Moving to Spain from Germany requires managing two tax systems simultaneously. On departure, German shareholders holding at least 1% in a GmbH or AG face Wegzugsbesteuerung (§6 AStG): Germany assesses a fictitious capital gain on the unrealised appreciation of those shares. Since 1 July 2021, the old unlimited EU deferral no longer exists; shareholders can apply for payment in seven interest-free annual instalments. On arrival, Spain becomes your country of tax residence after 183 days in a calendar year (Art. 9, Ley 35/2006). The Beckham Law (Art. 93 LIRPF, as amended by Ley 28/2022) then offers qualifying inbound workers a flat 24% IRPF rate on Spanish employment income up to €600,000 for six years. The Spain-Germany Double Tax Treaty, signed on 3 February 2011 and in force since 2013, governs which country taxes each income stream — employment income, dividends, pensions, and capital gains from real estate each follow different rules. German citizens moving to Spain need no visa, but must register as EU residents within three months of arrival.
What Changes When You Move from Germany to Spain?
Relocating from Germany to Spain involves two distinct administrative and tax transitions running in parallel: closing out your German obligations and establishing Spanish ones. Understanding which steps trigger which consequences — and in what order — is the foundation of a well-planned move.
How German tax residency ends
Your unlimited German tax liability (unbeschränkte Steuerpflicht) ends when you give up your last German domicile or habitual place of residence. The administrative act that formalises this is the Abmeldung — a formal deregistration at your local Einwohnermeldeamt (residents' registration office). In addition to the Abmeldung, you should notify your German Finanzamt (tax office) directly — a separate step known as the Steuerliche Abmeldung — to ensure German tax authorities have a record of your departure date. Failing to do either of these is one of the most common mistakes Germans make when moving abroad, and it can leave you technically resident (and taxable) in Germany for longer than intended.
Once unlimited tax liability ends, Germany retains the right to tax certain German-source income under the rules of limited tax liability (beschränkte Steuerpflicht) and, where the Spain-Germany Double Tax Treaty applies, under its specific income allocation articles. For most employees without German corporate shareholdings, the German-side obligations after departure are relatively straightforward: a final year income tax return, and an ongoing obligation to declare German rental income or receive German pension payments. For founders and shareholders, the picture is considerably more complex — addressed in the section on Wegzugsbesteuerung below.
How Spanish tax residency begins
Spanish tax residency attaches automatically once you spend more than 183 days in Spain within a calendar year, per Art. 9 of the Ley 35/2006 del IRPF. A secondary trigger exists if Spain becomes the centre of your economic interests — for example, if the majority of your income sources or business activities are located in Spain, even before the 183-day threshold is reached. The important implication is that the clock starts from 1 January of the calendar year, not from your date of arrival. Someone arriving in July 2026 cannot become a Spanish tax resident for the 2026 tax year even if they accumulate 183 days before year end; they would become resident from 1 January 2027 at the earliest — unless the centre-of-interests test triggers earlier.
As an EU citizen, you have the right to reside in Spain under EU freedom of movement law. However, stays beyond three months require formal registration as an EU resident, obtaining a Certificado de Registro de Ciudadano de la UE. This certificate is not a visa — it is a declaration of residence. You will also need a NIE (Número de Identificación de Extranjero), which is required for most administrative and tax interactions in Spain, and an Empadronamiento — registration on the municipal census of your Spanish town or city. These three documents are the administrative foundation on which everything else — Social Security registration, Beckham Law application, bank accounts — is built.
EU citizens do not need a visa to live in Spain. However, stays beyond three months require formal registration as an EU resident (Certificado de Registro). The 183-day tax residency clock runs regardless of whether you have completed this administrative step.
Source: Art. 9 Ley 35/2006 LIRPF; EU Directive 2004/38/CE
What the Spain-Germany DTT covers
The Double Tax Treaty between Spain and Germany was signed on 3 February 2011 and entered into force in 2013. It follows the OECD Model Convention and covers income tax and wealth tax for residents of one or both contracting states. Its core function is to prevent double taxation by allocating taxing rights: for each category of income, the treaty specifies whether the source country (Germany), the residence country (Spain), or both countries can tax it — and where both can tax, it requires one country to provide a credit for the other's tax.
