US, UK, German, Dutch and Belgian clients on Beckham Law applications, FATCA and Modelo 720 compliance, trust planning, stock options and AEAT defence — in their own words.
All clients are identified by role and origin only. Specific financial details have been generalised at clients' request.
I relocated from San Francisco to Barcelona on a digital nomad visa and assumed that my US employer's HR team had the Spanish tax side covered. They did not. Jacob identified that the Beckham Law application window was about to close and filed the Modelo 149 with less than two weeks to spare. His analysis of how the regime interacted with my ESPP and RSU grants — and what that meant for my US federal return — was genuinely impressive. The dual-country complexity is real, and Jacob is one of very few advisers who understands both sides of it without simplifying either.
My situation involved a US brokerage account, a UK pension, and several years during which I had not filed a Modelo 720 — because no one had ever told me I was required to. Jacob assessed the exposure, calculated the penalty risk under the revised post-TJCA framework, and guided me through a voluntary regularisation before the AEAT identified the omission. The process was stressful, but his calm technical command of both the Spanish and US reporting requirements made it manageable. The outcome was significantly better than I had feared at the outset.
We moved to Andalusia as a family and were beneficiaries of a UK discretionary trust that had been settled by my father. The question of how Spain would treat trust distributions — and whether the trust assets themselves triggered Modelo 720 obligations — was something our UK solicitors could not answer. Jacob produced a detailed written analysis of the Art. 91 LIRPF attribution rules, the treaty position, and a practical restructuring recommendation for our pre-residency window. The memo was thorough, clearly written, and has served as the reference document for our ongoing compliance. We would not have managed this without specialist advice at this level.
Ich habe Jacob kontaktiert, weil ich nach Mallorca umgezogen war und mir nicht sicher war, ab welchem Zeitpunkt ich in Spanien steuerpflichtig wurde und welche Pflichten daraus folgten. Er hat meine Situation unter dem DBA Deutschland-Spanien vollständig analysiert, die Frage der Ansässigkeit eindeutig beantwortet und mir klar erläutert, was ich gegenüber dem deutschen Finanzamt erklären musste. Die Beratung auf Deutsch war für mich entscheidend — es geht um zu viel, um Nuancen in einer Fremdsprache zu riskieren. Jacob versteht beide Steuersysteme aus eigenem Sachverstand und nicht nur aus der Sekundärliteratur.
I was a senior manager at a Dutch-listed company and had a significant number of stock options granted under Dutch law that vested after I became a Spanish tax resident. The interaction between the Netherlands-Spain double tax treaty, the Spanish IRPF treatment of the economic benefit at exercise, and the question of whether the 30% rendimientos irregulares reduction applied was not straightforward. Jacob worked through the analysis in detail and produced a strategy memo that our Spanish IRPF adviser — who had not seen this type of cross-border option structure before — then used as the basis for the filing. The collaboration worked well and the treatment was defensible.
My company relocated me to its Madrid office and I had heard of the Beckham Law but had no idea whether I would qualify or what the process involved. Jacob confirmed my eligibility within a day of our first call, managed the entire Modelo 149 application, and also flagged something my company's HR team had missed: that my employer needed to adjust withholding immediately upon approval rather than waiting until year-end. He also explained clearly why, as a UK national in Spain under the Beckham Law, I would not be treated as a Spanish resident for treaty purposes and what that meant for my UK pension contributions and ISA holdings. The level of detail was exactly what I needed.
I received an AEAT notification challenging my tax residency position — they were asserting that I had been a Spanish resident for two years prior to the date I had self-declared as resident. The potential assessment, including interest and penalties, was substantial. Jacob took over the matter immediately, reviewed the AEAT's reasoning in the initial notification, and built a careful factual and legal response based on the tie-breaker provisions of the Belgium-Spain treaty. The comprobación was closed without an assessment being raised. I was genuinely impressed by the precision of his argument and the speed with which he identified the weakness in the AEAT's position.
I had been living in Spain for six years without fully understanding my tax obligations as a US citizen. I had not been filing FBARs correctly and had significant unreported foreign financial accounts. A friend in a similar situation had received an IRS penalty notice and that prompted me to seek advice. Jacob assessed my entire compliance position across both US and Spanish obligations, prepared a plan for regularisation under the IRS Streamlined Foreign Offshore Procedures, and ensured my Spanish IRPF position was correctly reported for open years. His written explanations were clear enough for me to understand each decision we were making. The process took several months but the outcome was as good as it reasonably could have been.
Book a free 30-minute consultation. Jacob will review your cross-border position, answer your initial questions, and give you a clear picture of what is involved and what it will cost — with no obligation.
The content on this website is for general informational and educational purposes only. It does not constitute legal or tax advice and does not create a lawyer-client relationship. Tax laws change frequently and their application depends on individual circumstances. Always obtain specific professional advice before taking any action based on content found on this site. Jacob Salama — Salama Legal SLP — is a registered Spanish lawyer (Colegiado nº 11.294, ICAMálaga) and is not authorised to provide US or UK legal advice.