On December 21, 2024, the Spanish official gazette published Law 7/2024 of December 20, which establishes:
- A complementary tax to guarantee a minimum global tax rate for multinational and large national groups.
- A tax on interest margins and commissions of certain financial entities.
- A tax on liquids for electronic cigarettes and other tobacco-related products.
Additionally, on December 24, Royal Decree-Law 9/2024 of December 23 was published in the Spanish official gazette. It adopted urgent economic, fiscal, transport, and Social Security measures and extended some actions to address situations of social vulnerability. However, by resolution of January 22, 2025, the parliament did not ratify the decree and agreed to its abolition.
Therefore, only the main tax measures that come into force with the publication of Law 7/2024, with impact in the financial year 2025 and, in some cases, with effect from January 1, 2024, are detailed below.
Complementary Tax
Applicable to large multinational groups with a turnover equal to or greater than 750 million euros. This tax will apply when the tax rate does not reach the minimum of 15% on the adjusted accounting result.
Limitations on Compensating Negative Tax Bases BIN in Corporate Income Tax IS
Effective from January 1, 2024, the limitations annulled by the Constitutional Court ruling on January 18, 2024, are reintroduced:
- 50% of the previous taxable base for companies with a Net Turnover INCN between 20 and 60 million euros.
- 25% for entities with an INCN over 60 million euros.
Reversal of Deductible Portfolio Impairments
The requirement to reverse deductible portfolio impairments before 2013 now applies again.
Increase in the Capitalization Reserve Rebate
- The rebate in IS for capitalisation reserve increases from 15% to 20% generally and 30% under specific staffing requirements.
- Also, the maximum rebate increases from 10% of the taxable base to 20% and up to 25% for small businesses.
Temporary Limitation on Integration of Individual BINs in Consolidated Groups
Extension of the 50% temporary limitation until 2024 and 2025. Entities can reverse it within 10 years.
Progressive Reduced Rates in IS for Micro companies and SMEs
Progressive reduced rates of 17% and 20% for micro companies less than one million euros of INCN and SMEs. The application will be gradual during the financial years 2025-2029.
Increase in Personal Income Tax IRPFBrackets for Savings Income
Starting January 1, 2025, savings income over 300,000 euros will be subject to a 30% tax.
This increase will also affect beneficiaries of the Beckham regime with Spanish-sourced savings income.
Value Added Tax VAT
- Reduction of tax rates applicable to olive oil and other dairy products
- Implementation of a public electronic invoicing solution, scheduled for January 1, 2026, which will offer the possibility to issue invoices with the public solution or collect the e-invoices issued through the private solutions.
Special Taxes on Tobacco and Electronic Cigarettes
- Increases in the rates applicable to special taxes on tobacco.
- New tax on electronic cigarettes and other tobacco-related products.
Tax on Interest Margins and Commissions of Financial Entities
A tax on interest margins and commissions of certain financial entities replaces the temporary tax on credit entities.
If you need additional information about the tax measures approved in Spain for 2025,
