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Spain Publishes Law for Implementation of Pillar 2 Global Minimum Tax, New Bank Windfall Tax, Repeal of Energy Windfall Tax, and Other Measures

26 December 2024

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Approved Changes

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Spain

Spain has published Law No. 7/2024 of 20 December 2024 in the Official Gazette, which provides for the implementation of the Pillar 2 global minimum tax (complementary tax) in accordance with Council Directive (EU) 2022/2523 of 14 December 2022. As previously reported, this includes the introduction of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) in order to ensure a minimum tax level of 15% for MNE groups with annual consolidated revenue of at least EUR 750 million in at least two of the last four immediately preceding financial years. The law also provides for...