Compared
Beckham Law vs Italy’s regime for impatriates: a flat 24% or half your salary exempt?
Spain’s impatriate regime compared with Italy’s reformed regime for impatriate workers (in force since 2024): exemption vs flat rate, five years vs six, the qualification and four-year commitment Italy requires, foreign income, wealth-type taxes and which profile each one suits.
Javier López Founder · holds the Beckham regime · not a lawyer
Italy rewrote its regime for impatriate workers for arrivals from 2024. The old version, with 70% or 90% of salary exempt, is gone; the new one exempts 50% of employment and self-employment income up to €600,000 a year, for five years, with a qualification requirement and a four-year commitment. Against Spain’s flat 24% the comparison is closer than most people expect, and it turns on things other than the headline rate.
Change announced for 2027. Legislative Decree 117/2026, Italy’s new income tax code, repeals article 5 of Legislative Decree 209/2023 from 1 January 2027 and moves the regime into the new code (Normattiva). The conditions described on this page are those in force in 2026; the conditions from 2027 are not verified yet.
Side by side
| Spain (art. 93 LIRPF) | Italy (impatriates, from 2024) | |
|---|---|---|
| Mechanism | Flat 24% on employment income up to €600,000, 47% above; no allowances | 50% of employment and self-employment income exempt, up to €600,000 of income; the rest taxed at ordinary progressive rates plus regional and municipal surcharges |
| Extra for families | None | 60% exempt with a minor child, or a child born or adopted during the regime |
| Duration | Up to six tax years | Five tax years |
| Commitment | None | Reside at least four years; early departure claws back the benefit |
| Who qualifies | Any employee, posted worker, remote employee of a foreign employer, director, ENISA entrepreneur, start-up professional | Workers with a high qualification or specialisation, working mainly in Italy |
| Prior non-residence | Five tax years | Three tax years; six or seven if working for the same employer or group as before the move |
| Foreign non-employment income | Outside Spanish tax | Taxed on a worldwide basis, with foreign tax credits |
| Wealth-type taxes | Wealth tax on Spanish assets; large-fortunes tax above €3 million | IVIE on foreign property and IVAFE on foreign financial assets; RW reporting |
| Application | Modelo 149 within six months of Social Security registration | Elected through the employer’s withholding or the tax return; no separate six-month filing |
Foreign rules summarised as we understand them in September 2026; the 2027 conditions are pending verification. Confirm the Italian side with a local adviser.
Where Italy wins
The effective rate on salary, for most expatriate pay levels. Exempting half of a €150,000 salary and taxing the rest progressively typically produces an effective rate in the high teens, below Spain’s 24%. With a minor child the exemption rises to 60%. Italy also has no equivalent of Spain’s six-month trap: the regime is applied through the employer or claimed on the return.
Where Spain wins
Everything outside the salary. Under the Spanish regime, foreign dividends, capital gains and rental income are outside Spanish tax, and no foreign-asset reporting applies. Italy taxes all of it, adds the IVIE and IVAFE on foreign property and financial assets, and requires RW reporting. For someone with a portfolio, property abroad or a company at home, that difference can outweigh the salary rate.
Spain also asks no questions about qualification, requires no commitment to stay, lasts a year longer, and takes remote employees of foreign companies explicitly. Italy’s regime is designed around work performed mainly in Italy for the benefit of the Italian economy, and the qualification requirement excludes a good part of the people who would qualify in Spain.
The fine print on both sides
- Italy’s four-year commitment is enforced with a clawback: leave early and the benefit is recovered with interest. A three-year assignment does not fit.
- Italy’s longer look-back for the same employer: if you move within your group, the required prior non-residence stretches to six or seven years. Spain requires five in all cases.
- Spain taxes all employment income including days worked abroad, and gives no allowances, so at moderate salaries or with several dependants the ordinary IRPF can be cheaper. Our calculator flags it.
- Neither regime gives a clean treaty residence position for withholding on home-country income; Spain’s is the weaker one, since you are taxed as a non-resident.
- Italy also offers a lump-sum regime for new residents with large foreign income (a fixed annual charge, currently in the hundreds of thousands of euros, on all foreign income for up to fifteen years). Spain has nothing comparable.
Which one for whom
- Salary is most of your income, you have a high qualification and you will stay four years or more: Italy, on the numbers.
- Meaningful income or assets outside employment: Spain, and it is not close.
- Remote employee of a foreign company, or a role without a formal qualification: Spain; the Italian regime may not be available.
- Uncertain about the length of stay: Spain, with no commitment and no clawback.
Run the Spanish side with our calculator and diagnosis; have the Italian side modelled by a local adviser with the regional and municipal surcharges of the city you would live in.
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Frequently asked questions
Which regime taxes salary less, Spain or Italy?
On salary alone, Italy’s regime often produces the lower effective rate: half of employment income up to €600,000 is exempt and the rest is taxed at progressive rates, which at typical expatriate salaries lands below 24%. Spain’s flat 24% applies to the whole salary with no allowances. The picture changes once foreign income, duration and eligibility are included.
How long does each regime last?
Spain: the tax year of the move plus five, up to six years. Italy: five tax years, with a commitment to remain resident for at least four; leaving early triggers a clawback.
Does Italy tax my foreign dividends and property?
Yes. Italy taxes residents on worldwide income, so foreign dividends, gains and rents are taxed (with credits for foreign tax), and the IVIE and IVAFE wealth-type taxes apply to foreign property and financial assets, with RW reporting. Under the Spanish regime those foreign items are outside Spanish tax.
Who cannot use the Italian regime?
People without a high qualification or specialisation as defined by the rules, those who were Italian resident in the three previous tax years (six or seven if they keep working for the same employer or group), and anyone unwilling to commit to four years of residence.
Want to know where you stand?
Five minutes, no sign-up: verdict, deadline and what it is worth. Or ask to be matched with a registered professional for a fixed quote.
General information, not tax or legal advice. The regime has cumulative requirements and a 6-month deadline with no extensions; whether it fits you depends on your full situation. Foreign rules are summarised as we understand them in September 2026 and change often. Confirm the other country’s side with a local advisor before deciding.
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