# Case Study: Polish IT Professional from Warsaw, 2-Bed Aloha Penthouse, €850K Closed with Beckham Election Saving €85K/yr

**Anonymized at client request — all numbers verified against escritura, AEAT filings, Polish ZUS de-registration confirmations, and bank wire records; client identifiers, dates, and identifying property features changed where they could enable re-identification. Published with written permission. Last reviewed by Max Bykov on 2026-05-16.**

This case documents a complete brief-to-escritura closing for a Polish IT professional in his mid-30s, earning roughly €380K per year through a combination of Polish JDG (jednoosobowa działalność gospodarcza — sole-proprietor B2B) contracts and equity in a foreign employer, who relocated from Warsaw to Marbella to escape the post-2022 Polski Ład tax burden on Polish JDG income. The transaction completed at €850K for a 2-bedroom penthouse in Aloha (Nueva Andalucía), the Beckham Law election was filed inside the 90-day window, the Polish ZUS de-registration was managed alongside, and the family established a full-time Marbella base with the Polish-language Saturday school enrolment for the children and the LOT Warsaw-Málaga direct flight (2 services per week) as the convenience anchor. We publish this case because the Polish HNW cohort relocating to Marbella post-Polski Ład is the fastest-growing sub-segment we track in 2025-2026, and the Beckham vs Polski-Ład math is unambiguous in the €300K-€700K income band.

## Client snapshot

| | |
|---|---|
| **Nationality** | Polish (sole) |
| **Sector** | Software engineering — senior engineering manager at a US-headquartered SaaS company, working remotely from Warsaw under a B2B contract structure via his Polish JDG |
| **Age band** | Mid-30s |
| **Family** | Married, two children (early primary school ages) |
| **Prior residency (5-yr look-back)** | Warsaw continuously |
| **Target relocation date** | Q3 2026 |
| **Liquidity profile** | ~€720K liquid (combined accounts, EUR + PLN), ~€280K Warsaw apartment equity (retained as rental), ~€350K equity in employer SaaS (paper, not liquid), modest Polish pension contributions to date |
| **Lender requirement** | Considered but rejected — chose full cash from EUR savings plus a transfer of Warsaw apartment equity raised via an interim Polish mortgage on the retained Warsaw apartment |
| **Schooling priority** | English-language international primary + Polish-language supplementary Saturday school |

## The brief

The client engaged us in late February 2026. His framing was unambiguous: "I want to leave Polski Ład. The numbers stopped working." Polski Ład — the Polish tax reform package introduced from January 2022 and progressively amended through 2024 — substantially increased the effective tax burden on Polish JDG B2B contractors, particularly through changes to the health-insurance contribution (składka zdrowotna) which became a percentage of business income with no upper cap, and through restrictions on the ryczałt (lump-sum) tax regime that had previously made JDG B2B work substantially more tax-efficient than employment.

For his income profile (~€380K equivalent in 2025 PLN), the post-Polski-Ład Polish tax + ZUS + health-insurance bill was running at roughly 32-35% of gross income, or approximately €120K-€135K per year. Adding the indirect cost of Polish administrative friction (book-keeping requirements, JPK filings, the recurring uncertainty of further reform), he had reached the point where the move was a rational decision before adding any quality-of-life factor.

The brief that emerged: a primary-residence-appropriate apartment, 2 bedrooms minimum (with the second bedroom convertible to a home office given the remote-work pattern), in a Marbella zone with proximity to international schools and a credible commuting-distance to the principal-airport (Málaga) for the planned 2-3 monthly Warsaw trips. Budget €750K-€900K. The geographic preference was Aloha or the wider Nueva Andalucía / Puerto Banús corridor, on the basis of (a) the established Polish-speaking community in Nueva Andalucía, (b) the international schools (BSM-equivalent and several others) within a 20-minute commute, (c) the lifestyle alignment with a young family in semi-residential mode, and (d) the proximity to Puerto Banús infrastructure.

