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BOE-A-2026-8932 ·23 April 2026 ·Act critical
Tax

Multinational and large-scale groups: 6 months to resolve discrepancies in the complementary tax

The State-Navarra Cooperation Council initiates negotiations to resolve discrepancies regarding the fifth final clause of Foral Law 18/2025, which establishes a complementary tax for multinational and large-scale groups. A six-month period is set to resolve differences, as provided in the fifth final clause of the foral law (art. 5.1). The aim is to ensure a minimum global tax level, directly impacting the fiscal structures of these groups.

In 2 key points

  1. Negotiations are commencing to resolve discrepancies regarding the top-up tax (art. 5.1)
  2. A six-month period has been established to resolve differences in the application of the tax (art. 5.1)

How it affects those involved

Multinational and large-scale groups must participate in negotiations to adjust the top-up tax, which may lead to changes in their tax returns. Regional and state administrations may adjust their fiscal policies based on the outcomes. Tax advisors should monitor the progress of negotiations and anticipate potential modifications to the tax base. Taxpayers could see changes in their tax liabilities if adjustments to the minimum taxation level are approved.

Lifecycle

2026-04-23PublishedPublished in the BOE
2026-04-23Into forceComes into force (resolución de 30 de marzo de 2026)
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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