RSUs, stock options and bonuses under the Beckham Law: what nobody tells you

For a tech employee, salary is only part of the package: RSUs, stock options and bonuses can be half the compensation. And that is exactly where the Beckham Law can shine — or produce five-figure surprises if the timing isn’t planned.

The general rule: equity is salary

Under the regime, employment income is taxed at 24% up to €600,000 per year and 47% on the excess. RSUs are taxed as employment income at vesting; options at exercise (on the spread between value and strike). A €200,000 vest that would cost around 47% at the top general rate costs 24% under Beckham: ~€46,000 of difference in a single year.

Trap 1: vesting that crosses borders

RSUs vest over years. If part of the vesting period corresponds to work performed in another country before the move, that country may claim its share (the US, UK and Germany do so systematically), and Spain’s treatment of the “imported” part requires careful treaty and source-rule analysis.

Practical advice: before moving, map your vesting calendar — which tranches vest when, and which period of work they correspond to. Sometimes shifting the relocation a few months radically changes the combined bill.

Trap 2: the bonus year

Last year’s bonus usually pays out in March. If you move in January and receive, in March, a bonus earned for work performed abroad the previous year, its treatment depends on the treaty and where the work was done. Badly planned, you can end up double-withheld and spend months clawing it back.

Trap 3: the €600,000 threshold

The 47% on the excess turns “accumulation years” into a problem: when one tax year concentrates salary + bonus + a large vest + an option exercise, crossing the threshold is easy. Spreading option exercises across tax years, or coordinating sales and vests, can keep each year under it.

Trap 4: selling the shares

The 24% is for employment income. When you sell vested shares, the gain is a capital gain:

• Foreign-source (shares of your US parent, held abroad): generally not taxed in Spain under the regime — one of Beckham’s great quiet advantages. Caveat: the source country may have its own rule.
• Spanish-source: taxed on the savings scale.

This makes the regime’s 6 years a strategic window for realising gains that would later, as an ordinary resident taxed on worldwide income, cost up to 30%.

What to do before signing your relocation

1. Full inventory: granted RSUs, vesting calendar, options and strike prices, ESPP.
2. A year-by-year simulation of the regime’s 6 tax years, flagging the years that brush €600,000.
3. Coordination with your origin country for the “mixed” vesting tranches.
4. A sales plan: what to realise during the regime, and what after.

This is exactly the planning we do in the 6-year tax plan. If your package includes equity, advice isn’t a cost — it pays for itself with the first well-timed vest.