Spain Intra-company transfer

• Limit: €600k/yr ≈ $670k

Optional regime taxing Spanish-source income under non-resident rules: 24% up to EUR600,000 (≈ $670,000) and 47% above, for the year of arrival plus five years. Foreign-source income outside the qualifying work and entrepreneurial income is not taxed in Spain under this regime.

Taxed on

Tax calculated under Spanish nonresident-income-tax rules for opted-in individuals who become Spanish tax resident through a qualifying move. AEAT treats all work income and qualifying entrepreneurial-activity income earned during the regime as Spanish-source, even when activity is performed abroad, subject to the before-move/after-regime timing exception. Base A (dividends, interest and capital gains) uses a separate savings scale; other income is generally base B. A limited foreign tax credit may apply to qualifying foreign-earned employment/entrepreneurial income, with statutory cap.

Who it applies to

• Individual must become Spanish tax resident because of the move, not have been resident in Spain in the five tax periods before it, and elect the regime on form 149.
• The move (in the first year of application or the year before) must result from one of: an employment contract in Spain (including remote work for a foreign employer under the international teleworking visa), becoming a director of an entity, an entrepreneurial activity recognised under Art. 70 of Ley 14/2013, or a highly qualified professional serving start-ups or doing R&D&I work with more than 40% of business, professional and work income from it.
• The individual must not earn income through a permanent establishment in Spain (except in the entrepreneur and highly qualified professional cases).
• The regime applies in the tax period of the change of residence and the following five tax periods, while the conditions continue.
• Spouse and children under 25 (or any age if disabled), or the parent where there is no marriage, can elect too if they also become resident and their combined taxable base is lower than the principal taxpayer's.

Exclusions

• Not automatic with a digital-nomad or other visa; tax election, residence and activity conditions are separate.
• Dividends, interest and capital gains (Art. 25.1.f TRLIRNR income) use the separate savings scale in Art. 93.2.e: 19% up to EUR 6,000, (≈ $6,700) 21% to EUR 50,000, (≈ $55,900) 23% to EUR 200,000, (≈ $223,000) 27% to EUR 300,000 (≈ $335,000) and 30% above (30% from tax year 2025 under Ley 7/2024). The 24%/47% scale applies to the rest of the base.
• Non-business urban real estate in Spain may generate imputed rental income even when used as the taxpayer's habitual home (TEAC unification criterion of 17 July 2025).
• Qualifying employment and entrepreneurial income earned during the regime is treated as Spanish-source even when the work is done abroad, apart from income from activity before the move or after the regime ends.

Limits

• EUR 600,000 a year (≈ $670,000) · General part of the base: 24% up to this amount and 47% above (Art. 93.2.e.1); withholding on employment income is 24%, and 47% on pay from one payer above EUR 600,000 (≈ $670,000).
• EUR 300,000 a year (≈ $335,000) · Savings part of the base: 19% to EUR 6,000, (≈ $6,700) 21% to EUR 50,000, (≈ $55,900) 23% to EUR 200,000, (≈ $223,000) 27% to this amount and 30% above (Art. 93.2.e.2).

Days in the country

• More than 183 days in calendar year · Spanish tax residence if more than 183 days in Spain in the calendar year (Art. 9 LIRPF), subject to centre-of-interests rules.

Tax residence

Applicant must become Spanish tax resident because of the move and not have been resident in the prior five tax periods; election is filed on form 149 and lasts the arrival year plus five. Participants are treated as non-residents for double tax treaty purposes and are taxed in Spain only on Spanish-source income, with qualifying work and entrepreneurial income deemed Spanish-source.

Visas

Independent tax election; a telework visa can be a qualifying circumstance but does not confer the regime.

Other taxes

Spanish social security, VAT and business registration are separate. Participants are subject to Wealth Tax on a limited (Spanish-situated assets) basis. Non-business urban property in Spain gives imputed rental income even if it is the main home (TEAC criterion of 17 July 2025). A foreign tax credit for qualifying work and entrepreneurial income earned abroad is capped at 30% of the related tax charge.

Checked against official sources on 11 Oct 2026Change log

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