The present invention relates to a method for manufacturing a magnetoresistive element having a magnetization pinned layer, a magnetization free layer, and a spacer layer including an insulating layer provided between the magnetization pinned layer and the magnetization free layer and current paths penetrating into the insulating layer. A process of forming the spacer layer in the method includes depositing a first metal layer forming the metal paths, depositing a second metal layer on the first metal layer, performing a pretreatment of irradiating the second metal layer with an ion beam or a RF plasma of a rare gas, and converting the second metal layer into the insulating layer by means of supplying an oxidation gas or a nitriding gas.