Spain approves Pillar Two legislation

02 January 2025|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Global, BEPS 2.0|Spain

The Spanish Congress has passed legislation implementing Pillar Two into domestic law.
The legislation is generally aligned with the EU Pillar Two Directive and includes some elements from the OECD Administrative Guidance released in April 2024.
This legislation implements an Income Inclusion Rule and a Qualified Domestic Minimum Top-Tax (QDMTT) applicable for fiscal years starting on or after 31 December 2023, as well as an Undertaxed Profits Rule (UTPR) generally applicable for fiscal years star…

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