The treaty's tie-breaker rules (Art. 4) resolve cases of dual residency: if both countries claim you as resident, the treaty applies a cascade — permanent home, then habitual abode, then centre of vital interests, then nationality, then mutual agreement. Most Germans who move properly to Spain — completing Abmeldung, registering in Spain, and having no continuing German domicile — will clearly be Spanish tax residents under Art. 4 from the first full calendar year of Spanish residence. Note that the Beckham Law regime does not change this DTT residency classification: Beckham filers are still treated as Spanish tax residents for treaty purposes.
Wegzugsbesteuerung: Germany's Exit Tax on Shareholders
For German professionals without corporate shareholdings, departure from Germany raises no unusual exit tax issues beyond a final income tax return. For founders and shareholders, it raises one of the most financially significant questions in German international tax law.
When exit tax applies
The Wegzugsbesteuerung (§6 AStG) applies when a person ends their unlimited German tax liability and, at the time of departure, holds at least 1% of the shares in a corporation — German or foreign — as private assets. A second condition must also be met: the person must have been subject to unlimited German tax liability for at least seven of the last twelve years. If both conditions are satisfied, German tax law treats the departure as a deemed disposal of the shares at their fair market value on the date of exit, even though no actual sale has taken place. The resulting fictitious capital gain — the difference between the current market value of the shares and their acquisition cost — is subject to German income tax in the year of departure. Because the Teileinkünfteverfahren (partial income procedure) applies, 60% of the gain is taxable; at a top marginal rate of 45% plus Solidarity Surcharge, the effective tax rate on the gain can reach approximately 28%.
From 1 January 2025, the exit tax was extended to investment fund shares held as private assets via §19(3) of the Investmentsteuergesetz (InvStG). An individual who holds 1% or more of the units in an investment fund — or fund units with an acquisition cost of at least €500,000 — now faces exit tax on departure, in addition to the existing rules for corporate shares.
The 7-year instalment option — not a deferral
This is the most common planning misconception for Germany-to-Spain moves. Under the old law (before the ATAD reform, which took effect on 1 July 2021), moving to another EU or EEA country entitled the departing taxpayer to an unlimited, interest-free deferral of exit tax — effectively suspending the liability until the shares were sold. That regime no longer exists for departures from 1 January 2022 onwards.
Under the current rules, the exit tax is assessed and falls due in the year of departure. There is no automatic suspension. What a taxpayer can apply for is a payment arrangement: the outstanding liability can be split into seven equal, interest-free annual instalments (§6 Abs. 4 AStG). This instalment arrangement is conditional — it can be revoked if the shares are sold, transferred, or if the taxpayer moves to a non-EU country. During the instalment period, annual reporting obligations to the German Finanzamt apply. The Ratenzahlung (instalment plan) provides liquidity relief, but it does not postpone the tax event itself.
Since July 2021, Germany's unlimited EU exit-tax deferral no longer exists. For moves from 2022 — including to Spain — the tax is assessed in the year of departure. A 7-year interest-free instalment plan is available on application; it is not automatic.
Source: §6 Abs. 4 AStG (ATADUmsG reform)
Last verified: Jun 2026
The 7-year return rule remains fully intact. If the departing taxpayer returns to Germany within seven years of departure — extendable to twelve years with a one-time formal application — and continues to hold the shares throughout, the exit tax is annulled retroactively.
| Scenario | Exit Tax Treatment | When Tax Falls Due | Conditions |
|---|---|---|---|
| Move to Spain (EU) | Assessed in year of departure; 7-year interest-free instalment plan available on application (§6 Abs. 4 AStG) | Year of departure (payable in 7 annual instalments if approved) | Annual reporting to Finanzamt; instalments revocable on share sale or move to non-EU country |
| Move to UK, US, or UAE (non-EU/EEA) | Assessed in year of departure; instalment plan also available on application, but collateral or guarantee may be required | Year of departure | More complex conditions; immediate payment may be required if guarantee not accepted |
| Return to Germany within 7 years | Exit tax annulled retroactively (§6 Abs. 3 AStG) | N/A — tax liability extinguished on return | Must return within 7 years (extendable to 12); must have held shares throughout absence |
Who is not affected by Wegzugsbesteuerung
Employees without corporate shareholdings are entirely outside the scope of §6 AStG. Self-employed individuals (Selbstständige) operating as sole traders, without an incorporated GmbH or AG structure, are also unaffected — the exit tax targets shares in corporations, not personal business goodwill or professional practices. Shareholders who have been in Germany for fewer than seven of the last twelve years do not meet the residency threshold and are similarly excluded.
