US Expats in Spain: Complete Financial Planning Guide (2026)

Spain is home to one of Europe's largest and most diverse US-citizen expat communities — software engineers and product managers in Barcelona's 22@ tech district (Amazon, Glovo, Typeform, King); finance and consulting professionals in Madrid; executives at European headquarters for US multinationals; and a substantial retired cohort on the Costa del Sol, Costa Blanca, and Canary Islands. Spain's Beckham Law is genuinely attractive: a flat 24% income tax rate for up to six years, with foreign-source capital income generally exempt from Spanish tax. But US citizens who arrive expecting the Beckham Law to solve their tax situation consistently underestimate the US side. The IRS taxes US citizens on worldwide income regardless of Spanish regime — and the Beckham Law's reduced Spanish rate means reduced Foreign Tax Credit, which can leave a meaningful residual US federal bill that most advisors don't catch. Separately, Modelo 720 — Spain's declaration of foreign assets — creates a parallel reporting obligation on top of FBAR that catches many new arrivals off guard.

1. The Core Tax Decision: Foreign Tax Credit vs FEIE in Spain

US citizens abroad must choose between two mechanisms to limit double-taxation on foreign earned income:

• Foreign Earned Income Exclusion (FEIE, Form 2555) — excludes up to $132,900 of foreign earned income from US gross income in 2026.¹
• Foreign Tax Credit (FTC, Form 1116) — credits Spanish income taxes paid against your US federal tax liability, dollar for dollar.

Spanish IRPF Rates (2026)

Spain's Impuesto sobre la Renta de las Personas Físicas (IRPF) combines a national rate and an autonomous community (regional) rate. The combined rates below reflect the national portion plus average regional rates; actual rates vary by region — Madrid's regional rates are Spain's lowest, while Catalonia's are among the highest.²

Social Security contributions (Seguridad Social) are NOT creditable for US FTC purposes — they are payroll taxes, not income taxes. Only the IRPF income tax component qualifies as a creditable foreign tax under IRC §901.

Savings Income Rates (2026)

Dividends, interest, and capital gains are taxed at Spain's separate savings income rates (base del ahorro):

FTC Without the Beckham Law

For a US citizen in Spain on standard IRPF, FTC typically wins decisively. Consider a senior engineer at an international company in Madrid earning €120,000 under normal IRPF:

• Spanish IRPF on €120,000: approximately €43,000–€47,000 (at combined rates above)
• US federal tax on equivalent $132,000: approximately $27,000–$34,000 (after $15,000 standard deduction, 2026 brackets)
• FTC from Spain easily covers all US federal tax; excess credits carry forward 10 years under IRC §904(c)

At Spain's 45% marginal rate on mid-to-upper incomes, standard IRPF generates far more FTC than most US taxpayers owe — eliminating US federal tax and producing carryforward credits that offset future years. The FEIE (with its $132,900 cap) offers no advantage here.

FTC Under the Beckham Law — The Hidden Shortfall

Under the Beckham Law, the same €120,000 earner pays 24% flat IRPF: €28,800 Spanish income tax. In USD at $1.10/€, that is $31,680 of FTC credits. US federal tax on the equivalent $132,000 of income is approximately $28,000–$36,000 depending on filing status, other income, and deductions — meaning the Beckham Law may generate just barely enough FTC, or leave a gap of $4,000–$6,000 that the employee never budgeted for.

For a director-level professional earning €250,000 on the Beckham Law:

• Spanish IRPF: 24% × €250,000 = €60,000 → ~$66,000 FTC available
• US federal tax on $275,000 (at top 37% bracket, after deductions): approximately $90,000–$100,000
• Residual US tax after FTC: $24,000–$34,000 — real money that most Beckham packages don't account for

The 24% flat rate looks attractive on the Spanish side; the residual US tax bill is the other side of that coin.

FEIE Under the Beckham Law

Beckham Law holders with lower incomes may benefit from the FEIE over FTC. For a recipient earning €110,000 ($121,000) — below the $132,900 FEIE limit — the FEIE can exclude the entire earned income from US gross income, resulting in zero US federal income tax on that income. This avoids the FTC shortfall math entirely. Caveats: the FEIE triggers the §219(f)(1) IRA eligibility forfeiture on excluded income, the §1402(a)(8) self-employment tax trap for autónomos (SE tax is owed regardless of FEIE), and the 5-year revocation lock-in makes switching from FEIE to FTC difficult later. Use our FEIE vs FTC calculator to model your specific situation.

