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Spain Introduces New Interest Deduction Limitation, Implements DAC7, and Amends DAC6 Rules for Professional Secrecy

31 May 2023

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Approved Changes

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Spain

Spain published Law 13/2023 of 24 May 2023 in the Official Gazette on 25 May 2023, which contains various measures. One of the main measures is the introduction of new interest deduction limitation rules in line with the EU Anti-Tax Avoidance Directive (ATAD). Because Spain's current interest deduction limitation rules were considered equally effective as those in ATAD (generally, 30% of EBITDA), it was authorized to defer the transposition of the ATAD interest deduction limitation. The new rules, which apply from 1 January 2024, provide that the deduction of net interest expense is limited to 30% of EBITDA (operating profit)...