A separate note for German nationals specifically: §2 AStG establishes an extended limited tax liability (erweiterte beschränkte Steuerpflicht) that can apply to German citizens who move to a low-tax jurisdiction and retain significant German economic interests. Standard Spanish taxation is broadly comparable to German rates and would not typically trigger this provision. However, German nationals who move to Spain and obtain the Beckham Law regime — which provides a preferential tax treatment (Vorzugsbesteuerung) — may potentially be treated as having moved to a low-tax jurisdiction under §2 Abs. 2 AStG. Whether this provision engages depends on individual circumstances, including the volume of retained German economic interests. Professional German tax advice is strongly recommended for German nationals planning to use the Beckham Law before moving.
Kirchensteuer: The German Church Tax You Must Formally Cancel
For anyone who has worked in Germany and registered their religion at the Bürgeramt, this is one of the most overlooked items on a pre-departure checklist — and one of the few where inaction has an ongoing financial cost.
What Kirchensteuer is and why it persists after departure
German church tax is a state-administered levy collected on behalf of recognised religious communities — primarily Catholic and Protestant (Evangelisch) — from registered members who are subject to German income tax. It is calculated as a percentage of your annual income tax bill: 8% in Bavaria and Baden-Württemberg, and 9% in all other Bundesländer. Because it is collected through the standard payroll or tax return system, most employees never actively notice it until they examine a payslip closely and spot the KS line.
The liability attaches to two conditions: membership of a collecting religious community (as registered on your Anmeldung form) and German income tax liability. When you leave Germany and end your unlimited tax liability, the second condition falls away — but only for German-source income that is no longer subject to withholding. More practically: the registered membership does not automatically dissolve when you deregister your German address (Abmeldung). If you have not formally left the church before departure, the membership record persists.
Kirchenaustritt — the only way to stop it
The formal process of leaving a tax-collecting church in Germany is called Kirchenaustritt (church exit declaration). It must be done in person — no postal or online option exists. Depending on your Bundesland, you go to either the Standesamt (civil registry office) or the Amtsgericht (local district court). You will need valid ID and your current Meldebescheinigung (registration confirmation). The process takes approximately 15 minutes. The administrative fee ranges from €0 in Hamburg and Berlin to around €30 in Bavaria and Baden-Württemberg — some Länder charge up to €60. On completion, you receive an Austrittsbescheinigung (exit certificate). The Kirchensteuer deduction stops from the end of the month following your declaration — not retroactively.
Kirchensteuer does not stop when you move abroad. If you remain registered as a church member at Abmeldung time, the obligation persists. Complete the Kirchenaustritt before your last day in Germany — around 15 minutes at your local Standesamt or Amtsgericht.
Source: Kirchensteuergesetze der Länder
Do this before your departure, not after. Completing the Kirchenaustritt once you are no longer resident in Germany requires coordinating with German authorities from abroad, which is considerably more cumbersome than a fifteen-minute in-person visit before you leave. Some German dioceses also maintain contact with affiliated churches in other countries; for Catholics who were baptised abroad and have church records on file, membership can sometimes be traced even after a German Abmeldung if the Kirchenaustritt was not completed.
The Beckham Law for Germans Moving to Spain
The Beckham Law is the first tax question most German professionals ask when considering a move to Spain. It is also the question where the answer depends most heavily on how you are employed and how you structure your Spanish entry.
Can German nationals use the Beckham Law?
Yes — the Beckham Law has no nationality restriction. The qualifying criteria under Art. 93 of the Ley 35/2006 (LIRPF), as significantly expanded by the Ley 28/2022 (Startup Law), are structural rather than nationality-based. The key tests are: you must not have been a Spanish tax resident in the five tax years immediately before your arrival in Spain; and your move to Spain must be connected to qualifying work activity — employment, entrepreneurship, or highly qualified professional services.
