2026 brings a quiet but significant change: the corporate tax rate is falling again for many small and micro-enterprises, and this changes the year-end picture. The 2026 fiscal year not only changes figures, it changes decisions, because the corporate tax rate is being adjusted downwards once more.
If your company is small - generally speaking, if its turnover does not exceed ten million euros - the Corporate Income Tax begins a downward path that will continue for several years.
This is not a sudden jump, but a gradual reduction, year by year, which will take the rate from the current 25% to 20% from 2029 onwards. In practice, each year-end will be taxed a little less than the previous one.
It's a subtle but cumulative change.
- Please note: The reduction is not automatic simply for being "small"; it depends on meeting the requirements for small businesses each year.
- Micro-enterprises fall under a different scheme
When we talk about micro-enterprises—companies whose turnover does not exceed one million euros—the tax design changes. From 2025 onwards, the rate will no longer be a single rate but will become progressive.
The first €50,000 of taxable income is taxed at a lower rate, while the excess is taxed at a slightly higher rate. Furthermore, these rates also decrease over subsequent tax years.
This means that two companies with the same profit may pay different amounts depending on how their taxable income is distributed.
- Note: Not all taxable income is taxed at the lowest rate; only the first bracket.
- Not all companies benefit from this discount
To be perfectly clear: these reductions do not apply to asset-holding companies. If more than half of the assets consist of securities or are not used in an economic activity, the standard rate of 25% will apply.
It is one of those nuances that are often overlooked and that, when detected late, generate unpleasant surprises.
- Attention. A company may appear "operational" and still be considered a holding company for tax purposes.
- Short exercises and proportional limits in micro-enterprises
When a microenterprise has a fiscal year of less than one year - for example, due to a change in the closing date - the taxable base bracket that can be taxed at the reduced rate is not fixed.
That limit of 50,000 euros is prorated based on the actual duration of the tax year. Furthermore, it can never exceed the taxable income for that period.
In practice, this forces you to do the math with a bit more care, because it's not always in your best interest to close the financial year when it seems more convenient from a business perspective.
Changing the closing date can alter the effective corporate tax rate without it being immediately apparent.
- 2026 as a fiscal turning point
The year 2026 marks a new step in this gradual reduction. Small businesses will be taxed at 23%, and micro-enterprises will see the rates applicable to their tax brackets decrease again.
This scenario introduces an interesting variable into planning: the timing of when profits are generated starts to matter more than before.
It is not an invitation to force decisions, but rather to think with a bit more perspective.
- Attention. Delaying or bringing forward income and expenses can make fiscal sense, but only if there is a real economic reason behind it.
Tax rate
The tax rates applicable to tax periods beginning in 2024 and 2025 (Art. 29 and DT 44ª LIS) are as follows:
| Taxpayers |
2024 |
2025 |
| General type |
25% |
25% |
| Micro-enterprises (INCN <1,000,000) |
|
| Up to €50,000 |
23% |
21% |
| Rest BI |
23% |
22% |
| Small-sized entities (art. 101 LIS) |
25% |
24% |
| Newly Created Entities (NCE) (1) |
15% |
15% |
| Startups(2) |
15% |
15% |
| Asset entity |
25% |
25% |
| Fiscally protected cooperatives: |
|
| Cooperative returns |
| General |
20% |
20% |
| Micro-enterprises up to €50,000
Rest BI |
20% |
18%
19% |
| Small size entrance |
20% |
20% |
| ENC |
20% |
12% |
| Non-cooperative returns |
|
| General |
25% |
25% |
| Micro-enterprises up to €50,000
Rest BI |
23% |
21%
22% |
| Small size entrance |
25% |
24% |
| ENC |
25% |
15% |
| Credit cooperatives and rural savings banks: |
|
| Cooperative returns |
| General |
25% |
25% |
| Micro-enterprises up to €50,000
Rest BI |
23% |
21%
22% |
| Small size entrance |
25% |
24% |
| ENC |
25% |
15% |
| Non-cooperative returns |
|
| General |
30% |
30% |
| Micro-enterprises |
30% |
30% |
| Small size entrance |
30% |
30% |
| ENC |
30% |
30% |
| SOCIMI (Law 11/2009)(3) |
0% |
0% |
| Special tax on distributed profits |
19% |
19% |
| Special tax on undistributed profits |
15% |
15% |
| ZEC Entities – Canarian Special Zone(4) |
4% |
4% |
| Entities Law 49/2002 |
10% |
10% |
| Credit institutions and entities engaged in the exploitation, research and exploration of hydrocarbon deposits and underground storage facilities |
30% |
30% |
| Investment Companies and Funds, Bank Asset Funds, SICAVs and Mortgage Market Regulation Funds |
1% |
1% |
| Pension funds |
0% |
0% |
Grades
(1)For newly created entities, Transitional Provision 22 of the LIS must be taken into account.
(2)For emerging companies, Article 7 of Law 28/2022, of December 21, on the promotion of the emerging companies ecosystem, must be taken into account.
(3)Please note that in the event of entry-exit into the special tax regime of Law 11/2009, of October 26, which regulates the Listed Public Limited Companies for Investment in the Real Estate Market, Article 12 of the aforementioned law provides for certain rules in accordance with the general regime and the general tax rate of the Corporate Income Tax.
(4)Please note that the portion of the taxable base corresponding to operations not effectively and materially carried out within the Canary Islands Special Zone will be subject to the general corporate tax rate corresponding to the type of entity.
Source: AEAT
Small size
| Concept |
2024 |
2025 |
2026 |
2027 |
2028 |
From 2029 |
| IS Type |
25% |
24% |
23% |
22% |
21% |
20% |
Microenterprise
| Concept |
2024 |
2025 |
2026 |
From 2027 |
| Up to 50,000 |
23% |
21% |
19% |
17% |
| Base remainder |
22% |
21% |
20% |
- Planning without forcing, the silent key
In this context, it may be reasonable to consider whether it is advisable to postpone certain operations to years with lower rates or to bring forward expenses in order to soften the tax burden of the current year.
However, these types of adjustments must be made with caution. The line between planning and forcing is finer than it seems, and the Administration tends to focus particularly on year-end closings that are "too timely.".
Tax planning works best when it is discreet, consistent, and documented.
- A price reduction that deserves to be monitored year after year
The reduction in corporate tax is not an isolated event for a single fiscal year. It is a process that unfolds over time and requires reviewing each year-end with a slightly different approach than the traditional one.
It's not just about paying less, but about understanding when and why you pay less.
Taking the IS type for granted without reviewing current regulations can lead to ill-adjusted decisions.
You can contact this professional office for any questions or clarifications you may have.
Warm regards,
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A Àmbit Assessor, SL has 40 years dedicated to the tax, comptable and labor consultancy of the Pime.
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