The Spanish Tax Agency requests comments on the provisions relating to the Pillar 2 Global Minimum Taxation Scheme

Spain’s General Directorate of Taxation launched a consultation on May 16 on rules for a system ensuring a global minimum taxation of 15% for multinational enterprises (MNEs) and large groups in the EU with an annual income exceeding €750 million ($815.5 million) under EU Directive 2022/2523 and the second pillar of the OECD. The regulations would include measures clarifying aspects of the draft law for the system relating to: 1) primary and secondary supplementary taxes based on the Income Inclusion Principle (IIR) and the Under-Taxed Profit Principle (UTPR); 2) national supplementary tax for its constituent entities established in Spain, if the effective tax rate…