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Spain Publishes Pillar 2 Global Minimum Tax Rules for Basque Region

07 May 2025

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Approved Changes

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Spain

Spain has published Law No. 3/2025 of 29 April 2025 in the Official Gazette, which modifies the Economic Agreement with the Basque Country, originally approved in 2002. Among other things, modifications are made to adapt the agreement to Law No. 7/2024 of 20 December 2024 for the implementation of the Pillar 2 global minimum 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...