2025 marks an inflection point in Spain's tax digitalisation. Mandatory e-invoicing for B2B transactions, the full rollout of real-time VAT reporting systems and new frameworks for the taxation of the digital economy shape a year of transformation for tax and finance functions. At the same time, global minimum tax measures continue to apply and substantive changes to Corporate Income Tax are consolidating.
Mandatory E-Invoicing: The Major Operational Change of 2025
Law 18/2022 (the Create and Grow Act) and its implementing regulations make electronic invoicing mandatory for all B2B transactions carried out by businesses and self-employed individuals subject to tax in Spain. The rollout is phased:
- Businesses with turnover above €8 million: obligation in force since 2024; active compliance checks and the first penalties begin in 2025.
- All other businesses and self-employed individuals: obligation expected in the second half of 2025, subject to any regulatory extension.
The e-invoice must comply with the structured format (FacturaE or other formats recognised by the AEAT) and be sent through a system interoperable with the State’s public platform. Businesses must choose between managing issuance through an authorised trust services provider (PSC) or implementing their own compatible solution. Non-compliance may result in penalties of up to €10,000 per invoice issued in the incorrect format.
Corporate Income Tax Changes for 2025
The standard CIT rate remains at 25%, but differentiated minimums continue to apply. For 2025, the Tax Agency has announced enhanced controls on the correct application of the R&D deduction, which remains one of the most powerful incentives in the Spanish system but also one of the most audited. The applicable deduction ranges from 25% to 42% of research and development expenditure, with the possibility of monetisation if the company does not have sufficient tax liability.
Tax loss carry-forwards (BINs) accumulated by many businesses during 2020–2021 continue to be offset subject to the 70% cap on the prior taxable base for groups with turnover between €20 million and €60 million (50% for groups above €60 million). This restriction extends the tax recovery period for companies with significant accumulated losses.
Intra-EU VAT: OSS, IOSS and New Rules for Digital Platforms
Since the 2021 reform, the One-Stop-Shop (OSS) system allows businesses that sell goods or provide digital services to end consumers in other EU Member States to declare and pay the applicable VAT in a single Member State (Spain, if that is their country of establishment). In 2025, the obligations of digital platforms acting as intermediaries in sales of goods by third-party sellers are consolidated: they are deemed to be the “deemed supplier” and must collect and remit VAT directly.
For marketplaces and e-commerce platforms with intra-EU operations, this means reviewing contractual arrangements with sellers, adapting invoicing flows and ensuring that VAT is correctly collected and declared in each destination jurisdiction.
Personal Income Tax and Social Security Contribution Changes
The main Personal Income Tax development in 2025 is the increase in the employment income reduction for low and middle incomes, as part of the government’s commitment to ease the tax burden on workers earning below €22,000. The personal and family allowance is also updated by a percentage linked to the CPI.
On social security contributions, the maximum contribution base for contingencies continues to increase for higher earners as part of Law 21/2021 on the Guarantee of Purchasing Power. Self-employed individuals who opted in 2023 for the new actual-income-based contribution system will complete in 2025 the regularisation of contributions paid in 2024, with possible refunds or supplementary assessments depending on the final declared income.
Fiscal Consolidation Regime: Updated Criteria
The AEAT has published new interpretative guidance on the application of the fiscal consolidation regime to groups with complex matrix structures, particularly affecting the criteria for including or excluding indirectly held entities and the treatment of intragroup transactions involving transfer pricing. Groups that have not reviewed their consolidation perimeter in the last two years should do so before the close of the 2025 financial year.
2025 Tax Calendar: Key Dates
Formal obligations follow the usual rhythm: quarterly VAT (20 April, 20 July, 20 October and 30 January 2026), CIT (25 July for groups with a financial year coinciding with the calendar year), Personal Income Tax withholdings (monthly for large companies, quarterly for others). The new element is the inclusion of new crypto-asset reporting models in the January calendar.
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