Spain will open its first Pillar Two global information reporting and notification filing window for in-scope multinational groups under its domestic implementation of the global minimum tax rules later this month.
Spain will open the first global information reporting (GIR) and notification filing window under its Pillar Two framework on 30 April 2026, marking a key compliance milestone for multinational groups subject to the global minimum tax rules.
The filing requirement arises under Law 7/2024, which implements the EU Minimum Tax Directive into Spanish domestic law and applies from fiscal years beginning on or after 31 December 2023. The GIR and notification process forms part of Spain’s broader Pillar Two reporting regime, alongside the Under-Taxed Profits Rule (UTPR) and Qualified Domestic Minimum Top-Up Tax (QDMTT) framework.
Under the approved administrative structure, Spain will require entities in scope to submit the initial GIR and related notifications from 30 April 2026, ahead of subsequent compliance deadlines for UTPR and QDMTT filings scheduled in July 2026. The reporting obligations are set out under forms approved by Ministerial Order HAC/1198/2025.
The introduction of the GIR notification stage forms part of Spain’s phased implementation of the global minimum tax system, designed to ensure consistent application of OECD GloBE rules and enhance tax transparency for large multinational enterprises operating in Spain.
Earlier, Spain’s Ministry of Finance has issued Order HAC/1198/2025 of 21 October 2025, published in the BoletÃn Oficial del Estado on 29 October 2025, introducing three new tax forms as part of Spain’s implementation of the Complementary Tax, established under the EU Minimum Tax Directive (Directive (EU) 2022/2523) and Spain’s Law 7/2024.
