European tax arbitrage: Beckham Law vs. NHR 2.0 vs. Greece 50%

Spain, Portugal, and Greece are fighting over the same founders. Each offers a special tax regime designed to attract high-income remote workers and entrepreneurs. The rates are attractive. The marketing is aggressive. The expiration dates are the part nobody mentions.

These regimes all have one thing in common: they end. Five years. Seven years. Twelve years. And when they end, you’re back to the country’s standard rates — which are among the highest in Europe. If you didn’t plan for the exit before you entered, the exit becomes the problem.

Key takeaways:

• Spain’s Beckham Law: 0% on foreign dividends for 6 years — best rate, but exit tax on departure
• Portugal NHR 2.0: no longer exempts foreign income — only competitive if you qualify as a researcher/innovator
• Greece 50% exemption: ~18% effective rate for 7 years, no exit tax, no wealth tax — cleanest exit
• All three regimes expire. Plan the exit before you enter.
• If location doesn’t matter, territorial taxation is simpler, permanent, and cheaper than any European regime

This is the head-to-head comparison. Not just rates — eligibility, duration, what happens after, exit tax implications, and which one makes sense for a bootstrapped founder earning €200K-500K.

Spain: The Beckham Law (Ley Beckham)

Named after David Beckham, who used it when he signed with Real Madrid. Officially the Régimen de Impatriados (Impatriate Regime).

How it works

You’re taxed as a non-resident even though you live in Spain. Non-residents pay a flat rate on Spanish-source income and aren’t taxed on foreign income (with exceptions).

Detail	Rule
Duration	6 years (year of arrival + 5 full tax years)
Tax rate	24% flat on Spanish-source income up to €600K; 47% above €600K
Foreign income	Not taxed (except foreign employment income)
Capital gains	Taxed at standard rates (19-28%) on Spanish-source gains only
Wealth tax	Exempt from wealth tax on foreign assets
Foreign dividends	Tax-free if from non-Spanish companies

Eligibility

• Must not have been a Spanish tax resident in the 5 years before arrival
• Must have a reason to move to Spain (employment contract, company director role, or entrepreneur visa)
• Must apply within 6 months of registering as a tax resident
• Remote workers employed by foreign companies can qualify — this was extended in the 2023 Startup Law

For a founder earning €300K

If your income comes as dividends from a foreign company (e.g., a foreign company you own), under the Beckham Law:

• Foreign dividends: €0 tax
• Spanish-source salary (if you pay yourself from a Spanish entity): 24% flat = €72K on €300K
• If structured entirely through foreign dividends: effectively 0% on foreign income

The catch

After 6 years, you’re a standard Spanish tax resident. Spain’s personal income tax reaches 47% at the top marginal rate. Capital gains are 19-28%. Spain has a wealth tax. And Spain has an exit tax on assets over €4M or 25%+ holdings over €1M.

If you’ve been in Spain for 6 years under Beckham and then want to leave, you may face:

• Full Spanish tax rates if you stay past the regime’s expiration
• Exit tax on appreciated assets if you leave
• The need to have planned your next move before the regime expires

Verdict

The Beckham Law is excellent for a defined stay — 5-6 years in Spain with foreign income structured through a non-Spanish company. It’s dangerous if you drift past the expiration without a plan.

Portugal: NHR 2.0 (Incentivo Fiscal à Investigação Científica e Inovação)

Portugal killed the original Non-Habitual Resident (NHR) regime in 2024. Its replacement — sometimes called NHR 2.0 — is narrower, less generous, and harder to qualify for.

How it works

The new regime targets scientific research and innovation rather than general high-income individuals. The tax benefit is a flat 20% rate on eligible Portuguese-source income.

