Since Donald Trump’s victory in the 2024 U.S. presidential election, the switchboard at Lullius Partners has been lighting up with a distinctly American accent. “In November we were already busy” says Xavier Rubert, our managing partner, “but by the first quarter of 2025 the number of calls and video consultations from Americans asking about moving to Spain under the Beckham Law had tripled.”
What is fueling the rush? In a word, predictability. Under Spain’s revamped “Beckham Regime”—Article 93 of the Personal Income Tax Act—new residents who have not lived in Spain during the previous five tax years may opt to be taxed at a flat 24 percent on employment income up to €600,000. Above that threshold the ordinary progressive rates apply, yet the headline figure is low enough to turn heads in Manhattan, Austin, and Silicon Valley alike. The package also offers relief on stock-option income (up to €50,000 a year), a 50 percent deduction on carried interest, a generous incentive for seed-capital investments, and—crucially for portfolio-heavy households—an exemption from Wealth Tax on non-Spanish assets for six years.
For American expats, however, the story is more nuanced than the marketing suggests. “U.S. citizens relocating to Spain never leave Uncle Sam’s embrace,” Rubert reminds would-be movers. The United States employs citizenship-based taxation; unless you renounce the passport, the IRS still expects its due. As a practical matter, an American executive earning €335,000 under the Beckham Regime might pay roughly €80,000 to the Spanish Treasury and a further €16,000 to the IRS to top up to U.S. federal rates. The Spanish headline rate remains attractive, but the delta is narrower than glossy brochures imply.
That is where sophisticated, dual-qualified advice becomes indispensable. Trust structures that work beautifully onshore in the United States often trigger punitive look-through treatment in Spain. Likewise, 401(k)s, Roth IRAs, and even basic brokerage accounts require meticulous mapping to Spanish income and reporting rules or risk double taxation and penalties. “The most common misconception we hear is that the Beckham Regime gives you a six-year holiday from Spanish Worldwide Income,” says Rubert. “It does not—you still declare global income, you just pay Spanish ‘non-resident’ rates on it. If the structure housing that income is U.S.-centred, the compliance friction can be significant.”
Added to the tax matrix is migration law. Spain may have scrapped its Golden Visa, but American nationals still have multiple pathways—digital-nomad permits, highly qualified professional visas, entrepreneur visas, and straight local hires. Each route has its own timeline and evidential quirks; choose the wrong one and you could jeopardise the 30-day clock for filing the Beckham election or lose your eligibility entirely. Rubert’s advice: “Start the immigration and tax analysis in tandem, never sequentially. A beautiful visa issued on day 45 is worthless if you have already missed the Beckham window.”
Mallorca in particular has emerged as an understated hotspot. Our Palma office has seen enquiries ranging from remote-first tech founders to film producers captivated by the island’s blend of fibre-optic infrastructure and Mediterranean pace of life. Lifestyle still counts: lower real-estate prices than New York or Los Angeles, Michelin-starred restaurants, year-round flights, and, yes, 300 days of sunshine that look very good on social feeds and even better on mental-health indices. Yet the Balearic tax code holds its own wrinkles—progressive Wealth Tax brackets and distinct filing thresholds demand local finesse. “It is paradise,” Rubert laughs, “but paradise requires paperwork.”
“As a team of veteran TV / Film producers and entrepreneurs with deep roots in both Hollywood and Europe, we’ve spent years navigating the complexities of launching major international projects,” says Joe Q. Bretz, Mallorca-based producer and co-founder of multiple entertainment ventures. “We’ve had our share of false starts—ambitious productions that were delayed or derailed because we lacked fully integrated legal and financial guidance across borders. That changed when we began working with Xavier and the team at Lullius Partners. They’re not just tax attorneys—they’re strategic partners who understand the nuance of U.S.-EU structuring. Their seamless coordination with U.S. advisors and ability to anticipate both regulatory environments has been a game-changer” says Bretz.
“Thanks to their guidance, we’re finally positioned to move forward with a slate of international projects backed by proper structure, clarity, and investor confidence. They’ve helped us protect and unlock the value we’ve been building for years” Bretz adds.
Behind the scenes, the Spanish tax authorities have stepped-up audit activity. Verification letters now arrive within two to three years of arrival, not five or six. Points of focus include whether the taxpayer truly became Spanish-resident on the date claimed, whether foreign directors are exercising authority from Spain, and whether U.S. LLC distributions constitute salary or dividends in the Spanish sense. Poor documentation or aggressive self-assessments can lead to back-tax, interest, and penalties that dwarf the savings the Beckham flag once promised.
All of which explains the recent “aluvión” of U.S. consultations. Spain remains a fiscal life-raft—especially compared with California’s combined top marginal rate of nearly 53 percent—but only if navigation is precise. At Lullius Partners our Private Wealth team integrates Spanish, cross-border, and U.S.-angle counsel under one roof, coordinating tax, corporate, and global mobility teams in Madrid and Mallorca.
Rubert distils the value proposition with a smile: “The Beckham Law can be a Ferrari—or a banana peel. With the right pit crew, you reach Marbella in style. Without it, you end up arguing with two tax offices at once.”
For American expats, US citizens relocating to Spain, and anyone simply contemplating moving to Spain, the message is clear. Spain still offers blue skies, cultural depth, and a globally competitive tax framework—but only when the numbers, visas, and reporting obligations are orchestrated in concert. If you are browsing for expat tax lawyers in Spain, tax lawyers in Spain, or specifically looking for in-house expertise in Mallorca, reach out.
At Lullius Partners, we understand the unique challenges that U.S. citizens face when relocating to Spain. That’s why we’ve built a dedicated U.S. Desk, staffed by international tax lawyers and U.S.-Spain specialists, to provide seamless support to Americans moving to Spain—and to Mallorca in particular. Whether you’re a remote executive, a dual-national family, or a business owner expanding your life across borders, our team of Beckham Law lawyers in Mallorca, tax lawyers in Mallorca, and expat lawyers in Mallorca works to deliver fully coordinated, technically robust advice.
