Pillar 2 in Spain: Global Minimum Tax for large groups approved
We review its main characteristics and remind you of the aspects to which you should pay special attention.
On 21 December 2024, Law 7/2024 of 20 December was published in the Official State Gazette (BOE), which, among others, transposes Council Directive (EU) 2022/2523 in Spain, which aims to ensure an overall minimum level of taxation for multinational groups and large-scale domestic groups (Pillar 2). Specifically, the law incorporates a complementary tax (so called “Top-up-Tax, "TUT"), applicable to large groups with an annual consolidated revenue of EUR 750 million or more in at least two of the four fiscal years prior to the reference year, so that a minimum taxation threshold of 15% is reached in all cases. This tax will apply to large groups with a presence in Spain.
In general, the new tax will be effective for tax periods beginning on or after 1 January 2024, although certain deferred application rules are provided for and will be summarised below.
In this document we analyse the main keys to the new regulation.
In addition, in this other publication we analyse other tax measures included in Law 7/2024, and here the novelties related to the Economic and Fiscal Regime of the Canary Islands.
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