For a German professional who has never previously lived in Spain, the five-year lookback test is not an issue — it is the structural path that matters. Remote employees working for a non-Spanish employer are eligible, particularly where entry is via the Digital Nomad Visa route. Standard freelancers operating as autónomos without a qualifying startup or innovation classification are generally excluded from the Beckham Law and would instead access the DNV tax regime under Ley 28/2022. Founders of companies classified as innovative startups under the Startup Law can qualify via the entrepreneurial route, even with a majority shareholding. Company directors with less than 25% of the employing company's share capital can qualify via the employment/director route.
What the Beckham Law does for a German mover
Once the Agencia Tributaria (AEAT) accepts your application, you are a Spanish tax resident taxed as if you were a non-resident. Only Spanish-source income falls within the Spanish IRPF net. Employment income and business income from Spanish sources is taxed at a flat 24% up to €600,000 per year; income above €600,000 is taxed at 47%. Foreign income — including German dividends, German pension payments, and German rental income — is entirely exempt from Spanish IRPF during the six-year regime period. You are also exempt from Modelo 720 reporting obligations while under the regime, and wealth tax is limited to Spanish assets only.
The DTT interaction matters here. Germany retains withholding rights on certain German-source income even during your Beckham period: dividends from German companies are subject to German withholding at up to 15% (CDI Art. 10), government civil servant pensions remain taxable only in Germany (CDI Art. 17). Because these income streams are exempt from Spanish IRPF under the Beckham regime, there is no Spanish credit mechanism to offset the German withholding — you simply pay German withholding with no Spanish counterpart. The result is not double taxation, but neither is it zero taxation on those streams.
Note for German nationals specifically: if you intend to use the Beckham Law and retain significant German economic interests (shareholdings, rental property, German pension income exceeding certain thresholds), the interaction with §2 AStG's Vorzugsbesteuerung provision is a planning consideration that requires professional German tax advice before you move.
The Beckham Law application — Modelo 149
Beckham Law Application: Five Steps for German Professionals
Arrive in Spain and register with Social Security
Complete your Certificado de Registro as an EU citizen, obtain your NIE, and register with the TGSS (Tesorería General de la Seguridad Social) for your first Spanish Social Security alta. This registration date starts the 6-month clock for your Beckham Law application.
Gather your supporting documentation
You will need: your employment contract with a Spanish employer or the applicable visa documentation (for DNV route), proof of non-Spanish tax residency in the previous five years, passport, NIE, and Social Security alta certificate. Prepare German-side documents (e.g. last German tax assessment) to demonstrate prior non-residency.
File Modelo 149 within six months of your Social Security alta
The Modelo 149 is the formal election form for the Beckham Law regime. It must be filed with the AEAT within six months of your first Spanish Social Security registration date — not your date of arrival. Missing this window is irrecoverable: there is no late application mechanism.
Receive AEAT confirmation
AEAT processes the application and issues a recognition certificate. This can take several weeks. You may begin operating as a Beckham Law taxpayer during this period, but your employer (if applicable) will need the certificate to withhold at the 24% flat rate rather than the progressive IRPF rate.
File annual Modelo 151
During the six years of the regime, your annual Spanish income tax return is filed on Modelo 151 (not the standard Modelo 100 used by regular IRPF taxpayers). This model reports only Spanish-source income and applies the flat rate.
The Beckham Law window starts from your Social Security alta date — not your arrival date. Spending weeks on accommodation before registering with Social Security shortens your window. Register with Social Security as early as possible after arriving.
Source: Art. 116 RIRPF; Real Decreto 1008/2023
Specific Scenarios: Remote Employee, Freelancer, Founder
The Germany-to-Spain move looks very different depending on how you work. The German-side and Spanish-side decisions are interconnected, and the optimal path varies substantially across these three profiles.
The remote employee
For a German employee working remotely for a non-Spanish employer — a tech worker, a product manager, a consultant on a foreign payroll — the move is typically the most straightforward of the three profiles. No Wegzugsbesteuerung applies because there is no qualifying corporate shareholding. The Kirchenaustritt should be completed before departure if church tax applies.
