Beckham Law vs Portugal's NHR (ended), Italy's impatriati and Europe's other expat tax regimes: 2026 comparison

Javier López Founder · holds the Beckham regime

Published: 14 September 2026 Updated: 22 September 2026 11 min read

comparisonEuropePortugalItalyUnited KingdomBelgium

Verified as of 14 September 2026; the United Kingdom and Belgium rows were added and verified on 22 September 2026. These regimes change often, sometimes in the annual budget. Every fact below comes from the country’s tax authority or official legislation, or from a large advisory firm’s page dated 2025 or 2026; anything we could not verify from such a source is left out. Check the source before you rely on a figure. Everything about 2027 (the Dutch 27%, Italy’s move to a new code, Sweden’s draft bill) is announced or proposed, not in force, and is pending verification when it applies.

This article is general information, not tax advice.

Why compare at all

Spain’s Beckham Law is one of several European regimes that lower the tax of people who move in to work. They look similar in headlines and are very different in practice: some tax a flat rate, some exempt part of the income, some pay a tax-free allowance; some take any employee, others only researchers, listed activities or salaries above a threshold. If you can choose where to move, the regime that fits your job and your assets matters more than the headline rate.

The table

Country and regime	Status in 2026	How the benefit works	Duration	Cap or threshold	Who it applies to	Last relevant change
Spain · special regime for impatriates (art. 93 LIRPF)	Open	Employment income taxed at a flat 24%, 47% above €600,000; most foreign non-employment income outside Spanish tax	Year of residence plus the next 5	No salary threshold; 47% above €600,000	Employees (Spanish contract, posted, remote for a foreign employer), directors, ENISA entrepreneurs, highly qualified professionals for start-ups; not Spanish resident in the previous 5 years; Modelo 149 within 6 months	Law 28/2022 and RD 1008/2023 (from 2023)
Portugal · NHR	Closed to new entrants since 1/1/2024	Holders keep it for the rest of their 10 years	10 years from residence	n/a	Transitional rule: residence conditions met by 31/12/2023, or residence by 31/12/2024 with a job, lease, school enrolment or visa arranged by the end of 2023	Law 82/2023
Portugal · IFICI (art. 58-A EBF)	Open	Flat 20% on employment and business income from qualifying activities; foreign income generally exempt (35% if from blacklisted jurisdictions)	10 consecutive years	No income cap	Not resident in the previous 5 years; one of seven listed activity types (research, higher education, certified start-ups, qualified jobs in some companies…); never benefited from the NHR; register by 15 January of the following year	Portaria 352/2024/1, amended by Portaria 52-A/2025/1
Italy · impatriati (art. 5 D.Lgs. 209/2023)	Open; art. 5 repealed from 1/1/2027 and moved into the new income tax code (conditions from 2027 pending verification)	50% of income produced in Italy exempt (60% with a minor child); employment and professional income	Year of the move plus 4	Income up to €600,000 a year	Not resident in the previous 3 years (6 or 7 with the same employer or group); high qualification; working mostly in Italy; 4-year commitment with clawback	D.Lgs. 117/2026 (new code); Law 132/2025 added an AI research route
Greece · art. 5C Income Tax Code	Open	50% of Greek-source employment or business income exempt	7 tax years	No cap found	Not Greek resident in 5 of the previous 6 years; moving from the EU/EEA or a cooperating country; Greek employer, Greek branch or self-employed in Greece; stay at least 2 years	Law 5222/2025 removed the new-position requirement
Netherlands · 30% ruling	Open	Employer pays up to 30% of salary as a tax-free allowance	Up to 5 years	2026: maximum allowance €78,600 (salary €262,000); minimum taxable salary €48,013 (€36,497 under 30 with a master’s)	Employees recruited from abroad; lived more than 150 km from the Dutch border for more than 16 of the 24 months before	2025 Tax Plan: 27% from 2027; partial foreign taxpayer status abolished
