Spain reintroduces and extends limitations on use of tax losses and foreign tax credits, after prior implementation was ruled unconstitutional

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

Legislation recently passed in Spain is intended to overcome procedural inadequacies of a prior implementation ruled unconstitutional.
The new law introduces limitations on the amount of tax losses and foreign tax credits that can be used in each tax period.
A temporary limitation that caps the amount of standalone current-year losses that are contributed to the tax group's taxable income, initially limited to 2023, is now extended to 2024 and 2025.

Executive summary

A new law¹ passed in Spai…

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