Tax changes on the horizon: New taxes and adjustments to Corporate Income Tax, Personal Income Tax and VAT.

Two new taxes are created: the Tax on Liquids for Electronic Cigarettes and other Tobacco-related Products, and the Tax on the interest margin and commissions of certain financial institutions. Regarding Personal Income Tax (IRPF), the top bracket of the savings tax base is increased by one percentage point, from 28% to 29%. In Corporate Income Tax, new percentages for reducing the capitalization reserve are established; tax rates are lowered for micro-enterprises and small businesses; limits are reinstated for large companies regarding negative tax bases, international deductions, and the reversal of impairment losses, among other measures awaiting parliamentary approval.

This circular is intended to inform you of the recent amendments proposed by the Socialist Parliamentary Group (PSOE) to the Bill establishing a Supplementary Tax to guarantee a minimum global level of taxation for multinational groups. These modifications cover a wide range of tax aspects, including the creation of new specific taxes, adjustments to Corporate Income Tax, an increase in the taxation of capital gains under Personal Income Tax, and additional measures to combat fraud, with different entry dates.

Below, we offer a complete summary of the main tax changes included in these amendments.

1. General Tax Law: deadline for inspection actions in Complementary Tax to guarantee a minimum overall level of taxation for multinational groups

The time limit for tax audits to verify or investigate the Complementary Tax, in order to guarantee a minimum overall level of taxation for multinational groups, will be 27 months (18 months is the general time limit). We remind you that the extended time limit also applies, among other cases, to audits of tax consolidation groups or the special group of entities regime.

2. New taxes: electronic cigarettes and financial margins

To cover new sectors, two specific taxes are created:

• Tax on Electronic Cigarette Liquids and Other Tobacco-Related Products: From January 2025, this tax will apply to electronic cigarette liquids, nicotine pouches, and other similar products. Rates will vary, ranging from €0.10 to €0.20 per milliliter or gram, depending on the product type and nicotine concentration.
• Tax on Interest and Fee Margins of Financial Institutions: This tax levies the positive margin of interest and fees in credit institutions and branches in Spain, with progressive rates from 1% to 6%. This new tax will not be deductible from Corporate Income Tax and will be applicable from 2024 (it will be applicable in the first three consecutive tax periods beginning on or after January 1, 2024).

3. Changes to Corporate Income Tax

The amendments affect several aspects of this key tax, including:

• Reintroduction of limits for large companies: Limits on the compensation of negative tax bases (BINs), previously revoked by the Constitutional Court, are reinstated, establishing caps of 50% for companies with income between 20 and 60 million euros, and 25% for those exceeding 60 million.
• Capitalization reserve: The reduction in the taxable base is modulated according to the increase in the workforce with effects for tax periods beginning on or after January 1, 2025.
• – 20 percent of the amount of the increase in equity, without taking into account the company's workforce.
• – 23 percent if the average workforce in the tax period has increased, compared to the workforce of the previous tax period, by a minimum of 2 percent without exceeding 5 percent.
• – 26.5 percent if the increase in the average workforce of the previous tax period is between 5 and 10 percent.
• – 30 percent if the increase in staff is greater than 10 percent.

The reduction amount cannot exceed 20% of the taxable base, or 25% if the net operating profit (INCN) is less than €1,000,000. If the taxable base is insufficient, the outstanding amounts may be applied in the tax periods ending in the two immediately following years

• Reversal of impairment losses and offsetting of negative tax bases (NTBs): To recover tax impairment losses on deductible assets prior to 2013, companies must reverse these amounts in equal parts starting in 2024. The limit on offsetting deductions for double taxation is also reactivated, applying only to companies with revenues exceeding 20 million euros.
• Reduced tax rates for micro-enterprises and small businesses: Starting in 2025, a reduced tax rate will be established for micro-enterprises, beginning at 17% for initial profits (up to €50,000) and 20% for subsequent profits. Small businesses will see their tax rate progressively reduced to 20% by 2028.

4. Adjustment to Personal Income Tax on Capital Gains

For taxpayers with higher capital gains, the proposal is to raise the maximum marginal tax rate from 28% to 29% starting in 2025, affecting savings income exceeding €300,000. This increase will also apply to the tax regime for expatriates on certain dividend and interest income.

5. Hydrocarbon tax and measures against fraud

With the aim of equalizing taxation between diesel and unleaded gasoline, the tax rate on diesel and biodiesel for general use will increase, including an adjustment based on the retail price. Furthermore, anti-fraud measures in tax warehouses for hydrocarbons will be strengthened, with sales platforms and establishments that authorize unauthorized withdrawals of these products being held jointly liable.

6. Changes to VAT

• Housing rentals: Short-term housing rentals (maximum 30 nights) are expected to be taxed in areas where this type of accommodation hinders access to housing for residents. In these cases, accommodation will be considered hotel-like and will be subject to VAT, not exempt. The platforms through which the short-term accommodation service is offered will be responsible for paying the VAT.
• Settlement period:  It will be monthly for the holders of tax deposits of gasoline, diesel or biofuels included in the objective scope of the Hydrocarbons Tax, as well as the entrepreneurs or professionals who extract these products from the tax deposits.
• Jointly liable for the payment of the tax debt: Those jointly liable for the debt arising from the subsequent subject and non-exempt delivery are declared to be the holders of the tax warehouses who have improperly authorized the extraction or the exit or abandonment of the goods from the deposit regime other than customs.

7. Special Taxes on Tobacco

Taxes on tobacco products and related items (cigarettes, cigars, and pipe tobacco) will increase. This adjustment aims to raise taxes in an effort to reduce consumption and align with European practices regarding taxes on products that affect public health.

8. Economic and Fiscal Regime of the Canary Islands (RIC)

For tax periods beginning on or after January 1, 2025, it is proposed to extend the possibility of realizing the RIC through the rehabilitation of protected housing for rent, aimed at people registered in the Register of Protected Housing of the Canary Islands.

9. Public electronic invoicing solution

In order to move towards digitalization, a provision is introduced that obliges private electronic invoicing platforms to send copies of each invoice issued to a public solution, allowing the Administration greater control over tax compliance.

10. Declaration obligation for electronic cigarette products and others

The obligation to declare an inventory of products subject to the new tax on e-cigarette liquids is introduced. Failure to submit the required declaration or submitting an incorrect declaration will result in a penalty of €500.

These amendments, still under consideration, reflect a significant restructuring in several areas of tax legislation. Since they may be subject to change during the parliamentary process, our tax department will closely monitor their development and will keep you informed of any changes that may affect you.

You can contact this professional office for any questions or clarifications you may have.

Warm regards,

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MGI Àmbit

A Àmbit Assessor, SL has 40 years dedicated to the tax, comptable and labor consultancy of the Pime.

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