Belgium · special regimes for inpatriate taxpayers and inpatriate researchers (art. 32/1 and 32/2 CIR 92)	Open since 1/1/2022	Employer may reimburse up to 35% of gross pay as its own expenses, tax-free (30% until 2024); certain relocation costs on top	Up to 5 years, extendable by 3	Taxpayers: pay above €70,000 a year (€75,000 until 2024); no euro cap on it since 2025 (it was €90,000). Researchers: no pay threshold	Employees recruited directly from abroad by a Belgian employer or seconded within a group; in the 60 months before, not a Belgian inhabitant, not living within 150 km of the Belgian border and not subject to Belgian non-resident tax. Researchers: qualifying science or engineering degree or 10 years’ relevant experience, at least 80% of time on research. The employer applies within 3 months of the start	Law of 18/12/2025, for pay from 1/1/2025 (35%, €70,000, cap removed); SPF Finances circular 2026/C/51
France · régime des impatriés (art. 155 B CGI)	Open	Relocation bonus exempt (actual, or flat 30% of net pay); foreign-work portion exempt; 50% exemption on certain foreign passive income	Until 31 December of the 8th year after starting	Total exemption up to 50% of pay, or the foreign-work part up to 20% of taxable pay	Employees and managers called from abroad; not French resident in the previous 5 years	BOFiP update of 11/08/2025 (people who applied from abroad also qualify)
United Kingdom · 4-year foreign income and gains (FIG) regime	Open since 6/4/2025; the non-dom remittance basis was abolished the same day	Foreign income and gains exempt from UK tax when claimed; UK employment income taxed normally. Overseas Workday Relief (OWR) exempts pay for work done outside the UK	First 4 tax years of UK residence	FIG: none stated. OWR: the lower of 30% of the qualifying employment income or £300,000 a year	UK tax residents who were not UK resident for at least 10 consecutive tax years before; claimed year by year on the Self Assessment return; claiming loses the personal allowance and the capital gains annual exempt amount for that year	Remittance basis abolished from 6/4/2025; HMRC helpsheet HS266 updated 18/5/2026
Cyprus · s. 8(23A) and 8(21A)	Open	50% of employment pay exempt; or 20% (up to €8,550) for those who do not qualify	17 years (50%); 7 years (20%)	50% only for pay above €55,000 a year	50%: first Cyprus employment from 2022, not resident for 15 consecutive years before	2026 tax reform changed the income tax bands; KPMG’s April 2026 guide describes these exemptions unchanged
Luxembourg · inpatriate regime	Open	50% of gross annual pay exempt	8 years after the year of arrival	Pay counted up to €400,000; fixed pay at least €75,000	Highly qualified, hired or seconded from abroad; not resident, within 150 km or taxed in Luxembourg in the previous 5 years	Reform in force 1/1/2025
Denmark · researcher and key employee scheme	Open	Salary taxed at a flat 27% plus the 8% labour-market contribution	Up to 7 years	2026: average monthly pay at least DKK 65,400	Approved researchers and highly paid key employees	Threshold lowered from 1/1/2026
Sweden · expert tax relief	Open	25% of pay exempt from income tax	7 years	2026: monthly pay of at least SEK 88,801, or qualifying as an expert on merit	Not a Swedish citizen; not resident in the previous 5 years; Swedish employer or Swedish establishment; apply within 3 months	7 years since 2024; draft bill for 30% from 2027
Finland · key employee tax at source	Open	Flat 25% final tax on cash salary	First 84 months (60 for Finnish citizens)	Cash salary at least €5,800 a month	Not resident in the previous 5 calendar years; apply within 90 days	New act from 1/1/2026: rate cut from 32% to 25%
Austria · Zuzugsbegünstigung (§103 EStG)	Open	30% of income from scientific work exempt	5 years from arrival	None stated	Scientists and researchers moving their centre of life to Austria; apply within 6 months	Regulation of 2016

Sources for each row are listed at the end of the article.

Three ways these regimes work

A flat rate. Spain, Portugal’s IFICI, Finland and Denmark tax the covered income at a single rate. The saving depends on how high the ordinary scale would have been, so it grows with the salary.

An exemption. Italy, Greece, Cyprus, Luxembourg, Sweden and Austria exempt part of the income and tax the rest on the ordinary scale. Half of a salary taxed progressively can land below a flat 24% or above it, depending on the salary and the local scale. The United Kingdom exempts a different thing: foreign income and gains, while pay for work done in the UK stays on the ordinary scale.

