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GloBE Country Guide: Spain

Summary

Status Enacted Law and Regulations
LawOn April 29, 2025, Spain published Law No. 3/2025 of April 29, 2025 in the Official Gazette, which modifies the Economic Agreement with the Basque Country to adapt the agreement to Law No. 7/2024 of 20 December 2024 for the implementation of the Pillar 2 global minimum tax.

On April 2, 2025, Spain issued Royal Decree 252/2025 to approve the Regulations for the Global Minimum Tax. The Regulations include a number of aspects of the OECD Administrative Guidance. 

On December 21, 2024, Spain published law 7/2024 in its Official Gazette to transpose the EU Minimum Tax Directive. This includes an IIR and QDMTT from December 31, 2023 and the UTPR from December 31, 2024.

On December 19, 2024, Spain’s Parliament approved the law to transpose the EU Minimum Tax Directive.

On December 19, 2023, Spain’s Council of Ministers approved a draft law to implement the EU Minimum Tax Directive. It was subject to a consultation and was then subsequently approved as a second draft by the Council of Ministers on June 4, 2024. On June 14, 2024, the Official Gazette of the Spanish Parliament published the text of the Bill.

Draft GMT Regulations of December 4, 2024
Effective DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursYes – Transitional CbCR Safe Harbour, Transitional UTPR Safe Harbour, QDMTT Safe Harbour

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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