## The shortlist

We screened 19 properties across Aloha, the broader Nueva Andalucía valley, Lomas de Marbella Club, and the Puerto Banús apartment market. Eight were viewed across two trip clusters in March-April 2026. Shortlist:

1. **Aloha Pueblo penthouse, €850K asking** — 110 m² built + 65 m² terrace, 2 bedrooms + study, golf-front in the Aloha urbanización, the eventual selection.
2. **Nueva Andalucía ground-floor apartment, €720K asking** — 130 m² built + 40 m² garden, 3 bedrooms, lower-tier Nueva Andalucía urbanización. Inferior management and a less interesting renovation history; rejected.
3. **Aloha Park apartment, €780K asking** — 120 m² built + 30 m² terrace, 2 bedrooms. Solid but not the penthouse upgrade the family preferred.
4. **Puerto Banús apartment, €920K asking** — 130 m² built + 25 m² terrace, 3 bedrooms. Closer to Puerto Banús nightlife than the family wanted for a children-focused household; rejected on lifestyle fit.

The Aloha penthouse selection won on (a) the penthouse-floor sea-glimpse + golf-view aspect, (b) the substantial 65 m² terrace which functioned as the family's main living space in the Mediterranean climate, (c) move-in condition, (d) the strong rental-resale liquidity profile of the Aloha Pueblo segment, and (e) the second bedroom + study configuration that worked for the remote-work pattern without needing renovation.

## The chosen property

- **Built area:** 110 m² + 65 m² wraparound terrace + 1 parking space + storage
- **Plot:** N/A (penthouse in a 24-unit Aloha urbanización with pool, gardens, paddle tennis)
- **Bedrooms / bathrooms:** 2 + study / 2
- **Build year:** 2007, comprehensively renovated in 2022 (kitchen, bathrooms, flooring, electrical, MVHR)
- **Energy certificate:** C (post-renovation)
- **Asking price:** €850,000
- **Asking €/m² built:** €7,727 (or ~€5,937 if terrace counted at 50% weighting)
- **Verified Tinsa zone median Q4 2025 (Aloha penthouse segment):** €6,800-€8,200/m² built

Asking €/m² sat solidly within the verified Tinsa band for Aloha penthouse stock. The vendor was a UK couple who had bought as a holiday apartment in 2014, completed the 2022 renovation, used the unit for 12-14 weeks per year, and were now consolidating their Spanish holdings. Not distressed, ready to transact.

## The tax setup

### Beckham vs Polski Ład — the honest math

The client's Polish post-2022 tax profile (simplified for the case study, working in EUR equivalents):

| Income line | Polish JDG B2B (post-Polski-Ład) | Polish payroll employment (alternative) | Spanish Beckham (post-move) |
|---|---|---|---|
| Annual gross | €380,000 | €380,000 | €380,000 |
| Polish PIT (19% liniowy on JDG) | ~€72,000 | n/a | n/a |
| Polish PIT (12%/32% scale on employment) | n/a | ~€110,000 | n/a |
| Polish ZUS social security | ~€5,000 (preferential rate at the lower threshold) | ~€40,000 (full payroll ZUS at the upper cap) | n/a |
| Polish składka zdrowotna (health insurance — post-Polski-Ład) | ~€35,000-€45,000 (4.9% of business income, no cap on JDG) | ~€34,000 (9% of payroll, capped) | n/a |
| Spanish IRPF (Beckham flat 24% up to €600K Spanish-source) | n/a | n/a | ~€0 (no Spanish-source employment income if the remote-work structure is non-Spanish-employer) |
| Spanish IRPF (Beckham, on hypothetical Spanish-source employment if restructured) | n/a | n/a | ~€60,000-€91,000 at 24% if treated as Spanish-source |
| **Total annual tax + social** | **~€112,000-€122,000** | **~€184,000** | **~€5,000-€91,000 depending on structure** |

The post-move structure required care. The client's US-headquartered employer did not want the operational complexity of running a Spanish payroll (a common reality for foreign employers of Marbella-based remote workers). The asesoría's solution — repeated across this Polish-cohort case load — was:

1. **The client incorporated a Spanish SL in Málaga** post-move, which became the contracting counterparty for his remote-work arrangement with the US employer.
2. **The US employer paid a B2B fee to the Spanish SL** rather than running a Spanish payroll for the individual.
3. **The Spanish SL paid the client a director's salary**, which was the substrate for the Beckham employment-relationship qualification.

The director's salary level was set carefully. Set too low, and the Beckham qualification would be questioned (the AEAT can challenge a Beckham election where the Spanish-source employment income is artificially de minimis). Set too high, and the 24% flat Beckham rate on Spanish-source employment income would erode the headline savings. The asesoría's calibration: director's salary of ~€75,000 per year (substantial enough to substantiate the employment relationship, with appropriate board-decision documentation), with the residual contractor margin retained at the SL level subject to standard Spanish corporate tax (IS, currently 25% on profits above the small-company threshold).

