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BOE-A-2026-3911 ·20 February 2026 ·Act High impact
Tax

Multinational and large-scale groups: 12 months to adjust taxable base in line with Directive (EU) 2022/2523

The Foral Law 18/2025 modifies Articles 23.1.b and 139.1.b of Foral Laws 26/2016 and 13/2000 to transpose Directive (EU) 2022/2523, establishing a minimum global tax level for multinational and large-scale groups. The adjustment of the taxable base must be completed within 12 months from entry into force (art. 23.1.b, 139.1.b).

In 3 key points

  1. Multinational and large national groups must adjust taxable base within 12 months (art. 23.1.b)
  2. The taxable base is adjusted in accordance with Directive (EU) 2022/2523 (art. 139.1.b)
  3. Affects insurance and financial entities (art. 139.1.b)

How it affects those involved

Multinational and large national groups must adjust their taxable base within 12 months under Directive (EU) 2022/2523, directly affecting corporate tax calculations, profit distribution, and global taxable base. Insurance and financial entities must also review their tax procedures.

Lifecycle

2026-02-20PublishedPublished in the BOE
2026-02-20Into forceComes into force (disposicion final 5)
Official text Based on BOE data (boe.es). Information, not advice.

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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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