Detail	Rule
Duration	10 years
Tax rate	20% flat on eligible Portuguese-source income
Foreign income	Taxed at standard progressive rates (up to 48%) — not exempt
Eligible activities	Teaching, scientific research, qualified professions (engineers, doctors, artists), startup founders under certain conditions
Capital gains	Taxed at standard rates
Pensions	Taxed at 10% flat (grandfather clause for existing NHR holders)

Eligibility

• Must not have been a Portuguese tax resident in the 5 years before arrival
• Must engage in a qualifying activity in Portugal
• Much narrower than the original NHR — not all high-income individuals qualify

For a founder earning €300K

Under NHR 2.0, the picture is significantly worse than the original NHR:

• Foreign dividends from your own company: taxed at standard Portuguese rates (up to 28% on dividends, up to 48% on other income)
• Portuguese-source income from a qualifying activity: 20% flat
• If you don’t qualify as doing “scientific research or innovation”: standard Portuguese rates apply

The catch

NHR 2.0 is not the original NHR. The original exempted foreign income entirely. The replacement taxes foreign income at standard rates. For a founder with a foreign company distributing dividends, Portugal’s NHR 2.0 offers almost no advantage over being a regular Portuguese tax resident.

If you’re already in Portugal under the original NHR (grandfathered in), you’re fine. If you’re considering Portugal fresh in 2026 — the Beckham Law is better unless you qualify as a researcher or innovator.

Verdict

Portugal’s NHR 2.0 is a shadow of the original program. The 20% flat rate on Portuguese-source income is nice, but the loss of foreign income exemption makes it uncompetitive for founders with foreign companies. Unless you genuinely qualify as working in research or innovation, look elsewhere.

Greece: The 50% income tax exemption

The least known of the three, and arguably the most interesting for founders who want to stay in the EU long-term.

How it works

Greece offers a 50% exemption on employment and business income for new tax residents who take up employment or start a business in Greece.

Detail	Rule
Duration	7 years
Tax rate	Standard Greek rates, but only on 50% of income
Effective rate on €300K	~22% (vs. ~44% without the exemption)
Foreign income	Taxed — but at the 50% reduced base
Capital gains	Standard rates
Wealth tax	None (Greece has no wealth tax)

Eligibility

• Must not have been a Greek tax resident in 5 of the last 6 years
• Must transfer tax residence to Greece
• Must provide services under employment or run a business
• Applies to both employed and self-employed individuals

For a founder earning €300K

Greek progressive income tax rates on the 50% base:

Taxable Income (50% of actual)	Rate
First €10,000	9%
€10,001-€20,000	22%
€20,001-€30,000	28%
€30,001-€40,000	36%
Above €40,000	44%

On €300K income, your taxable base is €150K. Total tax: approximately €55,000. Effective rate: ~18.3%.

Compare to Spain’s Beckham Law on foreign dividends (0%) or standard Greek rates without the exemption (~44% on €300K = ~€110K).

The catch

• 7 years is longer than Beckham’s 6 — more time at reduced rates
• Greece has no wealth tax — unlike Spain
• Greece has no exit tax on most assets — unlike Spain, France, Germany, Norway
• After 7 years, you’re back to standard Greek rates (up to 44%)
• Greece’s banking and infrastructure is good but not on par with Western Europe

Verdict

Greece’s 50% exemption is the most overlooked option. No wealth tax, no exit tax, 7-year duration, and an effective rate of ~18% on €300K. It’s not as aggressive as Beckham’s 0% on foreign dividends, but it’s simpler, applies to all income (not just foreign), and leaves you in a country with no exit tax when you’re ready to go.

The comparison table

Factor	Spain (Beckham)	Portugal (NHR 2.0)	Greece (50%)
Duration	6 years	10 years	7 years
Best rate on €300K foreign dividends	0%	~28%	~18%
Best rate on €300K salary	24% flat	20% flat (if qualifying)	~18%
Foreign income treatment	Exempt (most types)	Taxed at standard rates	Taxed at 50% base
Wealth tax	Exempt on foreign assets	None under regime	No wealth tax
Exit tax	Yes (>€4M or 25%+ holdings >€1M)	Yes (EU deferral available)	No
CRS participant	Yes	Yes	Yes
Quality of life	High	High	High
Cost of living	Moderate-high	Moderate	Low-moderate
Residency difficulty	Moderate (entrepreneur visa)	Moderate	Moderate

The exit strategy (before you enter)

This is the part every comparison ignores. What happens when the regime expires?

