Country：西班牙 · Tax & Audit
Spain · Tax & Audit
The Spanish corporate income tax (CIT) general rate is 25%; newly formed companies apply 15% for their first two profitable periods and qualifying startups for their first four profitable periods. From 2025, SMEs and micro-enterprises gradually apply lower rates (micro-enterprises apply 22% to the portion not exceeding €50,000 in 2026, and SMEs 24%). The standard VAT rate is 21% (reduced rates 10%/4%). Withholding tax: dividends and interest 19%, royalties 19% or 24%. Companies meeting size thresholds must have an annual audit. Chinese companies structuring through Spain must add BEPS and global minimum tax considerations.
Key points
- CIT: general rate 25%; newly formed companies 15% for their first two profitable periods; qualifying startups 15% for their first four profitable periods; from 2025, micro-enterprises (net turnover below €1 million) and SMEs (below €10 million) gradually apply lower rates (2026: micro-enterprises 22% on the portion up to €50,000, SMEs 24%).
- VAT: standard rate 21%; reduced 10% (some food, hotels) and 4% (basic food, medicines); the Canary Islands apply IGIC instead of VAT.
- WHT: resident and non-resident dividends and interest 19%, royalties 19% or 24%; tax treaties may reduce further.
- Minimum tax: for turnover of at least €20 million or group taxpayers, CIT net liability must not be below 15% of taxable income (GloBE-like, from 2022).
- Transfer pricing: OECD standards apply; interest deduction capped at 30% of EBITDA (portion above €1 million); thin-capitalization rules do not apply, but related-party loan interest is non-deductible.
- Loss carry-forward: unlimited term but capped (turnover below €20 million can offset 70% of the positive tax base with a €1 million floor; €20–60 million portion 50%; above €60 million 25%).
- Audit: required when two of the following three conditions are met for two consecutive years (turnover above €5.7 million, assets above €2.85 million, more than 50 employees).
Procedure
- Obtain the provisional tax number NIF/CIF at registration (also the VAT number).
- Make CIT provisional payments in April, October, and December (18% of prior-year tax or 24%/17% of current-year).
- File the CIT annual return and settle tax within 6 months and 25 days after the fiscal year end.
- Prepare transfer pricing documentation and master/local files for cross-border payments (CbCR required for groups with turnover of at least €750 million).
- Arrange an annual audit once size thresholds are met.
Hard requirements
- Tax number and VAT registration.
- Transfer pricing documentation and CbCR (group threshold).
- Annual audit (size threshold).
- Minimum tax calculation (large taxpayers).
Costs
Accounting and tax filing agents.Audit feesTransfer pricing and global minimum tax consulting.⏱ ⏱ Timeline：CIT annual return due within 6 months and 25 days after the fiscal year end; audits follow in the months after the fiscal year end.⚠ Common risks
- The 15% minimum tax squeezes planning space for low-substance holding companies
- The 30% EBITDA interest cap affects leveraged structures
- SME/micro rate cuts from 2025 are phased in and subject to conditions
- AEAT audits actively; documentation must be complete
Handbook
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to：Corporate income tax (CIT), VAT, transfer pricing, and audit obligations of Spanish tax-resident companies; includes BEPS/global minimum tax considerations for Chinese capital structured through Spain.
Prerequisites
- Company obtained NIF/CIF tax number (also VAT) and completed tax registration
- Accounting books and financial statements maintained under Spanish GAAP
- Group-level confirmation of transfer pricing and CbCR thresholds
- Assessment of whether statutory audit size thresholds are met
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | Obtain NIF/CIF (also VAT number) at registration. Obtain NIF/CIF (also VAT number) at registration and complete tax and VAT registration via the business census (Censo de empresarios). | AEAT / Company | See incorporation dimension | — | Censo de empresarios (Modelo 036 / 037) | Penalty：No tax number, no invoicing. |
| 2 | Make provisional CIT payments within the year. Make CIT provisional payments within the year (April, October, December, at 18% of prior-year tax or 24%/17% of current-year). | Company / tax advisor | April, October, December | Provisional tax paid | Modelo 202 provisional payment | Penalty：Late provisional payments incur surcharges. |
| 3 | File the CIT annual return after the fiscal year end. File the corporate income tax (CIT) annual return and settle tax within 6 months and 25 calendar days after the fiscal year end (calendar-year companies usually file 1–25 July of the following year; the 2025 return shifted to 27 July due to a weekend). | Company or tax advisor. | Fiscal year end + 6 months + 25 days (July for calendar-year companies). | Tax or filing agent fees. | Modelo 200 (Modelo 220 for groups). | Penalty：Late filing incurs fines and surcharges. |
| 4 | VAT filing. File VAT quarterly (303) and annual (390). | Company or tax advisor. | Quarterly (303) and annual (390). | VAT | Modelo 303 / 390 | Penalty：Late-filing penalties. |
| 5 | Transfer pricing and CbCR documentation. Prepare transfer pricing master and local files for cross-border payments; groups with turnover of at least €750 million must file a country-by-country report (CbCR). | Group tax. | Ongoing or annual. | Transfer pricing (TP) consulting. | Transfer pricing (TP) master and local files; CbCR (for groups meeting the threshold). | Penalty：Missing documentation leads to audit adjustments and additional tax. |
| 6 | Minimum tax and interest deduction compliance. Minimum tax and interest deduction compliance: large taxpayers' CIT net liability must not be below 15% of taxable income (GloBE-like); interest deduction capped at 30% of EBITDA (portion above €1 million). | Tax | Annual | Consulting | GloBE-like minimum tax calculation; interest deduction assessment | Penalty：Planning space compressed, additional tax. |
| 7 | Arrange an annual audit once size thresholds are met. Arrange an annual audit once size thresholds are met: audit required when two of three conditions are met for two consecutive years (turnover above €5.7 million, assets above €2.85 million, more than 50 employees). | Company / auditor | After fiscal year end | Audit fees | Statutory audit | Penalty：Operating without an audit is unlawful. |
✅ Self-check list
⚠ Common pitfalls
15% minimum tax squeezes low-substance holding planning影响：Additional tax规避：Increase economic substance and staffing
30% EBITDA interest deduction cap影响：Excess interest non-deductible规避：Optimize capital structure
SME/micro rate cuts are phased in影响：Wrong rate applied triggers audit规避：Verify 2025–2026 eligibility conditions item by item
Modelo 200 late filing影响：Fines and surcharges规避：Lock the July window and prepare early
Missing transfer pricing documentation影响：Audit adjustments, additional tax and fines规避：Maintain complete TP master and local files
Audit threshold misjudgment影响：Operating without an audit is unlawful规避：Measure indicators over two consecutive years
📅 Ongoing post-incorporation obligations
- File the annual CIT return Modelo 200 / 220 on time
- File CIT provisional payments Modelo 202
- Quarterly and annual VAT filings
- Transfer pricing documentation and CbCR
- Minimum tax calculation (large taxpayers)
- Annual statutory audit (when thresholds met)
- Continuous updating of UBO beneficial owner information
🔗 Official portals
📎 Source：Spanish Corporate Income Tax Law; Deloitte International Tax Spain Highlights 2025; PwC World Tax Summary Spain; Spanish Tax Agency (AEAT)
Want to turn this into an actionable compliance workflow?
CompliGo · Outbound Compliance Automation
You now have the essentials. Hand it to CompliGo: auto-generate compliance documents, real-time validation, and one-click regulatory alerts. Free trial for new users.
CompliGo is an independent SaaS operated by the outbound team. This knowledge base only drives acquisition and never handles funds or collects/pays on your behalf.