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Law 6/2025 suspends Article 97.1 of Law 8/2023 throughout 2026, meaning the obligations derived from that article will not be applicable during that year. This measure affects all parties subject to said article and applies generally without specific conditions. The suspension also extends to Articles 19.1 and 23.3 of Law 1/1986, as specified in the legal text (via the addition of Art. 12 ter, 30 quinques, and 38 quater).
Taxpayers affected by Art. 97.1 of Law 8/2023 will not have to meet their obligations during 2026, temporarily reducing their tax burden. Tax authorities must not apply these obligations during that year. Advisors and management firms can adjust tax planning and avoid control actions or penalties. Individuals and companies relying on this article will be able to reorganise their filings without risk of penalties for non-compliance.
The tax team reviews your specific situation.
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