Spain: Consultation on draft legislation implementing Pillar Two global minimum tax

Comments accepted until May 31, 2024

Comments accepted until May 31, 2024

The government on December 19, 2023, published draft legislation to implement the OECD’s Pillar Two global minimum tax as provided under the EU Minimum Tax Directive 2022/2523. Read a KPMG report 

The Directorate-General for Taxation is now seeking comments from the most representative taxpayers and organizations potentially affected by the top-up tax, who have from May 17, 2024, until May 31, 2024, to submit their opinions.

Comments are specifically sought on the following five key areas:

  • Taxpayers subject to the top-up tax
  • Calculation of the tax base and adjusted covered taxes
  • Insurance companies
  • Information return
  • Management of the complementary tax

Next steps

Upon conclusion of this consultation, the Draft Royal Decree will be drawn up and published, following which a new period for comments and public consultation will commence (which, in principle, cannot be shorter than 15 business days).

Read a May 2024 report prepared by the KPMG member firm in Spain

For further information, contact a KPMG professional in Spain:

Pelayo Ora |

Clara Guasch |

Felipe Martinez |



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