The Spanish tax landscape for 2026 brings significant changes that every growing business needs to understand and anticipate. From modifications to tax rates to new incentives for internationalisation, tax planning is more than ever a key strategic tool.
Key Changes for the 2026 Fiscal Year
The tax reform approved in late 2025 introduces relevant adjustments to Corporate Income Tax. Companies with turnover below ten million euros will benefit from an expanded reduced rate, provided they meet certain requirements regarding job creation and profit reinvestment. Additionally, deductions for research, development and technological innovation are strengthened, with more generous percentages for projects incorporating artificial intelligence and sustainable technologies.
For SMEs taxed at the standard 25% rate, combining the reduced rate with the capitalisation reserve and equalisation reserve can translate into significantly lower effective taxation. The equalisation reserve allows the taxable base to be reduced by up to 10% (with a maximum of one million euros per period), with the effect of anticipating the offset of future losses or deferring tax for up to five financial years.
R&D&i Deductions with Artificial Intelligence Component
The strengthening of R&D&i deductions is one of the most significant developments of 2026. Projects incorporating artificial intelligence, machine learning or big data processing components may qualify for enhanced deduction percentages: up to 30% of research and development expenses incurred in the period, and up to 50% of the excess over the average of the two previous periods.
To access these deductions with full guarantees, it is advisable to obtain a motivated report from the Ministry of Science and Innovation certifying the R&D or technological innovation nature of the project. This report is binding on the AEAT regarding the classification of the project, although not on the applicable deduction amount.
Companies with insufficient tax liability to apply the deduction in the period may request its payment in the annual CIT refund or carry it forward to the following eighteen periods, making it a valuable tool even for companies in the investment phase or with temporary negative results.
Impact on Expanding Businesses
For companies in a growth phase, tax planning takes on an especially critical dimension. Expansion into new markets, hiring international talent and investing in productive assets generate fiscal opportunities that, when well managed, can result in significant savings. However, they also increase the complexity of regulatory compliance.
It is essential to review the corporate structure and cash flows to ensure that the tax burden is optimised within the legal framework. Coordination between domestic and international taxation is particularly relevant in cross-border operations, where double taxation treaties and European directives offer tax efficiency mechanisms that should not be overlooked.
Companies operating in several EU countries must pay particular attention to the implications of the OECD Pillar Two framework (global minimum rate of 15%), which affects multinational groups with consolidated revenues exceeding 750 million euros. While SMEs do not reach this threshold, their membership of larger groups may place them within the scope of the rule.
Internationalisation Incentives
The tax regime for companies taking the international step is particularly favourable in Spain. The participation exemption for foreign-source dividends and capital gains (Article 21 of the CIT Act) allows dividends received from foreign subsidiaries to be taxed at 0%, subject to certain participation and activity conditions. For companies in the process of internationalisation, correctly structuring the holding of foreign participations from the outset can save millions in effective taxation.
The Special Canary Islands Zone (ZEC) special regime offers a CIT rate of 4% for activities carried out materially in the Canary Islands, with a variable taxable base limit depending on the number of employees. For technology or digital service companies that can establish operations in the islands, the ZEC can represent a very significant tax advantage before the registration deadline expires in December 2026.
Recommended Strategies
At BMC, we recommend our clients adopt a proactive approach. This involves conducting a comprehensive tax review before the end of the first quarter, identifying applicable deductions and allowances, and establishing a tax obligations calendar to avoid surprises. Digitising accounting processes and integrating real-time tax reporting tools are investments that pay for themselves quickly.
The main planning actions for 2026 are:
- Review whether the company meets the requirements for the reduced CIT rate and, if so, manage the necessary job creation and reinvestment.
- Identify and document R&D&i projects to maximise tax deductions, requesting a motivated report where appropriate.
- Analyse the structure for holding foreign participations before receiving dividends or realising capital gains.
- Assess whether joining the ZEC regime is viable for the company’s activities.
- Update the tax obligations calendar to incorporate new dates arising from the reform.
Looking Ahead
The tax environment will continue to evolve with the progressive implementation of the OECD Pillar Two framework and new fiscal transparency obligations. Companies that integrate tax planning as part of their corporate strategy will be better positioned to grow sustainably and competitively.
At BMC, our tax team works closely with clients to turn regulatory complexity into competitive advantage. If you need guidance on how these changes affect your business, do not hesitate to contact us.
