People deciding where in southern Europe to relocate often narrow the field to three countries with headline tax regimes for new arrivals: Spain, Portugal and Italy. Each has built a special regime to attract talent, founders and mobile professionals, and each is structured very differently. The trouble is that these regimes are frequently described in slogans — "flat 24%", "tax-free pensions", "€100,000 and you're done" — that no longer match reality, because all three have changed materially in recent years. This page sets out, in general terms, how Spain's Beckham regime compares with Portugal's and Italy's current options, and the kind of person each tends to suit. None of it is a substitute for advice on your own facts.
On this page
Spain — the Beckham regime Portugal — from NHR to IFICI Italy — impatriati and the flat tax Side-by-side comparison Who each regime tends to suit Why the slogans are dangerous How to actually choose Frequently asked questions
"Clients rarely choose the wrong country because of the headline rate — they choose it because the slogan didn't match their income. Map the income first, then compare."
— Jacob Salama · International Tax lawyer, Ilustre Colegio de Abogados de Málaga (nº 11294)
Spain — the Beckham regime
Spain's special regime for inbound workers, universally known as the Beckham regime after the footballer who made it famous, is set out in Article 93 of the Personal Income Tax Act. In broad terms, a qualifying individual who becomes tax resident in Spain can elect to be taxed largely as a non-resident for a set period: the general base of income is taxed at a flat 24% up to €600,000 per year, with 47% applying above that ceiling. The regime typically runs for the year of arrival plus the following five — so roughly six years in total — after which the individual moves onto the ordinary progressive scale.
Since the Startup Act (Law 28/2022) widened access, the regime reaches not only employees but also certain entrepreneurs, highly qualified professionals, remote workers and administrators of start-ups, subject to conditions. The key feature is that qualifying employment and activity income is deemed obtained in Spain and pulled into the favourable flat rate, while savings income — dividends, interest and many capital gains — is analysed separately and does not simply become "24% income". For a full walk-through of eligibility and process, see our Beckham master guide.
Spain's pitch is a stable, predictable rate on earned and activity income for a defined window — not a blanket exemption of foreign wealth.
Portugal — from NHR to IFICI
For a decade Portugal's non-habitual resident (NHR) regime was the reference point for expatriates in southern Europe. It offered a reduced flat rate on certain Portuguese-source professional income and, crucially, generous exemptions on many categories of foreign-source income, including for some pensioners. That regime was closed to new entrants during 2024. Individuals who were already registered under NHR generally keep their remaining benefit for its run-off period, but new arrivals can no longer opt into the original scheme.
In its place, Portugal introduced a successor commonly referred to as IFICI (the tax incentive for scientific research and innovation), sometimes marketed as "NHR 2.0". This successor is considerably narrower: it is aimed at people carrying on qualifying activities — broadly certain research, innovation, teaching and highly qualified roles within eligible sectors and entities — rather than at any well-paid arrival. Where it applies, it can offer a reduced rate on qualifying employment and self-employment income and favourable treatment of some foreign income, but the eligibility gate is the decisive point, and the detailed rules are still bedding in. Anyone comparing Portugal today should confirm whether their specific activity qualifies, rather than assuming the old NHR is still available.
Italy — impatriati and the flat tax
Italy runs two quite different regimes that are often confused, and it helps to separate them clearly.
The first is the impatriati (impatriate workers) regime, aimed at people who move their tax residence to Italy to work. Rather than a flat rate, it works as a partial exemption: a defined percentage of qualifying employment or self-employment income is excluded from tax, so only the remaining portion is taxed on the ordinary Italian scale. The exemption applies for a limited number of years and is subject to conditions on prior non-residence, the location of the work and an income cap; the exact percentage and cap have been tightened in recent reforms, so the current figures must be checked. The effect is to lower the effective rate on earned income for incoming workers for a defined window.
The second is the flat-tax regime for high-net-worth new residents. This lets a qualifying individual who becomes Italian resident pay a substitute flat tax on all foreign-source income — historically €100,000 per year, with a higher figure (reported at €200,000) applying to individuals who transferred their residence after a certain date — regardless of how large that foreign income actually is. Italian-source income is still taxed normally, and the regime lasts for a limited number of years. Family members can often be added for a smaller additional flat amount. This is fundamentally a wealth-migration tool for people with substantial foreign income, not an incentive for local earners.
Side-by-side comparison
The table below is a simplified, general overview to show the shape of each regime — not a set of figures to rely on. Rates, caps, percentages, durations and eligibility conditions differ by year and by individual circumstances, and all three countries have amended these rules recently.
| Feature | Spain — Beckham | Portugal — IFICI (NHR successor) | Italy — impatriati / flat tax |
|---|---|---|---|
| Core mechanism | Flat rate on general-base income | Reduced rate for qualifying activities | Impatriati: partial exemption of earned income · Flat tax: fixed annual charge on foreign income |
| Headline number | 24% up to €600,000; 47% above | Reduced rate on qualifying income (confirm current rate) | Impatriati: % of income exempt · Flat tax: ~€100,000/yr (higher for later arrivals) |
| Who it targets | Inbound employees, entrepreneurs, qualified remote workers | Research, innovation, teaching & highly qualified roles | Impatriati: incoming workers · Flat tax: high-net-worth new residents |
| Foreign income | Savings income analysed separately; qualifying activity deemed Spanish | Some foreign income may be favourably treated (activity-dependent) | Impatriati: focused on Italian-worked income · Flat tax: foreign income covered by the fixed charge |
| Typical duration | ~6 years (arrival year + 5) | Limited period (confirm) | Impatriati: limited years · Flat tax: up to a capped number of years |
| Status of old scheme | Active, widened by Startup Act 2022 | Original NHR closed to new entrants in 2024 | Both active but recently tightened |
| Best conceptual fit | High-earning workers & founders wanting a predictable earned-income rate | Specialists in eligible research/innovation activities | Impatriati: incoming employees · Flat tax: the globally wealthy |
The specific rates, percentages, caps and durations above are indicative only and change frequently. They must be confirmed for the relevant year and for your personal circumstances before any decision.
