After approval: Modelo 151, compliance & exit

Much of the attention around the Beckham Regime focuses on getting in. But the regime is a multi-year commitment, and what you do after approval matters just as much as how you qualified. Two things are easy to neglect once the excitement of relocating fades: annual compliance through the correct return, and planning for the day the regime ends. Both reward foresight and punish improvisation.

"Approval is the start of a six-year obligation, not the finish line. File Modelo 151 on time each year, keep the qualifying conditions intact, and plan for the day the regime ends before that day arrives."

Modelo 151: your annual return

Once you are under the regime, you do not file the ordinary Spanish IRPF return in the usual way. The Spanish Tax Agency confirms that taxpayers who exercise the option via Modelo 149 file their annual tax return using Modelo 151. This is the return that applies the special rules — the flat rate on the general base and the specific treatment of income — for each year you are in the regime.

How long the regime lasts

The regime applies for the tax year in which you acquire Spanish tax residence plus the following five tax years — up to six years in total. That is a finite window, and the clock is running from the year you arrive. Knowing exactly when it ends is the starting point for sensible planning.

The annual filing rhythm

The mechanics of Modelo 151 mirror the ordinary Spanish tax calendar. The Spanish tax year is the calendar year, running from 1 January to 31 December, and the annual return is filed the following spring in the general campaign window that the Spanish Tax Agency opens each year. You will therefore go through the same broad rhythm as any resident taxpayer — a period during which the return is prepared, presented and any balance is settled — but you present it on Modelo 151 rather than on the ordinary Modelo 100 that other residents use.

It helps to think of the six-year window as a repeating annual cycle rather than a single event. Each year you gather the income and withholding information for the period, classify each stream according to the special rules, present Modelo 151 within the campaign window, and keep the supporting documentation. Because the return under the regime is not the same form as the ordinary one, it is worth confirming the exact filing dates for your year rather than assuming they are identical, and worth diarising them well in advance so that no year is missed. A missed or late return is one of the avoidable ways that an otherwise clean file becomes complicated.

The years are numbered here for clarity — what matters is that the regime covers the year residence is acquired plus the following five, and that the intensity of planning naturally rises towards the end of that window.

What income you report each year

The central attraction of the regime is how it treats income. Under Article 93 of the Personal Income Tax Act, as amended by Law 28/2022, a taxpayer who validly elects the regime is broadly taxed in a manner closer to a non-resident on Spanish-source income, rather than on worldwide income in the ordinary way. In practice this means the general base — employment and comparable income connected with the displacement to Spain — is taxed at the special flat rate rather than at the ordinary progressive scale that applies to other residents, while certain categories of income keep their own treatment. Our guide on the 24% rate explains how that headline figure works and where the limits sit.

It is useful to keep two mental buckets when preparing each year's return:

• General base income — chiefly the employment income arising from the activity that brought you to Spain. This is the income that the special flat rate is designed for.
• Savings income — items such as dividends, interest and capital gains, which as a general rule follow the savings-income treatment rather than the flat general-base rate.

The distinction matters because the rate and the rules are not the same across the two, and because the source of the income (Spanish or foreign) interacts with how the regime taxes it. Getting each item into the right bucket, consistently, from the first return to the last, is the quiet work that keeps a Modelo 151 file clean. Where income sits close to a boundary — for example, income that could be characterised in more than one way, or gains realised at an awkward moment — it is worth taking advice before the return is finalised rather than after.

Under the regime you are broadly taxed like a non-resident on Spanish-source income; the ordinary rule of worldwide taxation returns only when the six years end.

Wealth and informative obligations

Compliance under the regime is not only about the income return. Depending on your circumstances, other obligations can apply, and these deserve cautious, individual review rather than assumptions. Spain operates a wealth tax and, in recent years, a separate solidarity-type levy on larger net worth; whether either reaches you depends on the value and location of your assets and on how the special regime interacts with them in your year. This is precisely the kind of area where general information is no substitute for advice on your own numbers.

Spain also has an informative return for assets and rights held abroad — commonly discussed under its historic form number — which is an information declaration rather than a tax in itself. Whether a taxpayer under the special regime is required to file it, and in what form, is not something to guess at: it turns on residence status, the categories and values of the foreign assets, and the specific rules in force for the year. The safe posture is to identify early, for each year, which informative obligations might apply to you and to confirm them, so that an informative filing is never overlooked. Missing an information return can create disproportionate problems relative to the effort of simply checking.

Staying compliant across the years

Annual compliance should not be neglected. You must continue to meet the requirements of the regime throughout its duration, and file correctly each year. Income classification remains important — the treatment depends on the source and character of each income stream, as covered in our guide on the 24% rate — and consistency with your original file (activity, structure, ENISA project) continues to matter.

