Living in Spain

Why Some Wealthy Residents Who Moved to Portugal Are Looking Back to Spain

Portugal’s celebrated NHR tax regime attracted high earners and wealthy residents for years. As those ten-year benefits begin to expire, Spain’s Beckham Law is attracting renewed attention from people considering a return.

For years, the tax conversation between Spain and Portugal seemed to move in one direction. High earners, international executives and affluent residents looked west towards Portugal, drawn by a tax regime that offered a very different proposition from ordinary Spanish taxation.

Now that picture is beginning to change.

Portugal’s former Non-Habitual Resident regime — usually known simply as NHR — offered qualifying residents favourable tax treatment for a ten-year period. The original regime has since been closed to most new arrivals, while many people who entered it years ago are approaching the end of their own ten-year benefit window.

That is prompting an interesting question among some former Spanish residents: if the Portuguese tax advantage is coming to an end, could moving back to Spain under the special expatriate tax regime commonly known as the Beckham Law make sense?

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Why Portugal became so attractive

Portugal introduced its Non-Habitual Resident regime in 2009. For qualifying new tax residents, the arrangement could provide beneficial treatment for certain categories of Portuguese and foreign income for up to ten years.

The regime proved particularly attractive to internationally mobile professionals, investors and retirees. Portugal combined the tax incentive with a lifestyle that was already familiar to many people considering Spain: a warm climate, attractive cities, Atlantic coastline and easy access to the rest of Europe.

For some Spanish residents, the calculation was straightforward. A move to Lisbon, Porto, the Algarve or elsewhere in Portugal could significantly alter their tax position while allowing them to remain on the Iberian Peninsula.

Portugal eventually brought the original NHR programme to an end for most new applicants from 1 January 2024. Existing beneficiaries generally continue under the rules applicable to their original ten-year period, while transitional provisions applied to certain people who had already begun the process of moving. Portugal has also introduced a narrower replacement incentive focused more closely on scientific research, innovation and selected professional activity, so it would be wrong to suggest that the country has simply abandoned tax incentives altogether.

Why some former Spanish residents are considering a return

The timing matters.

Someone who became an NHR in Portugal in 2016, for example, may now be approaching the end of a tax regime that shaped the financial logic behind their original move.

Reports in 2026 have highlighted growing interest among Spanish taxpayers who moved to Portugal under NHR and are now exploring whether they could return to Spain under the Beckham Law.

For those who genuinely want to return — perhaps for work, family, business or lifestyle reasons — the change can make Spain look considerably more interesting than it did when they first left.

What is the Beckham Law?

The name is informal. Spain’s so-called Beckham Law is actually the special tax regime for certain workers, professionals, entrepreneurs and investors who move to Spain and become Spanish tax residents.

It acquired its nickname after David Beckham became one of its best-known early beneficiaries following his move to Real Madrid. The regime has changed considerably since those days, and professional sportspeople are no longer its defining users.

Under the current rules, qualifying individuals may elect to be taxed under special non-resident-income-tax rules while remaining Spanish tax residents. The regime applies for the tax year in which the move takes place and the following five tax years — effectively up to six tax years in total.

Those headline percentages are one reason the regime receives so much attention from highly paid executives and internationally mobile professionals. However, the calculation is more complicated than simply comparing 24% with Spain’s ordinary top marginal income-tax rates. Different categories of income can receive different treatment, and individual circumstances matter enormously.

Can Spanish citizens use the Beckham Law?

Yes. This is one of the most misunderstood parts of the regime.

The rules are not restricted to foreign passport holders. What matters is the applicant’s tax-residence history and the circumstances behind the move to Spain.

Under the current legislation, an applicant must generally not have been a Spanish tax resident during the five tax periods preceding the year of the move.

That potentially creates an interesting position for Spanish nationals who moved to Portugal many years ago. A Spanish passport does not itself prevent them from qualifying if they satisfy the actual tax and relocation requirements.

Can a spouse and children benefit too?

Potentially, yes. This is another area where the modern Beckham regime is broader than many people realise.

The legislation allows certain family members of the main applicant to opt into the special regime as well. This can include a spouse and children under 25 — or children of any age in the case of disability — and, where there is no marriage, the other parent of those children.

