BOE-A-2026-3911 ·20 February 2026 ·Act critical
Tax

Multinational and large-scale groups: 12 months to adjust taxable base under new complementary tax

The Foral Law 18/2025 modifies Articles 23.1.b of Foral Law 26/2016 and Article 139.1.b) of Foral Law 13/2000, after transposing Directive (EU) 2022/2523, to establish a complementary tax ensuring a minimum global tax level for multinational and large-scale groups. This change directly affects the taxable base of these entities, with effects from the entry into force of the text. The transposition is carried out in accordance with the Statute approved by Organic Law 13/1982.

In 2 key points

  1. Multinational and large-scale groups must adjust their tax base within 12 months (art. 23.1.b Ley Foral 26/2016)
  2. Transposition of Directive (EU) 2022/2523 to establish a top-up tax (art. 139.1.b) Ley Foral 13/2000)

How it affects those involved

Multinational and large-scale domestic groups must adjust their tax base within 12 months, leading to an increased tax burden for these entities. Affected companies will need to review their tax returns and calculation procedures. Tax advisors must adapt their reports and tax analyses to incorporate the new top-up tax. Navarrese tax authorities may see an increase in tax revenue.

Lifecycle

2026-02-20PublishedPublished in the BOE
2026-01-01Into forceComes into force (fecha_vigencia (indice oficial del BOE))
Official text Based on BOE data (boe.es). Information, not advice.
PDF on boe.es

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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