Spain’s Council of Ministers, on 4 June, 2024, passed the draft bill for implementing the Pillar Two global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022.
The bill includes the introduction of the Pillar Two income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure a minimum corporate tax of 15% for large multinational (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years.
The rules apply to all domestic and international groups with a parent company or subsidiary in an EU member state.
The bill also proposes implementing a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups and certain safe harbors. The IIR and QDMTT will apply for financial periods beginning on or after 31 December, 2023, and the UTPR generally will apply for financial periods beginning on or after 31 December, 2024.
The bill will now be submitted to the parliament for processing and approval before being published in the Official Gazette.
Earlier, Spain’s Ministry of Finance conducted a second public consultation on implementing the Pillar Two global minimum tax. The consultation concluded on 31 May, 2024.