They must move to Spain within the permitted timeframe, become Spanish tax residents and satisfy the relevant eligibility conditions themselves. There is also an income-based test: broadly, the combined taxable bases of those family members must remain below that of the principal applicant.

For families considering a move to Benahavís or Marbella, this can be highly relevant because the tax decision is rarely about one individual in isolation. However, the conditions are technical and each person who wants to use the regime must make their own election.

But moving back to Spain is not enough

This is where the headlines can become misleading.

Someone cannot simply spend five years abroad, return to Spain and automatically claim the 24% rate.

The move to Spain must arise from one of the circumstances allowed under the legislation. Depending on the applicant, that may involve employment, qualifying remote work, becoming an administrator of a company in permitted circumstances, undertaking a qualifying entrepreneurial activity or carrying out specified highly qualified professional work.

This is why professional tax advice should be taken before — not after — restructuring a life around the regime.

Remote workers can potentially qualify

The remote-working angle is particularly relevant to the Costa del Sol.

Spain’s current legislation specifically recognises certain employees who move to Spain and carry out their work remotely using computer, telecommunications and similar systems. The law also expressly refers to employed workers holding Spain’s international teleworking visa.

That means a person does not necessarily need to take a traditional office-based job with a Spanish employer to be considered. Someone relocating to Spain while continuing a genuine employment relationship with a foreign company may potentially fit within the regime, provided the statutory requirements are met.

For internationally mobile executives and professionals who can choose where they live, that considerably broadens the relevance of the Beckham Law — and helps explain why areas such as Benahavís and Marbella can be attractive to people whose work is no longer tied to one city.

There is a six-month deadline to apply

Eligibility is only part of the process. Timing matters too.

Each taxpayer makes the election individually. Family members wishing to join the regime must also submit their own Modelo 149 within the applicable deadline.

This is one reason tax planning should happen before the move. Someone who purchases a home, relocates the family and begins work before checking the structure of their application may discover that the tax position is not what they expected.

It is not designed as a retirement tax break

This distinction is especially important for people comparing Spain with Portugal.

Portugal’s old NHR system became well known among retirees as well as working professionals. Spain’s Beckham regime is different.

It is principally linked to moving to Spain because of qualifying professional, employment, entrepreneurial or related circumstances. Someone moving to Spain simply to retire and live from passive income should not assume that the Beckham regime will be available.

Likewise, holding a particular residence visa does not automatically establish eligibility for a tax regime. Immigration status and tax status are connected in practical terms, but they are not the same thing.

Approval is not automatic

Recent application figures underline that point.

Tax lawyer Guillem Domingo Pérez de Leceta has reported that 4,942 Beckham Law applications had been submitted during 2026 at the time the figures were obtained, with 3,453 accepted. That equates to an acceptance rate of approximately 69.9%.

The figures are a useful reminder that the Beckham Law is an elective tax regime with technical requirements, not an automatic entitlement for anyone moving to Spain.

Why this matters on the Costa del Sol

This is particularly relevant in places such as Benahavís, Marbella and the wider Costa del Sol, where the resident population includes international business owners, senior executives, entrepreneurs, remote professionals and families whose finances often span several countries.

For someone deciding whether to base themselves in Portugal, Spain, the UK, the United States or elsewhere, tax can influence the decision — but it is rarely the only factor.

Quality of life, schooling, international connections, property, healthcare, climate and proximity to family all matter too. Spain’s more competitive impatriate regime can therefore change the equation for someone who already prefers the lifestyle here but previously felt that the tax difference was too large to ignore.

Spain also offers a different level of scale. For internationally mobile families, that can translate into a wider choice of major airports, hospitals and private healthcare providers, international schools, universities, professional services and established expatriate communities.

The difference is especially noticeable on the Costa del Sol. Benahavís sits between Marbella and Estepona and within reach of Málaga, placing residents close to one of southern Europe’s busiest international airports, a substantial network of public and private healthcare, numerous international schools, established English-speaking professional services and an international community that has developed over several generations.

For Benahavís in particular, that combination matters. The municipality offers the space, privacy and quality of life associated with a high-end residential destination while retaining easy access to Marbella, Málaga’s growing business and technology ecosystem and the wider infrastructure of the Costa del Sol.

The Beckham Law is not always the cheapest option

A headline tax rate can be seductive, but it should never be viewed in isolation.

