Spain is seeking feedback on a draft order introducing key reporting forms for the complementary tax, which runs until 24 June 2025.
Spain’s Ministry of Finance opened a public consultation on 3 June 2025 concerning a draft order that sets out new reporting requirements under the global minimum tax framework, officially known in Spain as the Complementary Tax.
The consultation will remain open for comments until 24 June 2025.
The draft order outlines three electronic forms required for compliance. Form (Modelo) 240 is for the communication by the constituent entity declaring the informative declaration of the Complementary Tax. This form must be submitted electronically no later than three months before the deadline for the informative declaration. Form (Modelo) 241 is the informative declaration of the Complementary Tax itself, which must be filed electronically by the last day of the fifteenth month following the end of the tax period. Form (Modelo) 242 is the self-assessment of the Complementary Tax, due electronically within 25 calendar days after the close of the fifteenth month following the tax period.
Transitional provisions are also included in the draft. For the transitional tax period, Form (Modelo) 241 must be submitted at least two months before the final day of the eighteenth month after the end of the relevant period. In cases where the tax period ends before 31 March 2025, the form must be submitted no later than two months before 30 June 2026. This exact timing requirement applies to Form (Modelo) 240 for the same tax periods. Regarding Form (Modelo) 242 for the transitional period, the deadline is set for 25 calendar days after the end of the eighteenth month following the tax period, although no such form will be due before 25 days after 30 June 2026.
Additionally, the draft permits multinational enterprise (MNE) groups to opt for a simplified informative declaration for tax periods starting before 31 December 2028 or ending before 1 July 2030. These measures form part of Spain’s adoption of OECD Pillar 2 standards, which aim to ensure consistent application of the Complementary Tax.
Earlier, Spain published Law No. 7/2024, on 20 December 2024, in the Official Gazette, establishing the implementation of the Pillar Two global minimum tax in line with Council Directive (EU) 2022/2523 of 14 December 2022.