On 6 March 2023, the Spanish Ministry of Finance published a public consultation document on the transposition of the EU Directive implementing Pillar Two global minimum tax rules (Council Directive 2022/2523 of 14 December 2022, “Minimum Tax Directive”) into Spanish tax law.

The document acknowledges that the Spanish rules transposing the EU Minimum Tax Directive should be implemented before 31 December 2023 (31 December 2024 in the case of the Undertaxed Payments Rule). In effect, provisions implementing the EU Minimum Tax Directive into the Spanish tax law will be applicable in 2024.

The document recognizes that the Spanish rules implementing the EU Minimum Taxation Directive should be implemented before December 31, 2023 (December 31, 2024 in the case of the undertaxed payment rule). In fact, the provisions transposing the EU minimum tax directive into Spanish tax law will apply from 2024.

Taxpayers and stakeholders have until 24 March 2023 to submit comments.