Web3 founders often ask a simple question before relocating to Spain: can I put my token compensation under the Beckham Regime and pay the 24% flat rate? The answer is not a simple yes or no, because "token compensation" can mean several different things. It may be salary paid in a token. It may be a founder allocation with vesting. It may be a DAO grant, an advisory allocation, a staking reward, an airdrop or a later capital gain on a token that was already received. Spanish tax does not classify all of those events in the same way.
This page is deliberately different from our guides on crypto taxation under the Beckham Regime, stock options and RSUs, and Modelo 721 crypto reporting. Those pages cover the wider crypto rate analysis, traditional equity compensation and reporting. This page focuses on compensation paid or promised in tokens to Web3 founders, protocol employees, DAO contributors and crypto-paid consultants.
On this page
The starting point: payment medium vs tax character The two main buckets under Beckham The token compensation life cycle Tokens paid as salary or activity income Founder grants, vesting and lock-ups DAO and advisory compensation Later token sale or swap Reporting and Modelo 721 Evidence to prepare before moving Common mistakes Frequently asked questions
"For token compensation, the move plan has to separate the work-income event from the later asset event. That separation is where most of the tax answer lives."
— Jacob Salama · International Tax lawyer, Ilustre Colegio de Abogados de Málaga (nº 11294)
The starting point: payment medium vs tax character
The first rule is conceptual: a token is a payment medium or asset, not a tax category. If a company pays a developer in USDC for work, the tax question is not solved by saying "crypto". The first question is whether the receipt is employment income, professional or business income, investment income, a capital gain, a reward, or something else. Only after that classification is made can the Beckham Regime be applied.
Article 93 of the Personal Income Tax Act, as updated by Spain's Startup Act framework, can be very attractive for qualifying work or activity income. The regime taxes the qualifying general base at 24% up to €600,000 and 47% above that. But the regime does not convert every token-related euro into general-base income. If the token event is a capital gain or a savings-income event, the 24% headline may not be the relevant answer.
A token received for work and a gain made after holding that token are two different tax events. The first may be work income; the second is usually an asset-disposal question.
The two main buckets under Beckham
For most Web3 relocation files, the analysis begins with two buckets:
- General-base work or activity income. This is the bucket where salary, professional fees or qualifying entrepreneurial income may sit. Under Article 93, qualifying employment income and certain qualifying activity income obtained during the regime can be deemed obtained in Spain and taxed in the flat-rate general base.
- Savings-base or capital-gain analysis. Once a token is held as an asset, a later sale, swap or use of the token is generally analysed as a transfer of an asset. AEAT guidance on virtual currencies treats investor disposals as generating gains or losses by comparing transfer and acquisition values, and token-for-token exchanges can themselves generate gains or losses.
The difference is decisive. A founder who receives tokens for services during the regime may have a work-income event. If the founder later sells those tokens after they appreciate, the later appreciation is a different event. A model that puts both moments into one 24% bucket is usually too simple.
The token compensation life cycle
Token packages often look like equity compensation but are not always legally equivalent to equity. The documents matter. A typical package can include a grant letter, a vesting schedule, token delivery, lock-up, trading restrictions, DAO governance conditions, service milestones and clawback rules. Each stage can matter for tax timing and valuation.
| Stage | What to identify | Why it matters |
|---|---|---|
| Promise or grant | What legal right exists before vesting or delivery? | May be no immediate taxable value, or may need review if rights are transferable or valuable. |
| Vesting | When does the founder secure the right? | Often the key timing point for compensation analysis. |
| Delivery | When are tokens actually received and controlled? | Valuation and availability can depend on delivery and restrictions. |
| Lock-up | Can the token be sold, transferred or used? | Restrictions may affect valuation and practical liquidity. |
| Sale or swap | What is disposed of and for what value? | Usually a separate capital-gain or loss event. |
Tokens paid as salary or activity income
If tokens are received as payment for employment, consulting or a qualifying entrepreneurial activity, the starting point is work income. For an employee, that may be employment income. For a founder or consultant operating through a qualifying route, it may be professional or economic-activity income. In either case, the token has to be valued at the relevant receipt or recognition moment, because the fact that payment is made in crypto does not remove the need to measure income in euros.
Under the Beckham Regime, this is where the opportunity may exist. Employment income obtained during the years of application of the regime is deemed obtained in Spain, and qualifying activity income may also be brought into the regime where the legal conditions are met. If the token payment is genuinely consideration for that qualifying work or activity, it may sit in the general-base analysis. But that result depends on the role, the route, the payer, the contract and the year. It cannot be assumed from the word "founder" or "DAO".
Founder grants, vesting and lock-ups
Founder token grants are the hardest cases because they mix work reward, ownership economics, governance, liquidity restrictions and speculative upside. A grant may reward past work, future services, capital risk, protocol contribution or all of those at once. The tax analysis should begin with the documents: token allocation agreement, founder agreement, vesting schedule, lock-up, cliff, transfer restrictions, forfeiture and any service obligations.