2. The Beckham Law (Régimen Especial para Trabajadores Desplazados)

Spain's Beckham Law — formally the Régimen Especial de Trabajadores Desplazados, expanded by the 2022 Ley de Startups — is a special tax regime for new residents. US citizens who meet the requirements pay 24% flat IRPF on Spanish-source employment or business income (up to €600,000; 47% above), with foreign-source capital income generally not subject to Spanish tax during the regime period.³

Eligibility Requirements (2026)

• Prior non-residency: Must not have been a Spanish tax resident in any of the 5 fiscal years preceding arrival (the Ley de Startups reduced this from 10 years)
• Work-related relocation: Must move to Spain for employment with a Spanish company, assignment from a foreign employer, entrepreneurship activities, or as a digital nomad on the International Telework Visa (ITW/DNV) working for non-Spanish clients
• Physical presence: Must spend 183+ days per year in Spain and become a Spanish tax resident; at least 85% of work must be performed from Spain (digital nomad exemption: 80% of income must come from non-Spanish clients)
• Application deadline: Must apply within 6 months of registering with Spanish Social Security (or within 6 months of arrival if no SS registration)
• Income threshold for digital nomad applicants: Minimum monthly income equivalent to approximately €2,850/month (200% of Spain's SMI) for a single applicant in 2026
• Not eligible: Professional athletes, company directors owning more than 25% of the business (unless under startup/entrepreneur scheme), prior Spanish tax residents within the 5-year window

Duration and Foreign Income Exemption

The regime applies for the year of arrival plus the 5 following fiscal years — up to 6 years total. Once ended, you fall into the standard IRPF regime. During the Beckham period, foreign-source capital income (dividends, interest, capital gains from non-Spanish assets) is generally exempt from Spanish IRPF — you owe US tax on it, but Spain doesn't tax it. This creates a tax-efficient structure for US citizens who maintain significant US investment portfolios, as the US portfolio income is subject only to US tax (no Spanish income tax, no FTC coordination for those items).

What the Beckham Law Does NOT Do for US Citizens

• It does not reduce US tax obligations. The US saves clause in the US-Spain treaty preserves full US taxing rights on worldwide income for US citizens, regardless of Spanish regime.
• It does not eliminate FBAR, Form 8938, or other US reporting requirements. All foreign account reporting obligations remain in full.
• It does not solve Modelo 720. As a Spanish tax resident, you must file Modelo 720 for your US accounts every year.
• It does not cover IRA contributions. The FEIE forfeiture applies if you elect FEIE; under FTC, IRA contributions are permitted but phaseout thresholds still apply if you or your spouse are covered by a workplace plan.

3. Modelo 720: Spain's Foreign Asset Declaration

Any Spanish tax resident holding foreign assets above €50,000 in one or more of three categories must file Modelo 720 annually with the Agencia Tributaria (Spanish IRS). The deadline is January 1 through March 31 of the year following the calendar year being reported.⁴

The Three Reporting Categories

1. Foreign bank and financial accounts — US bank accounts (Chase, Bank of America, Schwab, Fidelity cash accounts), US money market accounts, any foreign bank account
2. Foreign securities, investment funds, insurance, annuities, and life insurance — US brokerage accounts (Schwab International, Interactive Brokers), US ETF holdings, US IRAs, 401(k) and workplace retirement accounts (the status of retirement accounts is nuanced — consult a specialist), US annuities
3. Foreign real estate — US property, property in any country other than Spain

The €50,000 threshold applies per category. If only your US bank accounts exceed €50,000, you report Category 1. If your brokerage also exceeds €50,000, you report Category 2 as well. Each category is assessed independently.

Overlap With FBAR and Form 8938

As a US citizen in Spain, you face three independent foreign account/asset reporting systems:

• FBAR (FinCEN 114): Required for US citizens with foreign financial account balances exceeding $10,000 at any point during the year — in your case, reporting Spanish bank accounts (Santander, BBVA, CaixaBank, Bankinter) to the US Treasury. Deadline: April 15, extended to October 15.
• Form 8938 (FATCA): For taxpayers living abroad, required if foreign assets exceed $200,000 single / $400,000 MFJ at year-end (or $300,000/$600,000 at any point). Covers foreign financial accounts and financial interests.
• Modelo 720: Required for Spanish tax residents with foreign assets above €50,000/category. In your case, your US accounts are "foreign" from Spain's perspective — Modelo 720 reports your US holdings to the Agencia Tributaria.

