Spanish Exit Tax (Impuesto de Salida, Article 95 Bis LIRPF)
Spain's exit tax under Article 95 bis of the Ley del Impuesto sobre la Renta de las Personas Físicas (LIRPF) was introduced in 2015. Conditions for application: you have been Spanish tax resident for at least 10 of the last 15 years, AND either: (a) your total latent capital gains in shares and holdings exceed €4,000,000, OR (b) your stake in a single company exceeds 25% AND the latent gain in that holding exceeds €1,000,000. Assets in scope: shares and interests in entities (listed and unlisted). NOT in scope: Spanish real estate (separate rules apply); personal assets; bonds. Tax rate: capital gains rates (19–28% for 2025 — Spain's savings income tax brackets). EU/EEA departures: automatic deferral until actual sale. Non-EU/EEA departures (USA, UK post-Brexit, Latin America): tax due immediately, OR quarterly instalments over 5 years if the departure is for employment reasons (you prove you are leaving for work). Below the €4M threshold: NO Spanish exit tax. Practical impact: affects wealthy Spanish entrepreneurs and long-term foreign residents with large Spanish company stakes — not the average Spain expat. Non-residents of Spain who held shares: not subject to the exit tax (must be Spanish resident for the 10-of-15 years).
Beckham Law (Régimen Especial de Impatriados): End on Departure
The Beckham Law (named after footballer David Beckham's arrival in Spain) allowed foreign nationals taking up Spanish residency for the first time (or after 5+ years of non-residency) to pay a flat 24% income tax rate on Spanish-source income up to €600,000, and 47% above that — instead of the standard Spanish progressive rates (up to 47%). The regime lasts for 6 years (the year of arrival plus 5). 2023 reform: the new 'Ley de Startups' updated the Beckham regime — expanded eligibility to entrepreneurs, digital nomads, and researchers; the flat rate changed to 24% up to €600,000 and 47% above. When you leave Spain during the Beckham regime period: the regime ends immediately. No clawback of the tax benefits already received during the Beckham period. You simply cease to be a Spanish resident (and thus no longer eligible for the regime). Important: if you claimed the Beckham regime and leave Spain within the 6-year window, you do NOT owe any additional Spanish tax as a 'clawback' — but confirm this with a Spanish gestor as fact patterns vary. Spanish tax clearance: no specific 'tax emigration certificate' exists in Spain — you notify AEAT of your departure via Modelo 030.
Modelo 030 / 030A: Notifying AEAT of Departure
To formally notify AEAT (Agencia Estatal de Administración Tributaria) of your change of tax residence from Spain: file Modelo 030 (Census Return for Change of Tax Data for Physical Persons) via the AEAT portal (agenciatributaria.es) or at a physical AEAT office. Modelo 030 changes: update your tax residence to your new country, declare your departure date, and provide your new overseas address. For high-earners or those with complex assets: some advisors recommend also filing Modelo 030A (declaration of change of tax residence to another country) — this formally invokes the exit tax provisions where applicable. Padrón municipal (municipal census): separately, deregister from the Padrón Municipal at your Ayuntamiento (town hall) — this is the civil register of residents. The Padrón deregistration is separate from the AEAT tax deregistration. NIE (Número de Identificación de Extranjero): your Spanish NIE number remains valid after departure — you will need it for property transactions, pension matters, and any remaining AEAT obligations. Certificado de no residencia: some banks and institutions require a 'Certificate of Non-Residency' from AEAT — apply via AEAT portal once your Modelo 030 has been processed.
Spanish Pension (Jubilación) and Social Security Abroad
Spain's public pension system (Sistema de Seguridad Social) provides both contributory pensions (prestación contributiva) based on contributions and non-contributory pensions for those without sufficient contributions. Contributory pension: fully portable — payable internationally by the INSS (Instituto Nacional de la Seguridad Social) from standard pension age (65–67, depending on contribution years). Contact INSS (seg-social.gob.es) before departure for your pension certificate (vida laboral) and to register your overseas payment details. Spanish pension withholding: Spain withholds IRPF (income tax) on pensions paid to non-residents — rate depends on the applicable DTA. Under Spain-USA DTA: pensions typically taxable in the residence country (USA); Spanish withholding is credited. Under Spain-UK DTA (post-Brexit): similar treatment. The pension is paid in EUR; convert to local currency via your bank or Wise. Spanish complementary pension plans (planes de pensiones): can be withdrawn on departure from Spain — subject to IRNR (Non-Resident Income Tax) withholding or IRPF if still resident. Voluntary contributions: if you lack sufficient Spanish contribution years, you can make voluntary contributions to increase your Spanish pension entitlement — even as a non-resident in some circumstances. Spain has totalization agreements with many countries.
IRNR and Non-Resident Spanish Property
IRNR (Impuesto sobre la Renta de No Residentes) is Spain's non-resident income tax. After departing Spain, you are subject to IRNR on Spanish-source income: (1) Spanish rental income: IRNR at 19% (EU/EEA residents) or 24% (non-EU/non-EEA). File Modelo 210 quarterly or annually. (2) Spanish property imputed income: even if you do NOT rent out your Spanish property, Spain imputes a deemed income of 1.1% (or 2%) of the cadastral value (valor catastral) annually — taxable under IRNR on Modelo 210. This 'deemed rental income' catches many Spanish holiday home owners who are unaware of the obligation. (3) Spanish dividends: 19% IRNR withholding (reduced under DTA to typically 15%). (4) Capital gains from Spanish property: IRNR at 19% on gains; buyer withholds 3% of purchase price as retention (retención) — you file Modelo 211 to recover excess if your actual gain tax is lower than 3% withheld. Wealth tax (IP — Impuesto sobre el Patrimonio): for non-residents owning Spanish property/assets above thresholds, the Spanish wealth tax may still apply — rates vary by autonomous community; some have reduced or eliminated it (Madrid has a 100% rebate). Annual Modelo 714 if wealth tax threshold exceeded.