In Spain, the remote employee has two primary structural options. The first is entry as an EU citizen (no visa required), registering as a tax resident after 183 days, and applying for the Beckham Law through the employment displacement route. The second, and more commonly recommended route for employees of non-Spanish companies, is the Digital Nomad Visa (DNV), which provides both a work permit and access to the DNV tax regime under Ley 28/2022 — also a flat 24% IRPF rate for the qualifying period. Note that the Beckham Law and the DNV tax regime are distinct legal frameworks; you apply through one or the other, not both simultaneously.
German pension: the worker's DRV contribution record continues to accumulate until they leave German Social Security. Contributions already made remain in the DRV system. On reaching German retirement age, the DRV pays the accrued pension to any address in the world — including Spain — under EU portability rules. Spain and Germany are both EU members, so contribution periods in both countries are aggregated when calculating pension eligibility thresholds.
The freelancer
A German self-employed professional moving to Spain does not face Wegzugsbesteuerung from §6 AStG, as there is typically no qualifying shareholding in a corporation. In Spain, the freelancer must register as autónomo (Régimen Especial de Trabajadores Autónomos, RETA). Since January 2023, monthly Social Security contributions for autónomos are determined by estimated net income under an income-based system. The Beckham Law is generally not available to standard autónomos unless they qualify under the startup or highly-qualified-professional routes defined in Ley 28/2022. The DNV tax regime is available to qualifying self-employed professionals under the Digital Nomad Visa, providing the same 24% flat rate through a different legal mechanism.
The founder
The founder profile — someone holding a meaningful stake in a German GmbH or AG — faces the most complex transition. The starting question is whether §6 AStG applies, and if it does, whether the 7-year instalment plan is appropriate or whether structural pre-departure planning (for example, timing the move, restructuring the holding, or exploring a Blocker KG arrangement) is worth considering before departure. These decisions should be made with a German tax advisor well in advance — ideally 12 to 18 months before the planned move date.
§6 AStG exit tax is assessed in your year of departure — the 7-year instalment option relieves cash flow but does not defer the tax event itself. Reviewing your GmbH or AG structure 12-18 months before the move is significantly more effective than planning after.
Source: §6 AStG (ATADUmsG); §6 Abs. 4 AStG
Last verified: Jun 2026
In Spain, a founder of an innovative startup — one classified under the criteria of Ley 28/2022 — can access the Beckham Law via the entrepreneurial route (Art. 93.1.d LIRPF), even with a majority shareholding in the Spanish company. A founder not meeting the startup innovation criteria can still qualify via the director route if they hold less than 25% of the company. During the Beckham period, German GmbH dividends paid to a Spanish-resident Beckham filer are exempt from Spanish IRPF. Germany will withhold at up to 15% under CDI Art. 10. From year seven onward — when the Beckham window closes — those dividends flow into the Spanish IRPF base at progressive rates, and German withholding becomes creditable.
Real Numbers: German vs. Spanish Tax on a €120,000 Salary
Abstract claims about tax savings are easy to make and easy to question. A worked example grounds the comparison.
German baseline — before the move
A German employee earning €120,000 gross in 2026, filing as a single taxpayer in NRW, faces the following approximate tax position. Taxable income after the Werbungskostenpauschale (standard employee deduction of €1,230) is approximately €118,770. Applying the §32a EStG 2026 progressive formula — with the Grundfreibetrag at €12,348, the 42% Spitzensteuersatz bracket starting at €69,879, and the 45% Reichensteuer above €277,826 — yields an income tax liability of approximately €37,000 to €40,000. The Solidarity Surcharge (5.5% of income tax) adds a further €2,000 to €2,200, bringing combined income tax and Soli to approximately €39,000 to €42,000. Church tax at 9% (NRW) adds a further €3,500 to €3,800 for registered members. Employee Social Security contributions total approximately €20,000 to €21,000 annually (capped at respective contribution ceilings). The effective income tax rate (income tax plus Soli only, excluding SS) is approximately 33-35%.
