Articles

ICT or the digital nomad visa? Both rest on the same weak point

Comparing routes8 min readReviewed: 2026-10-12

These are the two most heavily advertised routes into Spain, and they share something that rarely gets said out loud: both are judged on documents about a company and an employment relationship outside Spain. What the authorities see is paper, not reality. Which is precisely where the temptation to manufacture paper comes from.

Side by side

ICT (intra-corporate transfer) Digital nomad
Legal basis Ley 14/2013 Ley 28/2022
What must be proved Membership of one corporate group Income from an employer or clients outside Spain
Prior history required 3 months continuous employment in the group 3-month relationship; foreign company trading at least 1 year
Minimum income Not fixed (salary appropriate to the role) €34,188 per year for a single applicant
Family Permitted +75% for a second person, +25% for each additional
Cap on Spanish clients — At most 20% of income (freelancers)
Duration 3 years maximum (manager/specialist) 3 years if applied for in Spain, then a 2-year renewal
Decided by UGE-CE, 20 working days UGE-CE, 20 working days

The €34,188 figure is not arbitrary: it is 200% of the Spanish minimum wage. The 2026 minimum is €1,221 a month across 14 payments, so €17,094 a year. Bring a spouse and the requirement rises to roughly €47,000; add one child and it passes €51,000. And the income must be evidenced: payslips, invoices and bank credits that agree with each other.

The shared weak point

For an ICT you need a foreign employer that has had you on its payroll for three months. For the digital nomad visa you need an employer or client base abroad paying you close to €2,850 a month. If you have neither, the market has a ready answer: a contract can be produced, invoices can be produced, bank movements can be produced.

The first application may well succeed. The trouble starts afterwards.

1. The arrangement has to continue

A visa is a snapshot; a renewal is a film. At renewal you must show the same relationship still exists: payments continuing, contributions made, tax returns consistent with all of it. That constructed contract has to be kept alive for years, and its cost repeats every month.

2. Tax exposes the gap

After 183 days you are a Spanish tax resident. You file a return, and that declared income has to appear in it. Income that exists only on paper either has to be genuinely taxed — which is expensive — or left out, which creates a contradiction. The special regime (the Beckham law, 24% up to €600,000) only helps when the income is real.

3. The citizenship file opens years later

Naturalisation looks at your residence history and at good civic conduct. A document submitted in year one stays in the file. A problem that looks settled today can return at the exact moment it matters most.

So what should you do

If you genuinely earn from abroad and can prove it, the digital nomad visa is a good route and we will handle it. If you genuinely run a trading company, so is the ICT.

But if you have real evidence for neither, take the third option seriously: self-employment residence. There is nothing to manufacture, because the business is yours. You submit a real plan, you start a real activity, and your income is whatever it is. No 20% cap on Spanish clients, no foreign employer required, and the renewal runs for four years.

Spain is granting this route more readily than it used to. The only reason it is promoted less is that preparing the file is the heaviest work for the firm handling it — not for you.

Next step

Tell us what you actually have: what income, what history, what business. We will tell you which route is defensible on that basis.

Get in touch.

This page is general information and does not replace legal advice on your own case. Spanish immigration rules change often — talk to us before making a decision.

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