The Agencia Estatal de Administración Tributaria (AEAT) has released the official 2025 instruction manual for Modelo 151, the annual income-tax return filed by individuals under Spain's Special Tax Regime for Impatriates — popularly known as the Beckham Law. The document was published on the AEAT portal on 9 May 2026, just ahead of the regular filing window that opens on 1 April and closes on 30 June.
While the structural changes to the form itself are minimal, three areas have received material clarification that practitioners will want to factor into their 2025 filings: the classification of remote-work income, the treatment of stock-based compensation, and the documentation now expected for taxpayers paid by foreign employers.
Key takeaways
- The 2025 Modelo 151 keeps the same field structure as 2024; no major rewrites.
- Remote-work income from foreign employers must be reported under the new sub-code
RT.40-B, distinguishing it from intra-group transfer arrangements. - Stock-based compensation (RSUs, ESPP discounts) vests as Spanish-source income on the vesting date during Spanish residence — not on grant.
- Foreign-employer payslips now require a sworn translation if filed in support of the regime; informal renderings will trigger a request for clarification.
- The €600,000 threshold and the 24% / 47% rates are confirmed unchanged.
What is Modelo 151?
Modelo 151 is the annual personal income-tax declaration for taxpayers who have elected the Beckham regime through Modelo 149. It replaces Modelo 100 — used by ordinary Spanish residents — for the duration of the six-year coverage period. The form captures Spanish-source employment income, applies the flat 24% rate up to €600,000 and the 47% rate beyond that ceiling, and computes withholdings and final liability accordingly.
Remote-work income gets a new sub-code
The most concrete change in the 2025 instructions affects digital nomads and similar remote-work taxpayers. Until now, income paid by a foreign employer to a Spanish-resident impatriate was reported under the general employment-income box, with explanatory notes in the comments field. The 2026 instructions introduce a dedicated sub-code, RT.40-B, to capture this category specifically.
The change is largely administrative — the tax treatment is identical — but it gives the AEAT cleaner data to audit and significantly reduces the number of follow-up requests practitioners can expect during the cross-check period in July and August.
The clarification on RT.40-B doesn't change anyone's tax bill. What it does change is how cleanly the return passes the AEAT's automated reconciliation. Cleaner data, fewer letters. — DPLL Tax & Legal · Editorial commentary, May 2026
Stock-based compensation: vesting in Spain remains Spanish-source
The treatment of RSUs (restricted stock units) and other equity awards has been a recurring source of confusion. The 2025 instructions explicitly confirm the longstanding administrative position: shares that vest while the taxpayer is a Spanish tax resident are Spanish-source income, regardless of where they were granted or where the underlying employer is headquartered. They fall under the regime and are taxed at the flat 24% / 47% rate.
By contrast, shares granted before Spanish residence and which vest after the impatriate has ceased to be a Spanish tax resident remain outside the regime. The instructions illustrate this with a worked example involving a four-year vesting schedule starting before move and ending after a return abroad — useful precedent for anyone in a similar position.
Foreign-employer payslips now need sworn translations
This is the most material procedural change. The 2025 instructions formalise what had previously been case-by-case practice: payslips issued by foreign employers, when submitted in support of a Beckham filing, must be accompanied by a sworn translation into Spanish. The translation must be performed by a translator listed on the Ministry of Foreign Affairs' registry of sworn translators (traductor jurado).
Informal in-house translations, or translations performed by the taxpayer themselves, will trigger an AEAT request for proper documentation — and in practice add four to eight weeks to the processing time. Practitioners should budget for the translation cost (typically €15–30 per page) when preparing 2025 filings for foreign-employer impatriates.
What hasn't changed
Despite the procedural tweaks, the substantive parameters of the regime are confirmed unchanged for tax year 2025:
- Flat rate: 24% on Spanish-source employment income up to €600,000.
- Top band: 47% on the portion of employment income above €600,000.
- Filing window: 1 April – 30 June 2026 for the 2025 tax year.
- Coverage period: six tax years (year of arrival plus five).
- Foreign assets: no Modelo 720 obligation, no Spanish wealth tax on non-Spanish-situs assets.
Practical action items for 2025 filers
If you are filing Modelo 151 for tax year 2025, three concrete steps follow from the new instructions:
- Confirm with your employer whether your income should be reported under the new
RT.40-Bsub-code or the standard employment box. Get this right before filing — corrections after submission are non-trivial. - If any of your compensation includes RSUs or equity awards that vested during 2025, prepare documentation of the grant date, vesting schedule and the value at vesting (not at grant).
- If you are paid by a foreign employer, commission sworn translations of your 2025 payslips now. Translators are typically booked out two to three weeks in May–June.
For taxpayers whose situation is straightforward — a single Spanish employer, no equity, no foreign income — the 2025 filing should be substantially identical to 2024.