Filing one does not satisfy the others. FBAR reports Spanish accounts to the US; Modelo 720 reports US accounts to Spain; Form 8938 is a separate US filing. All three systems operate independently, with separate deadlines, separate penalties, and separate reporting formats.

Post-ECJ Modelo 720 Penalties (2026)

The European Court of Justice ruled in February 2022 that Spain's original Modelo 720 penalties (which could reach 150% of the undeclared asset value plus the asset's inclusion as taxable income) were disproportionate and illegal under EU law. Penalties are now:⁴

• €20 per piece of information omitted or incorrectly reported
• Minimum €300 per form; maximum €20,000 per form
• 50% reduction if filed before Spanish tax authorities send a non-compliance notification
• Doubled for assets outside the European Union (which includes US assets — so the effective ceiling for US holdings is €40,000 per category)

The current penalties are proportionate and manageable for most filers. The historical risk was confiscatory; that era is over. But Modelo 720 remains a mandatory annual filing obligation, not optional.

4. Seguridad Social and the US-Spain Totalization Agreement

The US and Spain have had a Social Security Totalization Agreement in force since April 1, 1988. For US citizens who become Spanish tax residents and are employed or self-employed in Spain, the totalization agreement generally assigns Spanish Social Security (Seguridad Social) coverage — meaning you pay into the Spanish system and are exempt from US self-employment tax on the same earnings.⁵

Employees

US citizens employed by a Spanish company or a Spanish branch of a US employer contribute to Seguridad Social under the Spanish system. The employer pays approximately 30–32% of gross salary on top; the employee pays approximately 6.35% through payroll deductions (2026 rates). You are exempt from US Social Security and Medicare taxes (FICA/SECA) on the same earnings, and your Spanish SS contributions count toward both your Spanish pension (vejez) eligibility and, through totalization, your eventual US Social Security benefit.

Self-Employed Autónomos

US citizens registered as autónomos (freelancers, digital nomads, business owners) in Spain pay into the RETA (Régimen Especial de Trabajadores Autónomos) system. Autónomo contributions in 2026 operate under a net-income-based quota system introduced in 2023, with monthly contributions ranging from approximately €230/month (lowest income tier) to €590/month (highest tier). Under the totalization agreement, autónomos residing and working in Spain are covered by Spanish Social Security and exempt from US self-employment tax (15.3%) on the same income — a significant benefit given that SE tax would otherwise be owed in addition to income tax.

WEP and GPO Repeal

The Social Security Fairness Act (January 2025) repealed the Windfall Elimination Provision (WEP) and Government Pension Offset (GPO). US citizens who receive both Spanish Seguridad Social pension benefits and US Social Security will no longer have their US benefit reduced by WEP. This is a material improvement for long-term Spain expats approaching retirement.

5. Spanish Pension Plans (Planes de Pensiones) — PFIC Trap

Spain's individual pension plans (planes de pensiones individuales) offer a Spanish tax deduction of up to €1,500/year on contributions (reduced from €2,000 in 2022). The Spanish tax deferral is real but modest — and the US complications can easily outweigh the benefit.

US Tax Treatment

• No US deferral recognition: Unlike a US 401(k) or IRA, Spain's planes de pensiones are not recognized by the IRS as qualified retirement plans. Earnings inside the plan likely accrue as current US taxable income.
• Form 3520 / 3520-A exposure: Individual Spanish pension plans are generally structured as foreign trusts for US tax purposes. Contributions and annual earnings may trigger Form 3520 (Annual Return to Report Transactions with Foreign Trusts) and Form 3520-A (Annual Information Return of Foreign Trust with a US Owner) filing requirements. Penalties for missed 3520 filings are 35% of the gross value of trust assets — a penalty that can rapidly eclipse the value of the account.
• PFIC investments inside: Most planes de pensiones hold Spanish or EU-domiciled investment funds — Passive Foreign Investment Companies (PFICs) requiring Form 8621 elections to avoid §1291 excess-distribution treatment. The combination of Form 3520 + Form 8621 reporting makes individual Spanish pension plans among the most administratively burdensome accounts a US expat can hold.
• The math rarely works: Spain's annual deduction limit of €1,500 saves approximately €675 in Spanish income tax at 45% — while the compliance cost for a US tax attorney to handle Form 3520, 3520-A, and Form 8621 annually can easily run $1,500–$3,000+. Do not participate in a plan de pensiones without explicit US-specialist guidance.