After Beckham (Spain, year 7+)

You’re now a standard Spanish tax resident. Income tax up to 47%. Wealth tax applies to worldwide assets. If you want to leave, Spain’s exit tax kicks in on large holdings. The EU stepping stone applies — move to another EU country first to defer the exit tax.

After NHR 2.0 (Portugal, year 11+)

Standard Portuguese rates apply — up to 48% on income, 28% on dividends. Portugal has exit tax provisions but with EU deferral. Less painful than Spain but not trivial.

After Greece (year 8+)

Standard Greek rates — up to 44%. But no exit tax and no wealth tax. You can leave Greece without a tax bill on unrealized gains. This is the cleanest exit of the three.

The real question

The real question isn’t “which regime has the best rate?” It’s “which regime gives me the best position when I leave?”

• If you want the lowest rate during the regime: Spain (0% on foreign dividends)
• If you want the longest duration: Portugal (10 years, but weaker benefits)
• If you want the cleanest exit: Greece (no exit tax, no wealth tax)
• If you want the best overall package: Spain for 5-6 years, then exit to a territorial tax country via the EU stepping stone

Who should choose what

Choose Spain’s Beckham Law if: Your income comes primarily from a foreign company as dividends, you want 0% on that income, and you have a clear exit plan before year 6. Best for: founders with a foreign holding company.

Choose Portugal NHR 2.0 if: You qualify as working in scientific research or innovation and want a 20% flat rate on Portuguese-source income for 10 years. Not recommended for: founders with foreign companies distributing dividends.

Choose Greece if: You want a simple, clean regime with no wealth tax, no exit tax, and a 7-year runway. You’re okay paying ~18% instead of 0%. Best for: founders who value exit flexibility over rate optimization.

Choose none of them if: You’re ready to go territorial. Panama, Paraguay, Costa Rica, the Dominican Republic — these don’t have expiration dates. 0% on foreign income isn’t a regime. It’s the permanent tax system.

FAQ

Which European tax regime is best for SaaS founders?

Spain’s Beckham Law offers 0% on foreign dividends for 6 years — the lowest rate. Greece’s 50% exemption offers ~18% effective for 7 years with no exit tax — the cleanest exit. Portugal’s NHR 2.0 no longer exempts foreign income and is only competitive if you qualify as a researcher or innovator.

Can I use the Beckham Law as a remote worker?

Yes, since Spain’s 2023 Startup Law. Remote workers employed by foreign companies can qualify. You can also qualify as a company director or through Spain’s entrepreneur visa.

What happens when these regimes expire?

You revert to standard tax rates in that country. Spain: up to 47% + wealth tax + exit tax. Portugal: up to 48%. Greece: up to 44% but no exit tax. Plan your next move before the regime expires — not after.

Can I switch between these regimes?

Not directly — each requires that you haven’t been a tax resident in the country for 5+ years before applying. You can use one regime, leave, and apply for another after the waiting period. In practice, most founders use one regime and then move to a territorial tax country.

Is it worth using a European regime vs. going straight to a territorial tax country?

If you want to live in Europe, yes. If location doesn’t matter, territorial taxation is simpler, permanent, and cheaper. The European regimes are time-limited tax holidays. Territorial taxation is the structure.

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These regimes are tools in the 7 Flags Framework, not destinations. Use them for the defined period, plan the exit before you enter, and know what comes next. The exit tax post covers the cost of leaving. The 29 countries list covers where to go after.