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Spain Publishes Regulations for Pillar 2 Global Minimum Tax

04 April 2025

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Approved Changes

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Spain

Spain has published Royal Decree 252/2025 of 1 April 2025 in the Official Gazette, approving the Complementary Tax Regulations to guarantee a global minimum level of taxation for multinational groups and large national groups. The regulations facilitate the interpretation and application of 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, and incorporate certain interpretative criteria derived from the OECD administrative guidelines. As previously reported, this includes the introduction of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit...