It is a common scenario for professionals who have settled in Spain under the Beckham Law: a few years into the regime, a second opportunity appears. A part-time contract, a board seat, an advisory role at another Spanish company. The natural question is whether that second income stream can be kept outside the special regime, taxed as an ordinary resident, while the original job stays at the flat 24%. A binding consultation published in February 2026 answers that question directly, and the answer is twofold: you keep the regime for both jobs, but you cannot pick and choose.
The Dirección General de Tributos (DGT) published consulta vinculante V0466-26 on 27 February 2026, resolving the case of a German national who moved to Spain and has been taxed under the Special Expatriate Regime (the so-called Beckham Law, Article 93 LIRPF) since 2022. His option runs through tax year 2027. From 2026, he plans to take on a second part-time contract with another Spanish company, and he asked the DGT whether he could keep only the first job in the special regime and tax the second job, and the rest of his income, as an ordinary resident.
Key takeaways
- No mix-and-match: for a single tax year you cannot tax part of your income under the special regime and part under general IRPF. You file one return only.
- That single return is either Modelo 151 (special regime) or Modelo 100 (ordinary resident). It is all or nothing.
- A second employer does not break the regime. Holding two contracts with two payers is not a ground for exclusion, so the second salary also falls under the special regime.
- The only carve-out remains the special professional-athlete employment relationship (RD 1006/1985), which cannot give access to the regime.
- The 24% rate and the 600,000 EUR threshold (above which 47% applies to the excess) are counted per employer, confirming criterion V0387-17. Two employers means two separate 600,000 EUR buffers.
You cannot tax one job in the regime and the other outside it
The DGT opened its answer with the most important point, because the taxpayer's premise was mistaken. For one and the same tax period, a taxpayer cannot tax one part of their income under the special regime and another part under the general IRPF rules. The two systems are not menu options to be combined within a single year.
The consequence is administrative as much as conceptual: the taxpayer must file a single income tax return for the year. Either it is Modelo 151, the return used by Beckham Law holders, in which case the whole of the income that the regime reaches is taxed under it, or it is Modelo 100, the ordinary resident return, in which case the special regime is not applied at all. There is no third return that splits the difference, and there is no way to route the second salary into a separate, general-rate calculation while keeping the first salary in the regime.
So the idea of keeping the first job in the Beckham Law and treating the second job as ordinary resident income is, on its own terms, not possible. The choice is between the regime and ordinary residence for the year as a whole, not job by job.
A second employer does not break the regime
The next question is whether taking the second contract puts the regime itself at risk. Here the news is reassuring. The DGT confirms that receiving employment income from two payers, under two separate employment contracts with two Spanish companies, is not a ground for exclusion from the special regime.
Article 93 LIRPF and the implementing provisions of the Income Tax Regulations (Articles 113 and following RIRPF) set out the conditions for entering and remaining in the regime, and the grounds for exclusion are listed in Article 118 RIRPF. Having more than one employer is not among them. The regime is built around the displacement to Spain and the start of an employment relationship with an employer in Spain; nothing in the rules requires that the relationship be the taxpayer's only one. Once admitted, the taxpayer remains in the regime for the year of arrival and the following five years, unless they renounce it or fall foul of an exclusion ground.
The DGT does flag the one exception that runs through Article 93: the special employment relationship of professional athletes regulated by Royal Decree 1006/1985 cannot be the basis for the regime. Outside that narrow carve-out, an ordinary second contract, whether a part-time role, a board seat, or an advisory engagement, does not threaten the regime. The practical upshot is that the second salary is taxed under the special regime alongside the first, at the flat 24% rate, because the taxpayer continues to be a Beckham Law holder for the year.
The 600,000 EUR threshold is counted per employer
The third part of the ruling addresses the rate mechanics, and this is where the existence of two employers becomes an advantage rather than a complication. Under Article 93.2.f) LIRPF and Article 114.3 RIRPF, the withholding rate on employment income under the regime is 24%. When the remuneration paid by a single payer during the calendar year exceeds 600,000 EUR, the rate applicable to the excess rises to 47%.
The decisive words are "a single payer". The DGT confirms, citing its earlier criterion in consulta V0387-17, that the 600,000 EUR threshold is calculated for each payer of employment income independently. In V0387-17 the question was precisely whether, for a taxpayer under Article 93 with income from more than one payer, the 600,000 EUR limit was assessed per payer or in aggregate. The answer then, reaffirmed now, is that the limit applies to each employer of employment income separately. (The earlier ruling referred to a 45% rate on the excess, which corresponds to today's 47%.)
For a taxpayer with two employers, this means each contract carries its own 600,000 EUR buffer at 24% before the 47% surcharge can ever apply. The threshold is not pooled across the two jobs.
The headline is easy to misread. A second job does not cost you the Beckham Law, and both salaries are taxed at the flat 24% with a separate 600,000 EUR threshold each. What you cannot do is cherry-pick: you cannot leave one income stream in the regime and pull the other out into ordinary residence. It is one return, one regime, for the whole year. , DPLL Tax & Legal · Editorial commentary, June 2026
What this means in practice
For Beckham Law holders weighing a second role in Spain, the ruling clears away a frequent worry and corrects a frequent misunderstanding. The points below summarise where things stand after V0466-26:
- You can take a second Spanish role without losing the regime. A part-time contract, a board seat, or an advisory engagement with a different Spanish company does not, by itself, expel you from the special regime, provided it is not the professional-athlete special relationship.
- Both salaries are taxed under the regime at 24%. Because you remain a Beckham Law holder for the year, the second job's employment income is taxed under the special regime exactly like the first, not under general IRPF.
- Each employer has its own 600,000 EUR threshold. The 47% surcharge on the excess is assessed per payer, so having two employers gives you two separate 24% bands up to 600,000 EUR each.
- You cannot split the year between regimes. There is no way to tax one job in the regime and another as an ordinary resident in the same tax period. You file a single return, Modelo 151 or Modelo 100, and the choice applies to the whole year.
- The regime still has a horizon. The option covers the year of arrival and the following five years. For the taxpayer in this case, that runs through 2027, after which ordinary IRPF resumes unless circumstances change.
Why the distinction matters
The ruling is a useful reminder that the Beckham Law operates at the level of the taxpayer and the tax year, not at the level of the individual income stream. Once you are inside the regime, the regime reaches the income it is designed to reach, and a second employment relationship is simply more income within the same framework.
That framework is, for most second-job scenarios, favourable. The flat 24% rate applies to both salaries, and the per-employer threshold means a second contract is unlikely to push you into 47% territory unless a single employer pays you more than 600,000 EUR. The trade-off is rigidity: you cannot engineer a hybrid in which the regime applies to one contract and ordinary residence to another. The system asks you to be in or out for the year, and to file the corresponding single return.
For anyone planning a second engagement, the practical questions are therefore less about whether the regime survives and more about timing, the per-employer threshold, and the remaining years of the option. Those are planning questions worth modelling before signing the second contract.
If you are a Beckham Law holder considering a second contract, a board seat, or advisory work in Spain, specialist advice helps you confirm that the new role does not trip an exclusion ground and that your withholding is set correctly per employer. Once you are within the Beckham Law regime, your annual return is filed on Modelo 151 annual return rather than the standard Modelo 100. For a personalised analysis of how a second job affects your specific situation, including the per-employer threshold and the remaining years of your option, we recommend seeking specialist advice from a qualified Spanish tax practitioner.