Beckham Law and stock options / RSUs: 24% vs the general scale

For employees of tech and finance companies, equity is often the part of the package that decides whether the Beckham Law is worth it. The reason is simple: in Spain, RSUs and stock options are employment income, and employment income is exactly what the regime taxes at a flat 24%. This article puts numbers on that comparison against the general scale. For the traps around vesting, bonuses and selling the shares, see RSUs, stock options and bonuses under the Beckham Law.

This article is general information, not tax advice.

When equity becomes taxable income

The Spanish rule follows the moment you receive something of value:

• RSUs: taxable when the shares are delivered at vesting, on their value that day.
• Stock options: taxable on exercise, on the difference between the market value and the exercise price.
• Bonuses: taxable when they are paid or become due.

In every case the result is employment income of that tax year. Under the regime, the employment income you earn while in it is taxed in Spain at 24% up to €600,000 and 47% above, wherever the work was done.

Why the general scale hurts more in a vesting year

The general regime taxes employment income on a progressive scale: the state scale plus your region’s. The more you earn in a year, the higher the rate on the next euro, and a big vest lands entirely on top of your salary. Under Beckham the rate on that extra income stays at 24% until you reach €600,000.

That is why the saving grows faster than the income. A salary alone may show a modest difference. The same salary plus a vest can show a large one.

An illustrative case

The numbers below are round and invented, for illustration only.

Sara is relocated to her company’s Madrid office on a Spanish contract, with a salary of €150,000. Her RSUs vest unevenly. Three possible years, run through our savings calculator (single taxpayer, all of it treated as employment income, Madrid scale):

• Salary only, €150,000: about €52,200 under the general regime against €36,000 under Beckham. About €16,200 less.
• Salary plus a €100,000 vest, €250,000: about €95,100 against €60,000. About €35,100 less.
• Salary plus a €500,000 vest, €650,000: about €273,500 against €167,500, because the €50,000 above €600,000 pays 47%. About €106,000 less.

Madrid has the lowest regional scale, so the same years in other regions show larger differences. Try your own figures in the calculator; the savings by region page shows the spread.

Two caveats on these numbers. The calculator treats all the equity as ordinary employment income. The general regime has specific rules for some equity, such as a reduction for income generated over more than two years and an exemption for shares delivered to employees under conditions. The calculator does not model them, and whether they change the comparison depends on your plan: confirm it with the professional. Under the regime the rules for equity are not the same as in the general regime, which is why the diagnosis does not offer Guided filing when you have stock options or RSUs.

Summary

Where it gets complicated

Vesting that started before the move. An RSU grant usually vests over several years. Income from work done before the move is not treated as earned in Spain under the regime, and for equity plans generated partly before the move the Directorate-General for Taxes applies a proportional criterion (binding ruling V0813-23): only the part that corresponds to the time worked in Spain is taxed here. The country where you worked before may tax its part. How the dates of grant, vesting and exercise split in your case is something to confirm with the professional before the move, not after the first vest.

The €600,000 line. It works per tax year. A year that stacks salary, bonus, a large vest and an option exercise can cross it, and the excess pays 47%. When you control the timing (options, some sales), spreading events across years keeps more of the income at 24%.

The end of the regime. The regime covers the first tax year you are resident in Spain and the next five. A vest or exercise the year after it ends is taxed on the general scale. Map your vesting calendar against those six years.

Selling the shares. Selling is not employment income. Gains on shares of a foreign company are generally outside Spanish tax while you are in the regime; after it ends they are taxed on the savings scale. The country of the company may have its own rules.

A salary that does not justify the regime. At moderate salaries the general regime can be cheaper in the years without a vest, because Beckham gives up personal and family allowances. The decision covers all six years, not just the best one.

What to prepare before you file Modelo 149

1. The grant agreements: RSUs, options, exercise prices, vesting schedule.
2. A year-by-year view of expected employment income during the six tax years, marking the years near €600,000.
3. Your work history during each vesting period: where you worked and when.
4. The date of your Spanish Social Security registration or certificate of coverage, which starts the 6-month window for Modelo 149. The deadline calculator gives you the exact day.
5. If you are not an EU citizen, the residence and work permit. It is a separate procedure from the tax election, and it does not pause the six months.

Where to start

The free diagnosis asks about equity. When you tick stock options or RSUs, it does not offer Guided filing and points you to a professional, because these dates need to be read together. The guide to the regime explains the rest of the requirements. If you already know equity is a large part of your package, you can ask for a review: we will look for a registered lawyer or tax advisor to take the case, with a fixed quote before you commit to anything.

Sources

• Law 35/2006 on Personal Income Tax, art. 93 (consolidated text, BOE)
• Royal Decree 439/2007, Personal Income Tax Regulation, arts. 113 to 120 (BOE)
• Directorate-General for Taxes, binding ruling V0813-23
• Royal Decree 1155/2024, Regulation of the Foreigners Act (BOE)
• Order HFP/1338/2023 approving Modelo 149 and Modelo 151 (BOE)