Whether the Beckham regime produces a saving depends on the applicant’s salary, investments, property, family situation, sources of income and where those assets and income streams arise.

For someone on a relatively modest Spanish salary, the ordinary Spanish income-tax system may produce a similar or even lower liability once personal circumstances and the ordinary tax framework are taken into account.

For a senior executive earning several hundred thousand euros, or an internationally mobile professional with a more complex financial position, the calculation may look very different.

Portugal has not stopped attracting international talent

It is also too simplistic to say that Portugal has simply shut the door on tax incentives.

The original NHR regime was repealed for most new entrants from 2024, while existing beneficiaries continue through the remainder of their original eligibility periods. Portugal has since moved towards a narrower incentive structure aimed at areas such as scientific research, innovation and selected high-value activity.

The result is not that Portugal suddenly became unattractive. Rather, the very broad comparison that once made Portugal an obvious tax choice for many internationally mobile people has become much more nuanced.

Tax is not the only part of the Portugal-Spain calculation that has changed

For internationally mobile professionals and families, the decision between Portugal and Spain has never been based on tax alone. Residence rules, the path towards citizenship, property costs and the practicalities of building a long-term life can be just as influential.

Portugal has tightened parts of that proposition in recent years. The former manifestação de interesse, or “expression of interest”, route that allowed some people already working in Portugal to regularise their residence without first following the conventional residence-visa route was abolished in 2024.

Portugal also reformed its nationality rules in 2026. For many foreign residents, the ordinary residence period associated with applying for Portuguese citizenship is now longer than it was under the previous framework. Anyone considering Portugal primarily as a long-term route towards citizenship therefore needs to assess the current rules rather than relying on the proposition that existed several years ago.

None of this means that Portugal is closed to international residents. It remains an attractive European destination with several residence routes. However, some of the advantages that helped drive its extraordinary popularity among mobile professionals, investors and families have become less generous or more narrowly targeted.

Portugal is no longer necessarily the lower-cost alternative

The financial comparison has changed in another important way: property prices.

Lisbon, Porto and sought-after coastal areas have experienced substantial housing inflation over recent years. By 2026, asking prices across Portugal were reaching new records, with Lisbon remaining the country’s most expensive city and the Algarve firmly established as one of its highest-priced residential markets.

That does not mean prime Portugal is necessarily more expensive than prime Benahavís or Marbella. The markets are different and luxury property varies enormously by location. What has changed is the assumption that moving from Spain to Portugal automatically means dramatically cheaper housing and everyday living.

For someone comparing high-quality residential areas rather than national averages, the gap can now be far narrower than the reputation Portugal developed during the early years of NHR might suggest.

Infrastructure and international scale matter too

For a household moving internationally, daily convenience can ultimately matter more than a spreadsheet comparison.

Spain’s greater scale gives internationally mobile residents access to a particularly broad network of airports, transport links, hospitals, universities, international schools and professional services. On the Costa del Sol, decades of international migration have also created a mature support network for people arriving from Britain, northern Europe, the United States and many other parts of the world.

Benahavís benefits from that infrastructure without feeling like a large international city. Residents can live among mountains, golf courses and low-density residential communities while remaining close to Marbella, Estepona and Málaga. For families and professionals who want privacy and space without giving up international schools, healthcare, air connections or an established international community, that balance can be a significant part of the decision.

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Could the pendulum be swinging back towards Spain?

Perhaps — but not because thousands of wealthy residents will suddenly cross the border at once.

What has changed is the calculation.

Portugal’s old NHR regime offered a powerful reason for some people to leave Spain. As those ten-year periods expire and Spain’s own impatriate rules become relevant to people who have spent at least five tax years abroad, returning can become financially viable in a way it may not have been before.

At the same time, Portugal’s immigration and nationality framework has become less generous in some respects, while the dramatic rise in housing costs has narrowed one of the other traditional arguments in its favour.

For some former residents, the decision may therefore be less about chasing the lowest possible tax rate and more about removing one of the main financial objections to living in Spain again — while rediscovering the practical advantages of Spain’s larger infrastructure and established international communities.

And for areas such as Benahavís and the Costa del Sol — where lifestyle has always been one of Spain’s strongest advantages — that could prove significant.

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