The 2024 fiscal year opens with a substantial package of tax changes affecting businesses of all sizes operating in Spain. From the phased entry into force of the global minimum tax for multinationals to adjustments in VAT on basic goods, new crypto asset reporting obligations and updates to the non-resident income tax regime, the tax agenda this year is demanding. Below we analyse the most significant changes and their practical implications.
Global Minimum Tax of 15%: Pillar Two Arrives in Spain
The transposition into Spanish law of Directive (EU) 2022/2523 — guaranteeing a global minimum level of taxation for multinational groups — represents the most structurally significant corporate tax reform in years. Through a Royal Decree-Law approved in late 2023, Spain incorporates the OECD Pillar Two rules.
The impact falls on multinational groups with consolidated revenues exceeding €750 million in at least two of the four preceding fiscal years. The key mechanism is the Income Inclusion Rule (IIR): if a group subsidiary is taxed in a jurisdiction with an effective rate below 15%, the Spanish-resident parent entity pays a top-up charge to bring the rate to that minimum.
For the affected groups — estimated to be several dozen with significant Spanish presence — the first full application year requires a jurisdiction-by-jurisdiction effective rate calculation that has never previously been performed in a systematic way. The associated reporting obligations (enhanced Country-by-Country Reporting and new annexes to the corporate tax return) add considerable administrative complexity.
VAT Changes: Food Reductions and Phased Reversal
The Government extended until 30 June 2024 the VAT reductions introduced as an anti-inflation measure in 2022. From 1 July 2024, a gradual reversal began: olive oil returned to the 10% rate (from a temporary 5%), and most basic foodstuffs that had been at 0% reverted to 4% (the standard super-reduced rate).
Companies in food distribution and hospitality need to update their billing systems to reflect these rate changes at the exact transition date, avoiding applying incorrect rates that could trigger subsequent regularisations or tax inspections.
Non-Resident Income Tax: Updates to the Beckham Regime
The Startup Law (Law 28/2022) introduced significant improvements to the so-called Beckham regime, which allows workers transferring their tax residence to Spain to be taxed under Non-Resident Income Tax (IRNR) for five years at a flat 24% rate on employment income up to €600,000.
In 2024 these improvements are fully operational: the minimum remuneration threshold has been eliminated (previously €600,000 per year), the regime is extended to digital nomads and entrepreneurs, and coverage is broadened to immediate family members who also transfer their residence. This is the time to review whether recently arrived international executives can benefit from this advantageous regime — applications must be filed within six months of commencing activity in Spain.
Corporate Tax: Minimum Rate for Large Companies and Deduction Limits
The corporate tax minimum rate for companies with turnover exceeding €20 million is set at 15% of positive taxable income before applying the capitalisation reserve and integration of tax loss carryforwards. For newly incorporated entities benefiting from the reduced 15% general rate, the minimum drops to 10%.
The limitation on the deductibility of net financial expenses — capped at 30% of tax EBITDA (with a €1 million exempt minimum) — remains in force for 2024. The restriction on tax loss carryforward offset at 70% of pre-offset taxable income for groups with turnover above €20 million (50% for groups above €60 million) also continues.
New Crypto Asset Reporting Obligations for Spanish Residents
Beyond Modelo 721 for foreign-held assets, 2024 sees the entry into force of Modelos 172 and 173, which require crypto service providers established in Spain to report their clients’ transactions to the AEAT. This includes exchanges, custody wallets and DeFi platforms with a Spanish presence.
For users of these platforms, the practical consequence is that the AEAT will have cross-referenced transaction data on their crypto activity from 2024 onwards, substantially increasing the audit risk for anyone who has not correctly declared crypto gains in prior years.
Real Estate Measures
The main development for the real estate market is the extension of the 30% personal income tax deduction for energy efficiency improvement works on rented properties, extended to 31 December 2024. The 15% deduction for investment in new primary residence purchases is maintained for certain groups (under-35s and large families) in autonomous communities that have activated it in their own legislation.
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