We close 2024 with a tax landscape that continues to evolve at a sustained pace. The year 2025 looks set to be one of consolidation of reforms already in motion — global minimum tax, new information reporting obligations, mandatory e-invoicing — and the gestation of changes that will reshape the fiscal environment in 2026 and beyond. For finance and tax directors, anticipating this agenda is the difference between orderly, well-managed compliance and costly last-minute adaptation.
Mandatory B2B E-Invoicing: The Major Operational Challenge of 2025
If there is a single measure that will define the tax and operational agenda for most businesses in 2025, it is the generalisation of mandatory electronic invoicing between companies. The implementing regulation of the Crea y Crece Act sets out the definitive timetable, and 2025 will be the year when the obligation extends to the broader business community.
Companies that have not yet begun adapting their ERP or management systems need to factor in that the process involves: selecting a technical format (FacturaE or another recognised structured format), integration with the AEAT platform, possible contracting of a Trusted Service Provider (TSP), and training billing and accounting teams. A minimum of three to six months is needed for a correct implementation.
Personal Income Tax Reforms: What the Government Has Announced
The Government has included several IRPF modifications in its 2025 agenda, aimed at reducing the tax burden on middle and lower earners. The most discussed measures are:
- Raising the filing threshold: The mandatory filing threshold is expected to increase from the current €22,000 (single employer) to around €22,500-€23,000, providing relief for low-wage earners.
- New bracket for high earners: A new IRPF bracket for income above €300,000 at a marginal rate of 50% is under debate, which would place Spain among the European countries with the highest tax burden on high-pay employment.
- Reduced capital income tax for small savers: Raising the existing €1,500 dividend exemption threshold and applying reduced rates to the lower savings base brackets is also under study.
Corporate Tax: Controls and New Deductions on the Horizon
The AEAT has announced a specific enforcement campaign for 2025 focusing on the correct application of the R&D&I deduction, the small company regime (ERD) and the use of regional corporate tax rebates. Companies applying these reliefs must ensure they hold sufficient technical and economic documentation to substantiate compliance with all requirements.
In parallel, new deductions linked to digital and green transition are anticipated, aligned with the objectives of the Recovery, Transformation and Resilience Plan. Although specific regulations will be approved during 2025, companies planning investments in these areas can position themselves to benefit from the first day the measures come into force.
Digital Economy Taxation: The OECD and EU Tighten the Screws
The OECD’s Pillar One — which redistributes taxing rights over the profits of large digital companies to the market countries where they operate — continues to advance, albeit with delays. For 2025, the multilateral convention that gives it legal force is expected to enter the final stage of international negotiation, although effective implementation is unlikely before 2026.
At the European level, the Digital Services Tax (DST) Directive continues to be debated, with some member states pressing for a coordinated solution to avoid the proliferation of national digital levies. Spain maintains its Digital Services Tax (Impuesto sobre Determinados Servicios Digitales) at a rate of 3% on revenues from digital advertising, online intermediation and data transmission for groups with global revenues above €750 million and Spanish revenues above €3 million.
The Intensification of Transfer Pricing Controls
The AEAT has communicated that 2025 will be a year of intensified inspections on transfer pricing, particularly for groups with subsidiaries in low-tax jurisdictions and in intangible asset transactions (brands, patents, know-how) between group entities. Mandatory documentation — masterfile and local file — must be prepared and up to date before the fiscal year closes.
Groups with active Advance Pricing Agreements (APAs) must verify that their actual transaction conditions remain within the agreed parameters, as any deviation can prompt an adjustment proposal from the inspectorate.
The International Investor Perspective: Spain Remains Attractive
From the perspective of the international investor, Spain remains an attractive destination for foreign direct investment. The Article 21 LIS exemption on dividends and capital gains, access to Spain’s extensive double tax treaty network (over 100 treaties in force), and the specific advantages of the Startup Law for new technology companies combine to offer a competitive environment at the European level.
SICAV vehicles and other collective investment instruments have reduced their attractiveness following recent reforms, but SOCIMIs (Spain’s equivalent of REITs) maintain their favourable regime for institutional real estate investment.
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