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Tax reform: Comments on the draft bill establishing a supplementary tax to ensure a global minimum level of taxation in multinational groups and large spanish groups

As part of the ongoing monitoring of the production of tax legislation, the Trustees of Fundación Impuestos y Competitividad have presented their preliminary observations on the aforementioned draft bill which aims to complete the transposition of European Directive 2022/2523 of the Council of 15 December 2022.

This process which ends in what has become known as Pillar II, taking as a basis the BEPS action 1 project “Tax challenges arising from the digital economy for multinational enterprises”, is undoubtedly an essential element in the new configuration of corporate income tax and a very important step in the definition of “global taxation for multinational companies”.

Considering the significance of this regulation, the Fundación Impuestos y Competitividad has made a notable effort to contribute some considerations which are as broad and robust as possible in keeping with its commitment to achieve the transposition of this scheme in terms which are as consistent as possible with its objectives in terms of legal certainty for taxpayers and the competitiveness of the Spanish tax system.

These observations are now made publicly available given the interest which the matter triggers for all social players with an important role in the field of taxation.