Spain enacts its 15% minimum tax for large groups

Law 7/2024 implements the EU Minimum Tax Directive (2022/2523). It also creates a tax on banks' net interest margin and a tax on e-cigarette liquids.

What changed

• A complementary tax tops up each group's effective rate to 15% in every jurisdiction where it operates.
• It covers multinational and large domestic groups with consolidated revenue of at least EUR 750 million in at least two of the four previous years.
• It applies to tax periods starting on or after 31 December 2023.
• The regulations, approved by Royal Decree 252/2025 of 1 April 2025, set out the calculations and filings.

Who is affected

Spanish entities of large groups and their tax and finance teams.

Sources

• Garrigues: Pillar 2 in Spain, complementary global minimum tax for large groups approved
• Cuatrecasas: Guía del Impuesto Complementario (Pilar Dos)