Spain’s General Directorate of Taxes has launched a public consultation on draft regulations designed to implement a complementary tax ensuring a global minimum tax for multinational enterprises (MNEs) and large domestic groups on 3 December 2024.
The regulations aim to enact the European Union’s (EU) Minimum Taxation Directive (2022/2523), which follows the OECD’s GloBE Model Rules for a 15% minimum tax under Pillar Two. It provides detailed guidance on determining the tax base, including adjustments for foreign currency gains, substance-based income exclusions, and refundable tax credits. They also specify rules for adjustments excluding dividends and for insurance entities.
The consultation began on 4 December 2024 and will continue until 26 December 2024.
Earlier, The Spanish lower house of parliament (Congress of Deputies) passed the draft bill on 21 November 2024, for implementing the Pillar Two global minimum tax.
