Spain
The final weeks of 2024 have been used to pass many tax measures that are relevant for both domestic and foreign investors
- Adoption of the OECD’s Pillar Two legislation through a new Impuesto Complementario.
- Reintroduction of corporate income tax measures declared unconstitutional. These measures include limitations to the use of net operating losses and double tax credits, as well as a fictional reversal of deductible impairment losses on shares.
- Limitations introduced in 2023 on offsetting tax losses within consolidated groups extends to 2024 and 2025.
- Significant changes to the capitalization reserve have been approved.
- Renewal or creation of taxes for certain companies.