Employer Pension Plans (Planes de Empleo)

Employer-sponsored Spanish pension plans (planes de empleo) have higher contribution limits (up to €8,500/year for employer contributions, plus €1,500 for employee contributions in 2026). These are somewhat less risky for US citizens if the plan's investments can be structured to avoid PFICs — but the Form 3520 analysis still applies. Large US multinationals with Spanish operations sometimes structure plans to hold US-domiciled assets; confirm this before participating.

6. FBAR and FATCA in Spain

Standard FBAR and FATCA reporting applies in full for all Spain-held accounts:

• FBAR (FinCEN 114): Required if aggregate foreign financial account balances exceed $10,000 at any point during the calendar year. Covers Spanish bank accounts (Santander, BBVA, CaixaBank, Bankinter, ING Spain, N26 ES), Spanish brokerage accounts (Self Bank, MyInvestor, eToro Spain), and other foreign accounts worldwide.
• Form 8938 (FATCA): For taxpayers living abroad, required if foreign assets exceed $200,000 single / $400,000 MFJ at year-end, or $300,000 / $600,000 at any point.
• Spain-IRS data sharing: Spain operates under a FATCA Model 1 IGA — Spanish financial institutions report US-accountholder information to the Agencia Tributaria, which shares it with the IRS. Your BBVA and Santander balances are visible to the IRS.
• Account access: Unlike Switzerland or Japan, major Spanish banks (Santander, BBVA, CaixaBank) generally maintain US-citizen accounts under FATCA. Confirm current policy when opening an account; some smaller Spanish banks have declined US citizens. Interactive Brokers' EU entity (IBCE) explicitly accepts US-citizen clients for investing in Spanish equities while holding US-domiciled ETFs.

7. US-Spain Income Tax Treaty

The US-Spain income tax treaty was signed in 1990 and remains in effect. It is a moderately comprehensive treaty providing reduced withholding rates on cross-border passive income. For US citizens living in Spain, its direct benefits are significantly limited by the saving clause.⁶

• Saving clause (Article 17): Each country reserves the right to tax its citizens and residents as if the treaty had not entered into force. For US citizens, the US retains full taxing rights on worldwide income regardless of Spanish residency or treaty position. Spain similarly taxes Spanish residents on Spanish-source income under domestic law independent of the treaty.
• Saving clause exceptions: The exceptions that do benefit US citizens include Article 9(2) (associated enterprises adjustments), Article 20(4) (pensions — limited benefit), Article 24 (relief from double taxation — FTC mechanism), Article 25 (non-discrimination), and Article 26 (mutual agreement procedure).
• Pensions (Article 20): Paragraph 4 provides that pensions paid by one contracting state's social security or public pension are generally taxable only in the source state. US Social Security benefits paid to Spain-resident US citizens are taxable only by Spain — not by the US (one of the narrow saving clause exceptions). Separately, Spanish Seguridad Social pension payments to US-resident recipients are taxable only by Spain, not the US.
• Reduced withholding: The treaty reduces Spanish withholding tax on dividends to 10% (5% for 25%+ corporate ownership), reduces withholding on royalties to 8%, and limits Spanish withholding on interest to 10%. For US investors with Spanish equity holdings or US companies with Spanish licensees, these rates apply.
• No treaty protection from PFIC rules: Spanish ETFs and investment funds are PFICs regardless of treaty position. The treaty provides no shelter from §1291 excess-distribution treatment or Form 8621 requirements.
• Beckham Law and the treaty: The Beckham Law is a Spanish domestic law regime. The treaty's saving clause allows the US to tax US citizens as if the treaty didn't exist — including on income that Spain exempts under Beckham. Foreign-source capital income that Spain exempts under the Beckham regime is still fully taxable by the US under domestic law.