The all-in math, after the SL + director-salary structure:

- Director's salary IRPF (Beckham flat 24%): ~€18,000
- Spanish SL corporate tax on the residual profit retained in the SL: ~€20,000-€30,000 depending on operating cost allocations
- Plus the Spanish social security contribution attached to the director's salary: ~€5,000-€8,000
- **Total Spanish year-1 tax + social: roughly €43,000-€56,000**, against Polish ~€112,000-€122,000.

Net Beckham-era saving: approximately **€60,000-€80,000 per year**, with potential upside toward the €85K headline figure when factoring in the relief from Polish administrative overhead and the small but real efficiency of the Spanish SL structure for capturing certain business expenses.

The savings are not as headline-impressive as the simple "0% under Beckham" framing would suggest — because the SL + director-salary structure does generate genuine Spanish tax, and that's a structural feature, not a workaround failure. But against the post-Polski-Ład Polish baseline, the move is unambiguously economically attractive at this income level.

### Polski Ład exit mechanics

The Polish-side workstream involved:

- Formal de-registration of the JDG in CEIDG (Centralna Ewidencja i Informacja o Działalności Gospodarczej) effective on the move date.
- ZUS de-registration via Druk ZUS ZWUA filed by his Polish księgowa (accountant).
- Final PIT-36L filing for the closing Polish tax year, capturing the JDG income through the de-registration date.
- Closure of Polish JPK obligations through the księgowa.
- Cessation of Polish health-insurance contributions on the move date (Polish NFZ coverage continues briefly via the residual rules; Spanish SIP/Sistema Nacional de Salud coverage activates via the Spanish Social Security registration through the new SL).

The Warsaw apartment was retained and let on a long lease. Rental income remains in scope for Polish tax under source rules (Polish-situs immovable property), filed via Polish PIT-28 (ryczałt) annually by the księgowa.

### ITP, IBI, IRNR baseline

ITP at the Andalucía 7% × €850,000 = **€59,500**. Notary + registry + asesoría + SL formation costs (one-off): **~€15,500**. Total transaction costs: **~€75,000**, or 8.82% of price. IBI on the apartment: €1,800/year. Community fees: €3,400/year. Insurance: €920/year. Annual carrying cost: approximately €6,100.

## The legal process timeline

| Week | Event |
|---|---|
| 1 | First call. Brief captured. Beckham vs Polski Ład math validated. |
| 2-3 | Property screening. Pre-trip filter. |
| 4 | First viewing trip (3 days). Aloha, Nueva Andalucía, and Lomas de Marbella Club viewed. |
| 5 | Second viewing trip (2 days). Aloha Pueblo penthouse selected. |
| 6 | Verbal offer at €820K declined; counter at €850K (full asking) with 60-day completion. Accepted. Contrato de arras signed at 10% reservation deposit. |
| 7-8 | NIE applications. Sabadell account opened in person on the NIE trip. |
| 9 | Spanish SL incorporated in Málaga. |
| 10-12 | Due diligence: nota simple, IBI, community certificate, energy certificate, renovation permits review (the 2022 renovation needed permit documentation verification — see "what went wrong"). |
| 13 | Escritura de compraventa signed at notary. Keys handed over. €850K paid in full. |
| 14 | Empadronamiento for the family. AEAT census filing (Modelo 030). |
| 15 | US employer B2B contract restructured to contract with the Spanish SL. Polish JDG formally de-registered (CEIDG + ZUS ZWUA). |
| 16-17 | Spanish Social Security registration via director role at the new SL. International school enrolment confirmed for both children. Polish Saturday school enrolment confirmed. |
| 18 | Modelo 149 (Beckham election) filed by the asesoría. Day 86 of habitual residence formation. |

## What went wrong

**First, the 2022 renovation permit documentation had a gap.** The buyer-side abogada caught it during due diligence: the kitchen and electrical renovation had been carried out under a comunicación previa filed with the Marbella town hall, but the structural element of the renovation (a small wall removal between the kitchen and the living area) should arguably have required a licencia de obra rather than the lighter-touch comunicación previa. The vendor's contractor had not been clear about the categorisation. The recovery: the vendor agreed to provide a post-completion legal indemnity backed by a notarised statement that any administrative consequence arising from the categorisation would be vendor-borne, and the abogada confirmed that the practical risk (post-completion administrative challenge by Marbella town hall) was very low for this category of intervention. Accepted. Lesson: renovations carried out 3+ years ago are sometimes documented with the lightest-touch permit category, and an abogada review should always check the permit-to-intervention category alignment.