Keeping the file consistent year to year

One of the least glamorous but most valuable habits under the regime is consistency. The picture you presented when you elected the regime — the activity that justified your displacement, the company or contract behind it, the ENISA project where relevant — should be recognisable in each year's return. When a file tells the same coherent story from the first Modelo 151 to the last, it is straightforward to explain if it is ever queried. When the story drifts year to year without explanation, questions become harder to answer well after the fact.

Practical consistency comes down to a few habits repeated each year:

• Classify recurring income the same way each year unless the underlying facts genuinely change, and record why if they do.
• Keep the documents that support each return — contracts, payroll records, dividend statements, withholding certificates — organised by year and retained for as long as they could be relevant.
• Reconcile each year's return against the previous one, so that any change is deliberate and explainable rather than accidental.
• Note any change in your activity, employer, company structure or residence intentions when it happens, rather than reconstructing it later.

None of this is exotic. It is simply the difference between a file that can be defended calmly and one that has to be pieced back together under time pressure. The master guide on applying for the Beckham Regime sets out the picture you build at the start; the task across the middle years is to keep that picture true.

When circumstances change

Life changes, and some changes affect the regime. If the qualifying activity ends, if you stop meeting the conditions, if you move away, restructure your business or create permanent-establishment issues, further analysis may be needed — and in some cases the regime can be lost. Modelo 149 is also the instrument used to communicate renunciation, exclusion and the end of the displacement, so material changes should be handled deliberately, not ignored.

Planning your exit

When the six years end, you transition to ordinary IRPF taxation on your worldwide income — a meaningfully different position, especially for high earners and those with international assets. Good exit planning considers the timing of income and gains, the structure of any companies, your residency intentions and, for US citizens, the interaction with US rules. Decisions taken in the final years of the regime can significantly affect the years after it.

The clients who benefit most from the Beckham Regime treat it as a six-year plan with a defined beginning, middle and end — not as a one-off approval.

A year-4-to-5 exit playbook

The transition from the special regime to ordinary IRPF is one of the few tax events you can see coming years in advance. That foresight is worth using. The following is a general framework, not a prescription — every situation differs and needs its own analysis — but it captures the questions that tend to matter most as the regime approaches its end.

• Timing of income and gains. Because the regime treats Spanish-source and foreign income differently from ordinary residence, the year in which a bonus, a distribution or a capital gain is realised can matter. Consider, well before the final year, whether particular items are better realised while still inside the regime or after it, always within the law and on advice.
• Company structure. If you own or control a company, the structure that served you during the regime may not be the right one afterwards. Founders in particular should revisit how their company is held and where — and be alert to the permanent-establishment questions that can arise when a foreign company is effectively run from Spain. Structural changes take time and should not be left to the final months.
• Residency intentions. Ordinary IRPF taxes worldwide income, so your intentions about where you will be resident after the regime feed directly into the planning. If a change of residence is genuinely on the table, it needs to be planned on its own timeline and for its own reasons, not improvised at the last minute.
• Modelling the after-picture. Build a rough model of your tax position under ordinary IRPF a year or two before the regime ends, so that the transition holds no surprises and any decisions are taken while there is still time to act on them.

The recurring theme is timing. Almost every worthwhile exit decision is easier and cheaper to make in year four or five than in the weeks around the changeover. Note too that Modelo 149 is also the instrument used to communicate renunciation, exclusion and the end of the displacement, so any early or planned departure from the regime has its own formalities to observe.

US-citizen coordination

US citizens and green-card holders carry an obligation that most other nationalities do not: the United States taxes its citizens on worldwide income regardless of where they live. That obligation does not pause while you are under the Beckham Regime, and it does not switch off when the regime ends. For a US person, therefore, Spanish and US planning have to be run together rather than in isolation.

Two points deserve particular attention. First, throughout the six years, US filing continues alongside your Spanish Modelo 151 — the Spanish special regime changes how Spain taxes you, but it does not change your US filing obligations. Second, the exit from the regime is a US planning event as much as a Spanish one: the shift to Spanish worldwide taxation interacts with the US system, with foreign tax credits and with the treaty position in ways that can be favourable or costly depending on how they are sequenced. The sensible approach is to coordinate the Spanish exit plan with a qualified US adviser well before the final year, so that the two systems are working with each other rather than against each other. This site provides general information on the Spanish side; the US side must be handled by someone qualified for it.

General information, not legal or tax advice. Grounded in Article 93 of the Personal Income Tax Act (as amended by Law 28/2022) and the Spanish Tax Agency's Modelo 149/151 procedures. Rules change and must be confirmed for your circumstances and year.