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Spain, Portugal and Italy — comparing special tax regimes
Beckham Regime · Comparison

Spain's Beckham regime vs Portugal & Italy

Three of southern Europe's most talked-about tax regimes sit side by side — Spain's Beckham regime, Portugal's NHR successor, and Italy's impatriati and flat-tax options. This is a plain-English comparison of what each offers and who each tends to suit. It is general information, not tax advice.

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.

Jacob Salama, tax lawyer

"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.

Two Italys, not one: the impatriati regime rewards working in Italy through a partial exemption on earned income; the €100,000/€200,000 flat tax rewards bringing foreign wealth to Italy through a fixed annual charge. Comparing "Italy" to Spain without saying which one is meaningless.

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.

FeatureSpain — BeckhamPortugal — IFICI (NHR successor)Italy — impatriati / flat tax
Core mechanismFlat rate on general-base incomeReduced rate for qualifying activitiesImpatriati: partial exemption of earned income · Flat tax: fixed annual charge on foreign income
Headline number24% up to €600,000; 47% aboveReduced rate on qualifying income (confirm current rate)Impatriati: % of income exempt · Flat tax: ~€100,000/yr (higher for later arrivals)
Who it targetsInbound employees, entrepreneurs, qualified remote workersResearch, innovation, teaching & highly qualified rolesImpatriati: incoming workers · Flat tax: high-net-worth new residents
Foreign incomeSavings income analysed separately; qualifying activity deemed SpanishSome 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 schemeActive, widened by Startup Act 2022Original NHR closed to new entrants in 2024Both active but recently tightened
Best conceptual fitHigh-earning workers & founders wanting a predictable earned-income rateSpecialists in eligible research/innovation activitiesImpatriati: 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.

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.

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.

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