An allowance. The Netherlands, Belgium and France work through a tax-free part of the pay: an allowance paid by the employer in the Dutch and Belgian cases, an exempt relocation bonus and foreign-work portion in the French one.

Where Spain stands out

Who gets in. Any employee qualifies, including a remote employee of a foreign company, with no salary threshold and no list of professions. Several regimes above require a local employer, a qualification, a listed activity or a minimum salary.
Foreign investment income. Under the Beckham Law, most income from outside Spain other than employment stays outside Spanish tax, and the Modelo 720 does not apply. The UK’s FIG regime also exempts foreign income and gains, but for four years, only after ten years away, and at the cost of the personal allowance.
No commitment to stay. There is no minimum stay or clawback, unlike Italy’s four-year commitment or the declaration to stay two years that Greece asks for.

Where Spain is weaker

The rate is not the lowest. Portugal’s IFICI rate is lower, and exemption regimes can produce a lower effective rate on a salary.
No allowances. Spain gives up personal and family allowances, so with a moderate salary or a family the ordinary scale can be cheaper, see does it pay off under €60,000.
A strict deadline. Modelo 149 within six months of your Social Security registration, with no extension.
Six years, not ten or seventeen. Portugal’s IFICI lasts ten years, Cyprus’s 50% exemption seventeen.

What is changing

United Kingdom: the non-dom remittance basis ended on 6 April 2025, replaced by the 4-year FIG regime and a capped Overseas Workday Relief.
Belgium: for pay from 1 January 2025, the tax-free allowance rose from 30% to 35%, the €90,000 cap was removed and the pay threshold fell from €75,000 to €70,000 (Law of 18 December 2025).
Netherlands: the 30% becomes 27% from 2027 under the 2025 Tax Plan.
Italy: the impatriate regime moves into the new income tax code from 1 January 2027; its terms from that date should be checked when the code applies.
Sweden: a draft bill proposes a 30% exemption from 2027; it is not law as of this update.
Finland: the rate fell to 25% from 1 January 2026.
Denmark: a lower salary threshold for jobs starting from 1 January 2026.

In more depth

We compare Spain with four of these regimes in detail: Portugal’s IFICI, Italy’s impatriate regime, Greece’s 50% exemption and the Dutch 30% ruling. Shorter comparisons cover France, Cyprus, Luxembourg and Denmark, Sweden and Finland. If you are leaving the UK, see the Beckham Law for UK citizens and a UK contractor moving to Málaga. The foreign side of any of them should be confirmed with an adviser in that country.

Where to start

If Spain is on your list, the free diagnosis tells you in five minutes whether you qualify and when your Modelo 149 deadline falls, and the savings calculator shows the Spanish side in numbers. If you are weighing Spain against another country with a real offer on the table, you can ask for a review: we will look for a registered lawyer or tax advisor to model the Spanish side, with a fixed quote before you commit to anything.

Sources

Spain

Portugal

Italy

Greece

Netherlands

Belgium

France

United Kingdom

Cyprus

Luxembourg

Denmark

Sweden

Finland

Austria

Federal Ministry of Finance, Zuzugsbegünstigung (1/1/2026)

Frequently asked questions

Is Portugal's NHR regime still available in 2026?

Not for new arrivals. The NHR was repealed from 1 January 2024, with a transitional rule for people who already met the conditions. Its successor, the IFICI, taxes income from a list of qualifying activities at a flat 20% for ten years.

Which European regime has the lowest rate?

Among flat-rate regimes, Portugal's IFICI (20%) is below Spain's 24% and Finland's 25%; Denmark charges 27% plus its 8% labour-market contribution. Italy, Greece, Cyprus and Luxembourg exempt half of the income instead, so their effective rate depends on the salary and the local scale. Headline rates are not comparable without running both returns.

What changes in 2027?

Three announced changes: the Netherlands' 30% ruling becomes 27%; Italy's impatriate regime moves into its new income tax code, with the current article repealed from 1 January 2027; and Sweden has a draft bill to raise its exemption from 25% to 30%, not yet law as of this update.

Can I use another country's regime and then Spain's?

Spain does not ask whether you used another country's regime. It asks whether you were Spanish tax resident in the previous five tax years. Each country sets its own rules on reuse: Portugal's IFICI, for example, excludes anyone who already benefited from the NHR.

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