Who each regime tends to suit
Because the three regimes are built on different logics, the honest answer to "which is best?" is almost always "best for whom, and for what income?". Some broad patterns emerge, all of which need confirming against current rules and your own facts.
- Spain (Beckham) tends to suit high-earning employees, founders and qualified remote workers who want a predictable flat rate on earned and qualifying activity income for a defined window, and who are comfortable that savings income is treated separately. It is attractive precisely because the effective rate on the general base stays close to 24% across a wide band. For self-employed applicants specifically, whether the flat rate reaches their income depends on classification — see our note on whether the 24% applies to self-employed income.
- Portugal (IFICI) tends to suit people whose work genuinely falls within the eligible research, innovation, teaching or highly qualified categories. For those individuals it can be very favourable; for everyone else, the closure of the original NHR means Portugal is no longer the near-universal expat haven it was, and the comparison should not rest on the old rules.
- Italy (impatriati) tends to suit incoming employees and independent professionals who will actually work in Italy and can benefit from the partial exemption on earned income for a limited period.
- Italy (flat tax) tends to suit high-net-worth individuals with large foreign-source income — investment returns, foreign business income, worldwide portfolios — for whom a fixed annual charge on all foreign income is efficient, and who are less concerned with the treatment of Italian-earned income.
A useful contrast is Spain against Portugal specifically, where the earned-income focus of Beckham sits beside the activity-gated successor to NHR; we look at that pairing in more depth in our Beckham vs Portugal NHR comparison.
Why the slogans are dangerous
Every one of these regimes is routinely described in a phrase that no longer tells the whole story. "Portugal is tax-free for expats" ignores the 2024 closure of NHR to new entrants. "Italy is €100,000 flat" ignores both the higher figure for later arrivals and the fact that Italian-source income is taxed normally on top. "Spain is just 24%" ignores the €600,000 ceiling, the separate treatment of savings income, and the six-year limit. Relying on any of these slogans to choose a country — and to move a family — is how expensive surprises happen.
A regime is only as good as its fit with your specific income, nationality and plans. The headline number is the start of the analysis, never the end of it.
There are also cross-cutting issues the headline rates never mention: wealth taxes and solidarity levies differ sharply between and within these countries; nationals of the United States carry citizenship-based taxation and treaty complications wherever they go; social-security position, exit taxes from the departure country, and the treatment of pensions, equity and capital gains all vary. Two people with identical salaries can reach opposite conclusions once these layers are added.
How to actually choose
Choosing between Spain, Portugal and Italy is not really a contest between three numbers; it is a matching exercise between your circumstances and the design of each regime. A sensible process usually runs in this order.
- Map your income first. Separate earned and activity income from investment and foreign-source income, because the three regimes reward these very differently — Spain and Italy's impatriati favour earned income, Italy's flat tax favours foreign wealth, Portugal's successor favours specific activities.
- Check eligibility honestly. Portugal's successor turns on qualifying activities; Italy's regimes turn on prior non-residence and other conditions; Spain's Beckham turns on the route by which you arrive and work. Assuming you qualify is the most common early mistake.
- Add the hidden layers. Wealth tax, solidarity levies, social security, exit taxes and — for US persons — citizenship-based taxation can change the ranking entirely.
- Confirm the current year's rules. All three regimes have changed recently and may change again; any comparison older than a year should be treated with suspicion.
- Model, then decide. Only once your real income mix is run against the current rules of each candidate country does a genuine ranking appear — and it is frequently different from the one the slogans suggest.
This is exactly the kind of comparison that should be done before signing a lease or resigning a job, not reconstructed afterwards from a tax return. If Spain is on your shortlist, the natural next step is to check whether the Beckham route fits your profile and how the election works in practice.
Frequently asked questions
Which of the three is cheapest?
There is no universal answer. Spain's flat 24% may win for a high-earning worker; Italy's flat tax may win for someone with very large foreign income; Portugal's successor may win for an eligible researcher. It depends entirely on your income mix, and all figures must be confirmed for the current year.
Can I still get Portugal's old NHR?
Not as a new entrant — the original NHR was closed to new arrivals during 2024. A narrower successor (IFICI) exists for qualifying activities, so you would need to check whether your activity qualifies.
Is Italy's €100,000 flat tax really flat?
It is a fixed annual charge on foreign-source income, but Italian-source income is taxed normally on top, and a higher figure applies to individuals who moved after a certain date. It suits high-net-worth people with large foreign income rather than local earners.
How long does Spain's Beckham regime last?
Broadly the year of arrival plus the following five — around six years — after which the ordinary progressive scale applies. See our Beckham master guide for detail.
Does this page give me a recommendation?
No. This is general information only and cannot recommend a country for your situation. A real comparison requires modelling your specific income against each regime's current rules.
General information, not tax advice. This page describes Spain's Beckham regime (Article 93 of the Personal Income Tax Act, as amended by Law 28/2022), Portugal's NHR and its IFICI successor, and Italy's impatriati and flat-tax regimes in general terms only. Rates, thresholds, exemption percentages, caps, durations and eligibility rules change frequently, differ by individual circumstances, and must be confirmed for the relevant year and for your own facts. No personalised advice is given and no lawyer–client relationship is created by this page.