Timing is central. A grant before moving to Spain, vesting during the Beckham years and sale after appreciation can span several tax periods and several legal categories. If a vesting tranche is compensation for services performed during the regime, the employment or activity-income analysis may be relevant. If the later sale reflects appreciation after the token was already received or recognised, the capital-gain analysis is separate.
The valuation problem is also real. Many tokens are illiquid, thinly traded, subject to lock-up, or listed on venues with inconsistent prices. The file should record why a particular euro value is used at grant, vesting, delivery or sale. For private or pre-launch tokens, this may require a defensible valuation memo rather than a price copied from a public exchange.
DAO and advisory compensation
DAO and advisory payments often arrive with casual labels: "grant", "bounty", "retroactive reward", "advisor allocation" or "community incentive". Those labels are not decisive. The review has to ask what the person did, who or what paid, whether there was a service agreement, whether the person had recurring obligations, whether the activity is organised as a business, and whether the income is connected to the qualifying Beckham route.
A DAO contributor who performs regular engineering, legal, product or growth work may look economically closer to a consultant than to a passive investor. A retroactive airdrop to users of a protocol may look very different. A strategic advisor who receives a token allocation subject to vesting may sit closer to an equity-compensation style analysis, but with token-specific valuation and reporting questions. The Beckham result turns on those facts, not on Web3 vocabulary.
Later token sale or swap
The later disposal is where many plans break. AEAT materials on virtual currencies describe investor sales as generating capital gains or losses by comparing transfer and acquisition values. AEAT also treats the exchange of one virtual currency for another as a swap that can generate a gain or loss. That means a token-to-token move can be a tax event even if no euros hit the bank account.
For Beckham purposes, the later sale or swap of tokens usually belongs in the capital-gain analysis, not the flat-rate work-income bucket. The acquisition value may be the amount already recognised as income when the token was received or vested, but the later appreciation is its own event. This is the same core distinction that appears in traditional stock option and RSU planning, but tokens add more volatility, custody and valuation friction.
Reporting and Modelo 721
Token compensation also raises reporting questions. Modelo 721 is Spain's informative declaration for certain virtual currencies situated abroad, with a filing window from 1 January to 31 March of the year following the year to which the information relates. Where tokens are held through foreign exchanges, foreign custodians or other non-Spanish custody structures, the reporting analysis must be reviewed separately from the income-tax treatment.
The key point is separation. A favourable Beckham answer on the income side does not mean there is no information return. A conclusion that a later sale is foreign-source or outside a particular tax charge does not answer whether a year-end foreign-held token balance is reportable. For a deeper reporting guide, see our page on Beckham and Modelo 721 crypto reporting.
Evidence to prepare before moving
The strongest Web3 files are built before relocation. The goal is to make the Spanish analysis auditable, not just plausible. Prepare:
- Employment, consulting, founder, DAO or advisory agreements describing the services and payment terms.
- Token grant documents, vesting schedules, cliffs, lock-ups, forfeiture and transfer restrictions.
- Wallet and exchange records showing receipt dates, quantities, custody and later disposals.
- Valuation support for each relevant date, especially for illiquid, private or pre-launch tokens.
- Prior-country tax filings and accounting records, especially for US persons and founders with corporate structures.
- A first-year calendar tying the move date, Modelo 149 election, vesting dates, year-end balances and Modelo 721 review together.
Common mistakes
The first mistake is assuming that "paid in crypto" means "crypto tax" rather than work income. The second is assuming the opposite: that every token received by a founder is work income taxed at 24%. Both shortcuts can be wrong. The third mistake is ignoring timing. A grant before arrival, vesting during the regime and sale afterwards are not one event.
The fourth mistake is treating a DAO as legally invisible. Someone must classify the services, payer, rights and records. The fifth is waiting until the tax filing season to build valuation evidence. By then, token prices, exchange records and governance documentation may be harder to reconstruct. The sixth is forgetting reporting. Modelo 721 and other crypto information returns live next to the Beckham analysis; they do not disappear because the regime is available.
Frequently asked questions
Can token compensation fall under the 24% Beckham rate?
Possibly, where the token is genuinely received as qualifying employment or activity income during the years the regime applies. The facts, contract, payer, role and timing need to be reviewed.
Is a later token sale taxed the same way as the original token receipt?
Generally no. The original receipt may be work income, while the later sale or swap is usually a separate capital-gain event.
Are DAO grants treated as employment income?
Not automatically. The label "DAO grant" is not decisive. The review must identify the services, obligations, payer, legal relationship, timing and whether the activity fits the qualifying Beckham route.
Does a lock-up change the answer?
It can affect valuation and timing analysis. A lock-up does not remove the need to classify the event, but it may be relevant when deciding what value is recognised and when.
Do I need to review Modelo 721 if I am under Beckham?
Yes. Modelo 721 is a separate information-return issue for certain foreign-held virtual currencies. Beckham does not replace that review.
General information, not legal or tax advice. Sources reviewed July 2026: AEAT guidance on Modelo 149 and the special displaced-worker regime; AEAT IRPF guidance on virtual-currency gains and token-for-token exchanges; BOE Order HFP/886/2023 on Modelo 721; Article 93 of Law 35/2006. Token compensation is highly fact-specific and should be reviewed before relocation.