A Decade After Moving to Portugal Under the Non-Habitual Resident Regime, Spanish Taxpayers Are Asking About Going Home

The Portuguese Residente Não Habitual (Non-Habitual Resident, or RNH) regime ran for ten years per beneficiary. For the Spaniards who signed up at the start of the last decade, that clock has run out, and a growing number are asking Spanish lawyers about going home under Madrid's own expatriate tax break, the Ley Beckham. ECO reported the trend on Monday, citing the Spanish daily El Confidencial.

"For years, Portugal has been one of the most attractive tax destinations for Spanish professionals, executives, entrepreneurs and high-net-worth individuals," Siro Barro, head of tax at the firm Edf, told the paper. "The RNH regime offered stable tax planning for a maximum of ten years. Since 2019, Spaniards who have exhausted that period have been starting their return."

Three things are pushing in the same direction

The first is arithmetic: the ten-year window closes and a former beneficiary falls back to ordinary Portuguese IRS rates. The second is that Spain has made its own regime more generous. The third, according to the lawyers quoted, is the cost of housing in Lisbon and Porto, which has climbed enough to erode part of the arbitrage that brought people over. Portuguese house prices rose 17.6% in 2025, the largest annual increase on record.

How the Beckham Law works

Spain's Régimen Especial de Impatriados (Special Regime for Inbound Workers) sits in Article 93 of the Spanish personal income tax law, and is named after David Beckham because the footballer used it on signing for Real Madrid. Professional athletes were later excluded, though Cristiano Ronaldo was inside the regime before that change.

A qualifying arrival is taxed as a non-resident at a flat 24% on Spanish employment income up to €600,000, with 47% above that line, and foreign-source income generally left outside the Spanish net. The benefit runs for six tax years: the year of arrival plus five. Spain's 2023 Ley de Startups widened it, cutting the required period of prior non-residence from ten years to five and opening the door to remote workers, entrepreneurs and certain family members rather than only employees posted by a Spanish company. The election is made on Modelo 149, within six months of registering with Spanish social security.

That five-year rule is the hinge. Someone who left Spain a decade ago for the RNH clears it comfortably, which is why the two regimes chain together neatly: ten years in Portugal, then six more in Spain at 24%.

The other side of the border is watching

Earlier this year the Spanish tax authority, Hacienda, stepped up inspections of what it treats as fictitious changes of residence to Portugal, targeting remote workers, pensioners and high-net-worth individuals who moved their tax residence south on paper. The European Commission estimated in 2022 that regimes of this type cost European treasuries about €4.5 billion a year, roughly €500 million of it in Spain.

Portugal, meanwhile, no longer offers the RNH to new arrivals. It has been replaced by the IFICI, a narrower incentive aimed at scientific research and qualified activities rather than at pensions and passive income.

What this means if your own ten years is ending

• Model the cliff before it arrives. The step from RNH treatment to standard IRS is not gradual. Work out the full-rate liability at least a year ahead.
• Residence is a question of fact, not of forms. Both Hacienda and the Autoridade Tributária (Tax Authority) look at where you actually live. Keep evidence that matches what you declare.
• The five-year clock is Spain's, not Portugal's. Anyone considering the Beckham route needs five clear tax years of Spanish non-residence, counted before the year of the move.
• Selling up has its own bill. Capital gains on a Portuguese property, and the timing of a sale relative to the change of residence, can outweigh the rate difference on income.

None of this signals an exodus. It does show that a ten-year incentive produces a ten-year cohort, and that the first of those cohorts is now doing its exit arithmetic in public.