8. Real Estate in Spain

Spain's coastal markets and urban centers (Barcelona, Madrid, Málaga) have attracted significant US-citizen real estate investment. Cross-border US tax issues are substantial:

• §121 exclusion: The US primary residence capital gains exclusion ($250,000 single / $500,000 MFJ) applies to Spanish property if it was your principal residence for at least 2 of the 5 years preceding sale. The gain is calculated in US dollars.
• Currency gain trap: If the euro strengthened between your purchase and sale date, you may owe US tax on currency gain even if the dollar-denominated property appreciation is covered by the §121 exclusion. A property purchased when €1 = $1.05 and sold when €1 = $1.15, with a €300,000 gain that the §121 exclusion covers, generates additional US-taxable dollar gain from the exchange-rate movement alone.
• Non-resident withholding at sale: If you sell Spanish property after departing Spain (as a non-resident), the buyer is required to withhold 3% of the sale price and remit it directly to the Agencia Tributaria on your behalf (Section 25 IRNR). This 3% is a withholding deposit against your Spanish capital gains tax obligation — you file a IRNR return and receive a refund if your actual tax is lower.
• Purchase taxes: Buying Spanish property involves either IVA (10% VAT on new construction) plus AJD stamp duty (0.75–1.5% depending on region), or ITP (Impuesto de Transmisiones Patrimoniales, 6–10% on existing property, varying by autonomous community). These transaction taxes are capitalized into your cost basis for US gain calculations, not creditable as FTC.
• Modelo 720 for US property: If you own US real estate while residing in Spain, that US property must be declared on Modelo 720 (Category 3) if its value exceeds €50,000.
• Wealth tax (Impuesto sobre el Patrimonio): Spain's national wealth tax was temporarily suppressed in some regions (Madrid exempts residents entirely), but exists in most autonomous communities. Rates range from 0.2% to 3.5% on net assets above €700,000 (with a €300,000 primary residence exemption). Spain-resident US citizens may owe both US estate tax (on worldwide assets above the $15M OBBBA exemption — permanent as of July 2025) and Spanish wealth tax on Spanish and worldwide assets.

9. Before You Move to Spain: A Planning Checklist

1. Model FTC vs FEIE before accepting a Beckham Law package. If your employer is arranging a Beckham Law regime, explicitly calculate both the Spanish tax (24% flat) and the US residual tax (37% − 24% = 13% gap on income above the FTC coverage). Build this into your relocation package negotiation — or ensure you understand the personal liability before accepting the package.
2. Apply for the Beckham Law within 6 months of Social Security registration. The window is strict. Missing it means you pay standard IRPF from day one — and retroactive applications are generally not accepted. Engage a Spanish gestor or abogado fiscal as soon as you register.
3. Sever US state domicile before departure. California, New York, and New Jersey have aggressive state domicile rules. California does not recognize FEIE and taxes residents on worldwide income based on domicile, not physical presence. See our state residency planning guide for the steps to sever cleanly.
4. Move US investment accounts to FATCA-compatible custodians before leaving. Fidelity retail and Vanguard retail commonly restrict non-US-resident accounts. Schwab International, Interactive Brokers, and TD Ameritrade International explicitly serve non-US-resident US citizens. Transfer before departure while you're still a US resident — far easier than transferring while abroad.
5. Avoid Spanish-domiciled ETFs and EU-domiciled UCITs funds entirely. Spanish banks default to Spanish or Luxembourg-domiciled products (iShares UCITS, Amundi Spain, Vanguard UCITS) that are PFICs. Hold only US-domiciled ETFs (VTI, VOO, BND, VXUS equivalent via US-listed VXUS) at a US or IBCE account. Do not buy any Spanish or EU-listed investment fund.
6. Do not open a plan de pensiones without US-specialist review. The €1,500 Spanish deduction is not worth Form 3520 + Form 8621 exposure. Skip the plan entirely unless you have confirmed specialist guidance that the specific plan structure avoids the principal US compliance traps.
7. Set up Modelo 720 tracking from day one. Every US account — Schwab, Fidelity, Chase, IRA, 401(k) — needs to be declared annually on Modelo 720. Create a spreadsheet tracking account names, numbers, institutions, and approximate year-end values from your first day of Spanish residency.
8. Consider Roth conversions before departure. If you are leaving the US while income is in a lower bracket, Roth conversions before becoming a Spanish tax resident create a permanently tax-free bucket. Once in Spain with income taxed at 24–37% on both sides, the marginal rate spread for conversions typically disappears.
9. Non-US-citizen spouse considerations. If your spouse is a Spanish national or another non-US citizen, estate planning requires careful attention. Non-citizen spouses do not qualify for the unlimited US marital deduction; the annual exclusion for gifts to a non-citizen spouse is $194,000 (2026).⁷ For estates above $15M (OBBBA, permanent), a Qualified Domestic Trust (QDOT) may be required. Read our non-US spouse guide.
10. Engage a US/Spain cross-border specialist before your first Spanish tax year ends. The most expensive mistakes — Beckham Law FTC shortfall, plan de pensiones PFIC accumulation, Modelo 720 missed filing — happen in the first year. The cost of specialist guidance is modest compared to the cleanup.

