Executive Summary
The year 2024 was the year of digital and global taxation. **Pillar Two** entered full force for obliged multinational groups in Spain, materialising the historic 2021 OECD agreement; **DAC7** generated its first declarations, providing the AEAT with massive information on the platform economy; and **DAC8** — on crypto assets — completed its European legislative process, anticipating the next wave of reporting obligations. At BMC, the international tax practice experienced one of its most active years, accompanying multinational clients on Pillar Two management and companies of all sizes on compliance with their digital economy obligations.
Tax revenue reached a new estimated record of €285 billion, consolidating the record-high trajectory of previous years, sustained by the solidity of the Spanish economy and the maturity of the AEAT’s cross-referencing information systems.
Key Highlights
Pillar Two in force represented the most technically demanding challenge for multinational groups’ tax functions in years. The Spanish transposition — through an addition to the Corporate Income Tax Act — established the framework for calculating the top-up tax under the IIR and UTPR rules. Groups with more than 180 entities in the scope of obliged entities in Spain had to invest in specialised calculation tools, data collection processes by jurisdiction and training their tax teams to understand the new normative architecture.
DAC7 declarations submitted for the first time in January 2024 — covering the 2023 financial year — placed at the AEAT’s disposal information of enormous value for auditing digital economy taxpayers. The 45% increase in verifications related to the digital economy certified the immediate use of these data by the Administration.
The IRPF reform was the subject of political debate during the year, though it did not materialise in significant regulatory changes. Discussion about reducing the maximum marginal rate, treatment of capital income and incentives for long-term savings polarised the fiscal debate, generating uncertainty in long-term wealth planning.
Analysis by Tax Category
Corporate Income Tax and Pillar Two: The coexistence of the standard corporate tax with the new Pillar Two top-up tax required a thorough review of effective rate calculation models. The most analysed jurisdictions were those with favourable tax regimes (Ireland at 12.5%, Netherlands, Luxembourg, Malta) where groups held entities with real rates below the 15% threshold.
VAT and platform economy: The AEAT intensified verifications of platform economy operators, both property landlords and marketplace sellers. Correct characterisation of income (business activity or otherwise) and application of VAT on tourist rentals were the areas of greatest conflict.
Wealth taxation: The announced abolition of the Golden Visa generated a significant volume of queries about the tax impact of sale transactions completed before the programme closed, taxation of capital gains and implications of changing tax residence.
Regulatory Changes
DAC8 (Directive 2023/2226), approved in October 2023 with a transposition deadline of December 2025, extended crypto asset information obligations to crypto-asset service providers under the MiCA framework. Preparing for these new obligations was one of the priority tasks for crypto sector companies during 2024.
International tax planning required deep updating of transfer pricing models in light of Pillar Two and the new rules for income allocation.
Outlook
The tax horizon for 2025 included the full consolidation of Pillar Two, the first DAC7-specific inspections on the platform economy, preparation for DAC8 and the possibility of new tax measures in the context of budget negotiations. Tax compliance continued to require an increasing dedication of specialised resources.
Our Pillar Two and international tax team positioned itself as a reference adviser in managing the new obligations of global taxation, offering advanced technical solutions and first-rate strategic advice.