Spain under the Beckham Law
The same €120,000 in Spanish employment income under the Beckham Law produces a radically simpler calculation. The flat rate is 24%, applied to the full €120,000: income tax equals €28,800. No regional surcharge. No progressive complexity. Employee Social Security contributions in Spain are 6.35% of gross salary: €7,620. No Kirchensteuer equivalent in Spain. German-source income (dividends, pensions, rental income outside Spain) is entirely exempt from Spanish IRPF during the six Beckham years.
| Tax Scenario | Income Tax (approx.) | Solidarity Surcharge | Employee Social Security | Effective Income Tax Rate |
|---|---|---|---|---|
| Germany (resident, NRW, single) | €37,000–€40,000 | €2,000–€2,200 | ~€20,000–€21,000 | ~33–35% |
| Spain — Beckham Law (years 1–6) | €28,800 (flat 24%) | None | €7,620 (6.35%) | 24% |
| Spain — Standard IRPF (year 7+, Madrid) | ~€33,000–€37,000 | None | €7,620 (6.35%) | ~30–33% |
A German professional on €120,000 pays roughly €28,800 in income tax under Spain Beckham Law — compared to upwards of €39,000 under German rates including Soli, before social contributions.
— ApexTax analysis, 2026
Year seven and beyond
When the six-year Beckham window closes, Spain's standard IRPF applies in full. Worldwide income becomes taxable in Spain, including German pension payments, German rental income, German dividends, and any other foreign income streams that were previously exempt. German withholding on those streams becomes creditable against Spanish IRPF. The standard Spanish progressive rates reach 47% at the national level for income above €300,000; regional surcharges add to this in communities like Catalonia. Madrid is the most tax-efficient community for high earners at standard rates. Planning for year seven — particularly the timing of GmbH dividend distributions or property sales during the regime versus after — is one of the most valuable pre-expiry conversations a Beckham filer can have with a Spanish tax advisor.
Five Mistakes Germans Commonly Make When Moving to Spain
Forgetting the Kirchenaustritt before departure
Church tax does not stop because you leave Germany. If you are still registered as a member of a tax-collecting religious community when you deregister your German address (Abmeldung), that registration persists. Completing the Kirchenaustritt after moving abroad requires coordinating with German civil authorities from a foreign country — substantially more difficult than a fifteen-minute in-person visit before you leave. Do it before you go, even if you are not sure whether you are still registered.
Missing the six-month Beckham Law window
The Beckham Law application window opens on the date of your first Spanish Social Security alta and closes six months later. It cannot be extended. German professionals who spend weeks sorting out accommodation, bank accounts, and documentation before registering with Social Security are eroding their window. If you miss the deadline — even by a day — you cannot apply for that move to Spain. The regime is gone for good.
The Digital Nomad Visa and Beckham Law both offer a 24% flat rate but via separate regulations (Ley 28/2022 vs Art. 93 LIRPF). You cannot apply for both simultaneously. Determine which route fits your employment structure before arriving in Spain.
Source: Ley 28/2022; Ley 35/2006, Art. 93
Not completing both the Abmeldung and Steuerliche Abmeldung
Many Germans who move abroad complete the Abmeldung (deregistration at the Einwohnermeldeamt) but do not separately notify their Finanzamt. The Steuerliche Abmeldung — a formal letter or form notifying your tax office of your departure — is distinct from the municipal deregistration. Without it, your Finanzamt may not know your departure date, may continue to send correspondence to your old address, and may assess income tax on the assumption of continued residency.
Triggering Spanish tax residency without a Beckham Law application in place
A German professional who arrives in Spain, spends more than 183 days in the calendar year, and does not file Modelo 149 by the applicable deadline defaults to standard IRPF — progressive rates on worldwide income. This happens more often than it should: people arrive, build a life, and only seek tax advice in April when their first Spanish tax year is already over. If you are going to move to Spain in a way that makes you tax resident, the Beckham Law timeline needs to be part of your pre-departure planning, not an afterthought.
Confusing the Beckham Law and the DNV tax regime
Both offer a 24% flat rate. But they are governed by different laws, have different eligibility criteria, require different application procedures, and have different implications for Social Security and DTT interaction. Applying via the wrong route — or applying for both simultaneously — is a compliance risk that can result in rejection or retrospective IRPF liability at progressive rates.
