Spain: Tax Agency publishes 2025 corporate tax, non-resident income tax return forms

Panama has enacted Law No. 526 of 28 May 2026, introducing economic substance requirements for MNE groups earning foreign passive income from the 2027 fiscal year. Entities must show real presence in Panama or face a 15% tax on net income, alongside stricter PE rules, a GAAR, and OECD nexus-based limits on IP exemptions.

Romania’s National Agency for Fiscal Administration (ANAF), in a draft order published on 28 May 2026, proposed changes to profit tax redirection rules for sponsorships and patronage, introducing stricter compliance checks, new notification procedures for excess allocations, and enhanced digital verification of taxpayer eligibility and beneficiary status.

The European Commission, in an FAQ, clarified that EU Member States must treat Cyprus as having a qualified income inclusion rule under the EU Pillar 2 Directive, confirming its recognition for global minimum tax purposes despite its absence from the OECD central record.

The Swedish Tax Agency has updated its Global Minimum Tax guidance to adopt the OECD’s flexible approach for first-year GloBE Information Return filings, waiving certain exchange agreement requirements and late-filing penalties for returns due by 30 June 2026, subject to specified conditions.

Albania has completed ratification of the STTR MLI, a key Pillar Two instrument designed to ensure a minimum 9% tax rate on specified categories of cross-border income.

The Portuguese Tax and Customs Authority has outlined procedures for applying OECD-agreed relief from local GIR filing obligations under the Global Minimum Tax Regime, including requirements for Model 62 declarations and centralised GIR return filings for the 2024 fiscal year.