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Tax Advisory in Navarra: Economic Agreement, Hacienda Foral, and the Autonomous Community's Own Tax Regime

Specialists in the Navarra Economic Agreement: CIT under Foral Law 26/2016, foral IRPF, Hacienda Foral de Navarra, and connection points for foral companies.

Navarra's Economic Agreement: why Navarra's tax regime is unique and must not be confused with the Basque regime

Law 28/1990
Legal basis of Navarra's Economic Agreement
Foral Law 26/2016
Navarra CIT: own rates and deductions
20%
CIT rate for newly created companies (first year)
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Quick assessment

Does this apply to your business?

Do you know whether your company must pay to the Hacienda Foral de Navarra or to the AEAT under Economic Agreement rules?

Are you correctly applying the Economic Agreement connection points for CIT and VAT?

Are you aware of the Foral Law 26/2016 deductions that do not exist in the state CIT?

Have you analysed the differences in Navarra's foral IRPF for your employees resident in the Autonomous Community?

0 of 4 questions answered

Our approach

Our foral tax advisory team in Navarra: specialists in the Economic Agreement and Foral Law 26/2016

01

Economic Agreement connection point analysis

We determine which administration — Hacienda Foral de Navarra or AEAT — has jurisdiction over your company's tax in each tax (CIT, VAT, IRPF), applying the Economic Agreement rules of Law 28/1990 as updated by Foral Law 36/2022. We identify double taxation risks and cross-administration overlaps.

02

Tax strategy under Foral Law 26/2016 CIT

We develop a plan exploiting the Navarra CIT's own rates and deductions: differentiated rates for SMEs (25% general, 23% for bases below EUR 60,000, 20% for newly created companies in the first year), foral R&D deductions, and foral Navarra tax consolidation.

03

Compliance before the Hacienda Foral de Navarra

We manage all tax obligations before the Hacienda Foral de Navarra: foral CIT (Form 200 N), foral VAT (Form 130 N), foral Navarra IRPF, foral Wealth Tax, and informative returns. We file self-assessments on time before the competent body.

04

Coordination with common territory and other foral territories

Where the company operates in both Navarra and common territory or the Basque Country, we coordinate taxation between administrations under Economic Agreement and Concierto Económico allocation rules, avoiding both double taxation and cross-assessment.

The challenge

Navarra operates under a tax system radically different from Spanish common territory: the Economic Agreement between the State and the Autonomous Community of Navarra — governed by Law 28/1990 and updated by Foral Law 36/2022 — grants the Hacienda Foral de Navarra full normative and revenue powers over the main direct and indirect taxes. Navarra's Corporate Income Tax is governed by Foral Law 26/2016 — not by the state Law 27/2014 — with its own rates and deductions that many companies with activity in Navarra are unaware of. Unlike the Basque Provincial Treasuries (Bizkaia, Gipuzkoa, Álava), whose foral system operates through the Basque Economic Agreement (Law 12/2002), Navarra has its own legal instrument: the Economic Agreement, with its own connection-point rules and a Hacienda Foral with full management and inspection autonomy.

Our solution

BMC serves companies and groups with activity or a registered office in Navarra through a model of specialist advisory in the Economic Agreement: analysis of connection points to determine which administration — Hacienda Foral de Navarra or AEAT — has jurisdiction for each tax, compliance under Foral Law 26/2016 CIT, foral Navarra IRPF planning, foral Wealth Tax, foral ISD, and coordination where the client's activity extends simultaneously to common territory and foral Navarra. Routine advisory is provided remotely, with video conferences, digital documentation, and electronic representation before the Hacienda Foral.

Navarra is the only Spanish Autonomous Community with a fully foral tax system articulated through the Economic Agreement between the State and the Autonomous Community of Navarra (Law 28/1990, most recently updated by Foral Law 36/2022). Unlike the common regime, the Hacienda Foral de Navarra has normative, management, and inspection competence over the main taxes: Corporate Income Tax is governed by Foral Law 26/2016, with its own rates and deductions; foral IRPF has its own consolidated text; and Wealth Tax and Inheritance and Gift Tax also follow differentiated Navarra legislation. Navarra's foralidad must not be confused with the Basque foral systems (Bizkaia, Gipuzkoa, Álava), which have their own Concierto Económico (Law 12/2002) with similar characteristics but structurally different features.