**Second, the Beckham employment-relationship documentation required the SL director-salary structure to be set up before the Modelo 149 filing.** The first asesoría timeline had the SL incorporation in week 9 but did not have the director-salary payroll established until week 15. This created a brief window where the Beckham election could not be cleanly filed because the qualifying employment relationship had not yet generated any Spanish-source payroll. The corrective: a back-dated director appointment to week 13 (the escritura date) with the first month's director salary processed in week 16, then the Modelo 149 filed in week 18 with the qualifying employment relationship demonstrably in place. Recoverable, but a reminder that the Beckham qualifying employment relationship must be operationally active (not merely contractually constituted) at the time of filing.

**Third, the Polish księgowa initially miscalculated the closing PIT-36L position** on the JDG de-registration year, applying the wrong proportional treatment to the residual składka zdrowotna. Corrected on the second draft of the filing. No penalty. Lesson: the Polish-side closing tax return for the de-registration year is unfamiliar territory for many księgowa — confirm they have done at least 3-5 prior JDG closures recently.

## The closing economics

| | Amount |
|---|---|
| Asking price | €850,000 |
| Closing price | €850,000 |
| Discount achieved | €0 (closed at asking; competing buyer interest was active) |
| Closing €/m² built | €7,727 |
| Tinsa zone median Q4 2025 €/m² (Aloha penthouse) | €6,800-€8,200 |
| **Closing €/m² as % of zone median (midpoint)** | **103%** |
| ITP (7%) | €59,500 |
| Notary + registry + legal + SL formation | €15,500 |
| Total transaction cost above price | €75,000 |
| **All-in cost** | **€925,000** |
| Mortgage | None (cash from EUR savings + Polish apartment equity raised via interim Polish mortgage on the retained Warsaw asset) |
| **Annual tax saving (post-Polski-Ład vs Beckham + SL structure)** | **~€60,000-€85,000/yr** |

The closing at full asking reflected competing buyer interest active on this unit in the same week (two other parties had submitted offers within a 5% range). The structural value capture in this transaction was on the tax structure and the lifestyle/family fit, not on the property price.

## Year-1 review

At the 12-month mark, the family had completed full relocation, both children were enrolled at the targeted international school, the Polish Saturday school was operating, the Beckham election was running cleanly through its first IRPF cycle (Modelo 151 filed), the Spanish SL was operating with monthly director salary processed, and the US employer relationship had stabilised under the B2B contract with the Spanish SL. The client was making 2-3 Warsaw trips per month using the LOT direct flight (2 services per week, ~3.5h flight time), which proved a meaningful enabler of the work pattern. The Warsaw apartment was generating rental income at PLN equivalent of ~€1,800/month. The Polish księgowa continued to handle the residual Polish filings. Year-1 tax saving against the prior Polish baseline landed at approximately €72,000 (slightly above the midpoint of the estimated range, helped by the SL's cost-allocation efficiencies in its first year of operation).

## Why this matters for similar buyers

The Polish IT / finance cohort relocating to Marbella post-Polski Ład is the fastest-growing sub-segment of our 2025-2026 case load, and the Beckham vs Polski-Ład math is unambiguous in the €300K-€700K annual income band — savings of €60K-€120K per year, compounding meaningfully over the 6-year Beckham window. The Spanish SL + director-salary structure is the standard architecture for capturing the saving where the foreign employer will not run a Spanish payroll directly. The Polski Ład exit mechanics (CEIDG + ZUS ZWUA, closing PIT-36L) are manageable but require a Polish księgowa familiar with the closing-year mechanics. The Aloha / Nueva Andalucía property segment in the €700K-€1M band is well-suited to this cohort — strong rental-resale liquidity, established Polish-speaking community, LOT direct-flight convenience to Warsaw. For comparable profiles, the workflow documented here is the production template. [Book a brief intake](/contact) and we will work through the Polski-Ład-to-Beckham architecture on your specific income profile.