Is there a minimum corporate tax rate?

With effect for tax periods beginning on or after 1 January 2022, for taxpayers whose net turnover is at least €20 million during the 12 months prior to the start of the tax period or who are taxed under the special consolidation regime, regardless of their net turnover, the net quota may not be less than the result of applying 15 percent to the tax base, reduced or increased, where appropriate and as appropriate, by the levelling reserve, and reduced by the investment reserve regulated in article 27 of Law 19/1994, of 6 July, amending the Economic and Tax Regime of the Canary Islands. This quota will have the character of a minimum net quota.

The minimum net rate will not apply to taxpayers who pay the tax rates provided for in sections 3, 4 and 5 of article 29 of Law 27/2014 or to entities under Law 11/2009, of October 26, which regulates Listed Public Limited Companies for Investment in the Real Estate Market.

For taxpayers who pay tax at the rate of 15% as provided in section 1 of article 29 of Law 27/2014, because they are newly created entities, the minimum net rate will be 10% of the taxable base.

Taxpayers who pay taxes at the tax rate provided for in the first paragraph of section 6 of article 29 of Law 27/2014, that is, credit institutions, as well as entities dedicated to the exploration, research and exploitation of hydrocarbon deposits and underground storage facilities in the terms established in Law 34/1998, of October 7, of the hydrocarbon sector, the minimum net rate will be 18% of the taxable base.

In cooperative entities, the minimum net quota may not be less than the result of applying 60% to the full quota calculated in accordance with the provisions of Law 20/1990, of December 19, on the Tax Regime of Cooperatives.

For entities in the Canary Islands Special Zone, the positive tax base on which the percentage is applied will not include the part thereof corresponding to operations carried out materially and effectively within the geographical area of said Zone that is taxed at the special tax rate regulated in article 43 of Law 19/1994, of July 6, amending the Economic and Fiscal Regime of the Canary Islands.

With effect for tax periods beginning on or after 1 January 2025 , section 1 of article 30 bis of Law 27/2014, of 27 November, on Corporate Income Tax, is amended by section Four of the Eighth Final Provision of Law 7/2024, with the purpose of adapting the determination of the minimum net tax to the tax rates of article 29 section 1 of Law 27/2014. Thus, it is established that in the case of entities whose net turnover for the immediately preceding tax period is less than 1 million euros, for the purposes of determining the minimum net tax rate, the percentage indicated will be the result of multiplying the scale provided for in section 1 of article 29 of Law 27/2014 by fifteen twenty-fifths , rounded up. In the case of small entities, the percentage indicated will be the result of multiplying the tax rate provided for in section 1 of article 29 of Law 27/2014 , by fifteen twenty-fifths, rounded up .