The Navarra Economic Agreement is one of Spain’s two major foral tax regimes, alongside the Basque Economic Agreement. Both have historical roots that predate the 1978 Constitution and were expressly recognised by its First Additional Provision. However, they present first-order institutional and normative differences.

In Navarra, the management of the main taxes falls to the Hacienda Foral de Navarra (a body of the Autonomous Community), not a Provincial Council. This means there is a single foral tax administration for the whole of Navarra, with its seat in Pamplona. The Economic Agreement Law 28/1990, as updated by Foral Law 36/2022, governs the connection points that determine when a company pays to the Hacienda Foral de Navarra and when to the AEAT.

Our Foral Tax Advisory Team in Navarra: Specialists in the Economic Agreement and Foral Law 26/2016

BMC serves companies with activity or a registered office in Navarra through a remote specialist advisory model focused on the Economic Agreement. Our Madrid tax team has hands-on experience analysing Navarra Economic Agreement connection points, compliance under Foral Law 26/2016, and coordinating between the Hacienda Foral de Navarra and the AEAT for groups with simultaneous activity in several territories.

For proceedings requiring a physical presence in Pamplona — Hacienda Foral inspections, TEAFNA proceedings, in-person dealings with the Navarra Tax Agency — we collaborate with local members who know the internal workings of the foral tax administration.

What a Company with a Registered Office in Navarra Can Save

Foral Law 26/2016 sets rates that in some brackets are more favourable than the state CIT:

Company typeState CIT (Law 27/2014)Navarra foral CIT (Foral Law 26/2016)
General regime25%25%
SME (base < EUR 60,000)23%23%
New creation (1st year)15% (state law)20% (own foral rate)
Protected co-operatives20%Own foral rate

Beyond rates, the Foral Law 26/2016 deductions can represent a significant advantage over state CIT in R&D, job creation, and productive investment sectors.

What Our Tax Advisory Service in Navarra Includes

Initial connection point analysis: we review your company or group’s position to determine precisely which administration — Hacienda Foral de Navarra, AEAT, or Basque Haciendas Forales — has jurisdiction for each tax and for what proportion of turnover, under the current Economic Agreement.

Foral Navarra CIT compliance: preparation and filing of Form 200-N (Navarra foral CIT), with correct application of Foral Law 26/2016 rates, own foral deductions, and foral consolidation rules where applicable.

Foral VAT and IRPF compliance: periodic VAT self-assessments before the Hacienda Foral de Navarra for companies with a foral registered office, and management of foral Navarra IRPF for payroll withholdings and for members or directors resident in Navarra.

Foral Wealth Tax and ISD planning: analysis of the family business exemption in foral Navarra IP and of the foral ISD reductions for transfers on death and inter vivos.

Cross-administration coordination: for groups operating simultaneously in Navarra and common territory or the Basque Country, we manage proportional taxation under applicable connection points, coordinate with the AEAT and the Basque Diputaciones Forales as needed, and document the adopted approach to protect the group against cross-audits.


Request a connection point analysis with our team specialising in the Navarra Economic Agreement.

Track record

What a company with a registered office in Navarra can save compared with the common tax regime

We had a subsidiary in Pamplona and had been filing CIT with the AEAT for years when we should have been paying mostly to the Hacienda Foral. BMC analysed the connection points, regularised the situation, and designed a plan that exploits the Foral Law 26/2016 deductions. The tax saving and legal certainty are incomparable.

Industrial group based in Pamplona
Finance Director

Experienced team with local insight and international reach

What our tax advisory service in Navarra includes

Economic Agreement connection point analysis

Determination of the competent administration (Hacienda Foral de Navarra or AEAT) for each tax, under Economic Agreement rules of Law 28/1990 as updated by Foral Law 36/2022.

Navarra foral CIT — Foral Law 26/2016

Compliance, planning, and optimisation under Navarra CIT: differentiated rates, specific deductions, foral consolidation, and self-assessment filing with the Hacienda Foral.

Navarra foral IRPF and withholdings

Management of foral IRPF for Navarra residents: own rate scale, foral deductions, payroll withholdings, and foral inpatriate special regime.

Foral Wealth Tax and ISD

Planning of foral Wealth Tax and Navarra foral ISD: reliefs, exemptions, and foral family business.

