The Spanish lower house of parliament (Congress of Deputies) passed the draft bill on 21 November 2024, for implementing the Pillar 2 global minimum tax in line with Council Directive (EU) 2022/2523 of 14 December 2022.
The bill now awaits approval from the Senate (upper house).
Earlier, 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.
