On 14 June 2024, Spain’s Congress of Deputies published the draft bill for implementing the Pillar 2 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 draft bill also provides for the introduction of a qualified domestic minimum top-up tax (QDMTT).
Pending approval and publication in the Official Gazette, the IIR, and QDMTT will apply for financial periods beginning on or after 31 December, 2023, and the UTPR will generally apply for financial periods beginning on or after 31 December, 2024.
The UTPR will apply to tax years starting on or after 31 December, 2023, for constituent entities of groups with ultimate parent companies in EU Member States that have opted for a deferred application of the IIR and UTPR per Article 50 of the Directive.
As previously reported on 4 June, 2024, Spain’s Council of Ministers, passed the draft bill for implementing the Pillar Two global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022.