Cross-administration coordination

Management of proportional taxation for companies operating in Navarra and common territory or the Basque foral territories, avoiding double taxation and cross-assessments.

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Service Lead

Ana Garcia Montoya

Partner - Tax Division

Master in Taxation, CEF Law Degree, University of Barcelona
FAQ

Frequently asked questions about the Economic Agreement, the Hacienda Foral de Navarra, and the foral CIT

Although both Navarra and the Basque Country have their own foral tax systems, they are legally distinct regimes. Navarra's foralidad is based on the Economic Agreement (Law 28/1990, updated by Foral Law 36/2022) between the State and the Autonomous Community of Navarra. Basque foralidad operates under the Economic Agreement (Law 12/2002), and each historical territory (Bizkaia, Gipuzkoa, Álava) has its own Diputación Foral with differentiated legislation. In Navarra, management and collection of the main taxes falls to the Hacienda Foral de Navarra (a body of the Autonomous Community), not a Provincial Council. The connection-point rules of the Navarra Economic Agreement and the Basque Concierto Económico are similar in structure but differ in detail.
Foral Law 26/2016 sets a general CIT rate of 25%, similar to common territory. However, there are differentiated rates: (1) a reduced rate of 23% for companies whose taxable base is below EUR 60,000; (2) a rate of 20% for newly created companies in their first year with positive taxable income; (3) reduced rates for co-operatives and non-profit entities under their special regime. The deductions regime is its own and different from common territory: R&D, internationalisation, and job creation deductions have their own conditions and amounts set by Foral Law.
Connection points are the Economic Agreement rules that determine when a company must pay to the Hacienda Foral de Navarra and when to the AEAT. For CIT, the general rule is: if the registered office is in Navarra and turnover does not exceed EUR 7 million, taxation is exclusively to the Hacienda Foral. If that threshold is exceeded and the company operates in several territories, taxation is proportional to turnover in each territory (Navarra, Basque foral territories, common territory). A company that is unaware of these rules may file with the wrong administration, generating cross-assessments from both treasuries.
Navarra's IRPF is governed by Legislative Foral Decree 4/2008 (Consolidated Text of the Foral Law on IRPF, periodically updated). It has its own rate scale, deductions, and specific rules. The most relevant differences from state IRPF include: its own rate brackets, deductions for family and personal circumstances at different amounts, and a special inpatriate taxation regime (analogous to the Beckham Law but with its own conditions). A senior executive who moves their residence to Navarra should analyse whether to opt for the foral inpatriate special regime.
Yes, significantly. Navarra has its own normative competence over Wealth Tax and Inheritance and Gift Tax. Navarra's foral Wealth Tax has its own progressive rates and exemptions, including the family business exemption under specific foral conditions. As for Inheritance and Gift Tax, Navarra applies its own Foral Law with reliefs and exemptions different from common territory, which can make the tax burden on inheritances or gifts between close family members significantly different from what would apply in common territory.
Yes. Our Navarra advisory model is entirely remote: video conferences, digital documentation, and electronic filing before the Hacienda Foral de Navarra. When a proceeding requires a physical presence in Pamplona (Hacienda Foral inspections, TEAFNA proceedings), we collaborate with local members. Many companies based in Madrid, Barcelona, or abroad that operate or have subsidiaries in Navarra engage us precisely for our specialisation in the Economic Agreement, which is independent of geographical proximity.
The most relevant practical differences for companies are: (1) In Navarra there is a single Hacienda Foral for the whole territory; in the Basque Country, each historical territory (Bizkaia, Gipuzkoa, Álava) has its own Diputación Foral with its own normative powers. (2) The CIT connection-point thresholds are similar (EUR 7 million turnover as the mixed-taxation threshold) but differ in calculation. (3) Navarra has broader historical competences over VAT than the Basque territories. (4) CIT deductions and rates under Navarra foral law (Foral Law 26/2016) differ from those of each Basque foral CIT regulation.
Yes. Foral Law 26/2016 includes incentives that are in some respects more favourable than state CIT, particularly for newly created companies, R&D companies, and companies investing in Navarra. We analyse the opportunity to establish the registered office or activity centres in Navarra where this has genuine economic logic and offers legitimate tax advantages.
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