that notice is not treated as obtained during the regime.
Let us see the effect in figures:
- Spanish salary from January to mid-August: 135,000 × 7.5 / 12 = 84,375 €.
- Singapore salary from mid-August to December, at a rate of 180,000 € a year: 180,000 × 4.5 / 12 = 67,500 €.
- With the notice filed in time, Modelo 151 includes the Spanish salary: 84,375 × 24 % = 20,250 €. The Singapore salary would only come in if it were Spanish-source income, and work performed in Singapore is not.
- Without the notice, there is a risk that the 67,500 € will be treated as obtained during the regime: 67,500 × 24 % = 16,200 € more, with a double taxation deduction limited by article 114.2 of the Regulations to 30 % of the corresponding tax, that is, 4,860 € at most.
The notice is given on Modelo 149, the same form used to opt into the regime, and in Oliver's case it would have to be filed before 15 September.
This is the step most often forgotten, because it falls in the middle of the move. If your posting ends and you are still resident that year, count the month from your last day of work in Spain and file Modelo 149 before it runs out. Without that notice, the regime's worldwide employment income rule can reach salaries you are already earning in another country.
If he leaves in April: no Modelo 151 for that year
If Oliver leaves on 30 April and is not resident in 2027, he stops being an IRPF taxpayer that year and the regime disappears with it: there is no Modelo 151 for 2027. His last Modelo 151 is the one for 2026.
He becomes liable to IRNR, the Spanish non-resident income tax, only on his Spanish-source income for 2027. The salary from January to April, for work performed in Spain, is income obtained in Spain under article 13.1.c of the IRNR Law. As he is not resident in the European Union or the European Economic Area, the general rate in article 25.1.a is 24 %: on 135,000 × 4 / 12 = 45,000 €, that would be 10,800 €, in principle against the tax his company withholds.
The guide on Modelo 247 explains the notice that helps the company stop withholding as if Oliver were still resident.
What is closed off in the last return
| Issue | What to look at |
|---|---|
| Income not yet allocated to a year | Article 14.3 of the IRPF Law requires it to be included in the last period that has to be declared when taxpayer status is lost |
| Unvested RSUs or options | Split between the regime period and the period after leaving |
| Property in Spain | Still taxed as a non-resident: imputed income or rent, and 3 % withheld by the buyer on a sale |
| Wealth tax | Territorial basis for assets in Spain, as in the regime |
| Residence certificate from the new country | Oliver requests it from the Singapore tax authority; it proves his residence to third parties |
The shares from his employer that have yet to vest deserve their own calculation, which we describe in stock options and RSUs in the regime. If he has a home in Madrid that he does not sell, its treatment as a non-resident follows a logic similar to the one we explain in how your home is taxed in the regime, although without the question of the main home any longer.
The exit tax, in context
Article 95 bis of the IRPF Law taxes unrealised gains on shares on losing residence when the taxpayer has been resident for at least ten of the previous fifteen tax periods and certain values are exceeded. With a regime of six years at most, this requirement usually only concerns someone who already lived in Spain before or stays on for a long time afterwards. If that is your case, look at the guide on the exit tax.
If you are preparing to leave and want to choose a date with the figures in front of you, tell us your timetable on the Beckham form. We cannot tell you how your salary will be taxed in the new country, which is a matter for your adviser there, nor assure you that the tax authorities will share every view, but we can put the Spanish side in order and coordinate with whoever you appoint. If instead of leaving you use up the regime in Spain, read the year after the regime ends.
The regime's last return, the notices on leaving and coordination with the adviser in the destination country are part of what is described on the Salama Tax page on article 93.