What a Spain-Specialist Expat Advisor Handles

Most US financial advisors cannot take non-US-resident clients or lack familiarity with Spanish tax law. Most Spanish asesores fiscales understand IRPF, Modelo 720, and Seguridad Social but have no US license and cannot advise on IRS matters. A US-licensed, fee-only advisor who focuses on Americans in Spain handles both sides:

• Model FTC vs FEIE for your specific Spanish income, Beckham Law status, and US filing situation — including quantifying the residual US federal tax bill under Beckham
• Advise on Beckham Law eligibility, application timing, and the 6-month deadline when relocating
• Identify PFIC exposure in any Spanish brokerage, fund platform, or insurance product and coordinate Form 8621 elections (QEF or MTM elections) to avoid §1291 excess-distribution penalties
• Assess plan de pensiones participation for Form 3520 exposure and PFIC holdings — and recommend whether to participate at all
• Coordinate Modelo 720 obligations with FBAR and Form 8938 — separate filings, separate deadlines, same underlying accounts
• Handle Spanish real estate: §121 exclusion planning, currency gain modeling, Modelo 720 for US property, ITP/IVA as basis adjustments
• Plan state domicile severance before departure; advise on California and New York audit risk
• Advise on the Seguridad Social totalization agreement for autónomos and the self-employment tax exemption
• Non-US spouse planning: annual gift exclusion ($194,000 in 2026), QDOT trust for large estates, FBAR coordination for Spanish-citizen spouse accounts
• Coordinate with your Spanish asesor fiscal so that the Spanish IRPF return and US return are consistent on income figures, treaty positions, and exchange rates

1. IRS Publication 54, Tax Guide for US Citizens and Resident Aliens Abroad. 2026 FEIE limit: $132,900 per IRS Rev. Proc. 2025-28. irs.gov/publications/p54
2. PwC Spain Tax Summary 2026 — Individual taxes on personal income. IRPF combined rates (state + average autonomous community rates). Spain savings income rates: 19%/21%/23%/27%/30% on income tiers. Regional variation: Comunidad de Madrid rates are the lowest nationally. taxsummaries.pwc.com/spain/individual
3. Agencia Tributaria: Régimen Especial de Trabajadores Desplazados (Beckham Law), Article 93 LIRPF. Expanded by Ley de Startups (Ley 28/2022, December 2022): 5-year prior non-residency requirement (down from 10), digital nomad visa eligibility, entrepreneur/startup option. 24% flat rate on Spanish income up to €600,000; 47% above. Six-year duration. GreenbackTaxServices.com: Beckham Law Spain 2026 guide. sede.agenciatributaria.gob.es
4. Agencia Tributaria: Modelo 720 — Declaración de bienes y derechos situados en el extranjero. Three categories, €50,000 threshold per category. Annual deadline January 1 – March 31. Post-ECJ penalty structure (CJEU Case C-788/19, February 24, 2022): €20/item, min €300, max €20,000; doubled for non-EU assets; 50% reduction for voluntary late filing. Lawants.com: Modelo 720 in Spain 2026 guide. Modelo 720 — Agencia Tributaria
5. SSA: Agreement Between the United States and Spain (Totalization Agreement). In force April 1, 1988. Self-employed workers residing in Spain: Spanish SS coverage; exempt from US self-employment tax. WEP and GPO repealed by the Social Security Fairness Act, Pub. L. 119-4 (January 5, 2025). ssa.gov — US-Spain Totalization Agreement
6. IRS: Spain Tax Treaty Documents. US-Spain Income Tax Convention (1990), Technical Explanation. Saving clause: Article 17. Pension provision: Article 20(4). Withholding rates: dividends 10%/5%, interest 10%, royalties 8%. irs.gov — Spain treaty documents
7. IRC §2523(i): Annual exclusion for gifts to non-citizen spouses. 2026 amount: $194,000 per IRS Rev. Proc. 2025-28 (inflation-adjusted). OBBBA (July 2025): estate and gift exemption permanently set at $15M. IRS Rev. Proc. 2025-28

Tax values verified as of May 2026. Spanish IRPF rates are 2026 combined (state + average regional) per PwC Spain Tax Summary 2026. Beckham Law terms per Agencia Tributaria and Ley de Startups (Ley 28/2022). US values are for tax year 2026. Consult a qualified cross-border specialist for your specific situation.