German nationals who do not complete a formal Abmeldung at the Einwohnermeldeamt may retain German tax residency on paper. The Abmeldung and the Steuerliche Abmeldung (notification to Finanzamt) are two separate steps — both are required.
Source: §8 Abgabenordnung (AO); §1 EStG
Ongoing German Tax Obligations After the Move
Leaving Germany does not necessarily mean leaving all German tax obligations behind. For most German movers, a set of continuing German-source income streams will require attention for years — sometimes decades — after departure.
German pension payments
German statutory pension entitlements (gesetzliche Rentenversicherung, Deutsche Rentenversicherung) continue to accrue any remaining contributions and are paid to any address in the world upon reaching retirement age, including Spain. Under EU portability rules (Regulation 883/2004), contribution periods in Germany and Spain are aggregated when calculating pension eligibility thresholds. The DRV issues the pension in euros and transfers it to your Spanish bank account.
Under CDI Art. 17, the Spain-Germany DTT allocates taxing rights as follows: private and social security pensions (Altersrente from the DRV, occupational pensions, Riester, Rürup) are taxable primarily in Spain as the country of residence. Government and civil servant pensions (Beamtenpension) are taxable only in Germany. In practice, this means you should apply to the German Bundeszentralamt für Steuern (BZSt) for a Freistellungsbescheinigung (withholding exemption certificate) once you become Spanish tax resident, instructing Germany to stop withholding income tax on your DRV pension — since Spain will tax it. The process requires a Spanish tax residency certificate (certificado de residencia fiscal from AEAT) as supporting documentation.
German rental income and capital gains
German rental income from property you continue to own in Germany is taxable in both Germany and Spain under CDI Art. 6. Germany taxes it as a non-resident (beschränkte Steuerpflicht) at progressive rates; Spain taxes it as worldwide income under IRPF, with a credit for German tax already paid. There is no double taxation, but there is dual filing — a German non-resident income tax return and a Spanish IRPF return both including the German rental income.
German dividends and the Modelo 720 question
German dividends received after your Spanish tax residency begins are subject to German withholding (up to 15% under CDI Art. 10). Under standard IRPF, Spain credits this withholding against your Spanish tax liability. Under the Beckham Law, German dividends are entirely exempt from Spanish IRPF — the German withholding is not creditable in Spain but neither is there any Spanish tax to pay on those dividends.
The Modelo 720 — Spain's mandatory declaration of foreign assets exceeding €50,000 per category — does not apply to Beckham Law filers during the regime period. Once you transition to standard IRPF in year seven, German bank accounts, German share portfolios, German real estate, and German pension accounts with a capitalised value above €50,000 per category must be declared on Modelo 720.
The TEAC (Tribunal Económico-Administrativo Central) issued a binding ruling in July 2025 (Resolución 3697/2025) requiring Beckham Law filers to include imputed rental income from their Spanish primary residence as taxable income — a position the TSJ Madrid (Sentence 665/2025, September 2025) has contested. The legal dispute remains unresolved pending a Supreme Court ruling. Conservative filers should include the imputed income; the matter should be reviewed with a Spanish tax advisor at filing time.
How ApexTax Helps German Professionals Move to Spain
Moving from Germany to Spain involves more decisions in more jurisdictions than almost any other intra-EU relocation. The German side requires coordinating Abmeldung, Kirchenaustritt, Wegzugsbesteuerung assessment, pension record management, and — where applicable — GmbH exit planning. The Spanish side requires structuring the right tax regime entry (Beckham Law, DNV, or standard IRPF), registering with the correct Social Security scheme, and timing the Modelo 149 application correctly. Both sides need to align.
ApexTax works as a Tax Strategy Consultancy and Single Point of Contact for the full transition — designing the sequence of steps, identifying which regime fits your employment and ownership structure, and coordinating the vetted qualified professionals who execute the technical implementation on both sides of the border.
Implementation of Wegzugsbesteuerung assessment, Modelo 149 filing, Social Security registration, and German pension administration is delivered by independent qualified professionals — German tax advisors and Spanish tax advisors — selected and coordinated by ApexTax. We do not file Modelo 149 ourselves, represent applicants before the AEAT or the German Finanzamt, or provide formal German or Spanish tax advice.