We previously informed you of the main changes to the 2025 Corporate Income Tax regulations. As the filing deadline approaches, we would like to revisit the key developments and highlight several additional changes affecting this year’s filing campaign.
- Capitalisation Reserve
As a general rule, the reduction available under the capitalisation reserve regime has increased from 15% to 20% of the increase in a company’s equity. This reduction may increase to 23%, 26.5% or 30% if certain average workforce growth requirements are met.
In addition, the maximum amount of the reduction has been increased. As a general rule, the reduction may not exceed 20% of the taxable base before applying said reduction. This limit increases to 25% for taxpayers whose net turnover was below €1 million during the 12 months preceding the start of the relevant tax period.
- New Corporate Income Tax Rates
New Corporate Income Tax rates have been introduced for micro-enterprises, small companies and cooperatives, with transitional rules applying to the first two categories.
For tax periods beginning in 2025, the applicable rates are as follows:
- Micro-enterprises
- 21% on the first €50,000 of taxable income.
- 22% on the remaining taxable income.
- Small Companies (Reduced-Size Entities): Taxed at 24%, unless subject to a different statutory tax rate.
- Tax-Protected Cooperative Companies
- Cooperative income: taxed at rates obtained by reducing the standard Corporate Income Tax rates established in Article 29.1 of the Corporate Income Tax Act by 3 percentage points, provided that the resulting rate does not exceed 20%.
- Non-cooperative income: these entities will be taxed at the rates established in Article 29.1 of the Corporate Income Tax Act.
- Credit Unions and Rural Savings Banks
- Cooperative income: taxed at the rates established in Article 29.1 of the Corporate Income Tax Act.
- Non-cooperative income: taxed at a rate of 30%.
- Minimum Taxation
For entities whose net turnover in the previous tax period was <below €1 million, the following minimum effective tax rates apply for the purposes of determining the minimum net tax liability referred to in Article 30 bis(1) of the Corporate Income Tax Act (which applies to taxpayers with an annual turnover of at least €20 million or taxpayers forming part of a tax consolidation group, regardless of net turnover):
- 13% on the first €50,000 of taxable income.
- 14% on the remaining taxable income.
For other small companies (reduced-size entities), the applicable percentage is calculated by multiplying the general Corporate Income Tax rate established in Article 29.1 of the Corporate Income Tax Act by 15/25, rounded up where necessary. Consequently, for tax periods beginning in 2025, the applicable percentage is 15%.
- Freedom to depreciate
The freedom to depreciate regime applies to investments in facilities using energy from renewable sources, as well as to certain vehicles and new charging infrastructure, provided that these assets are used for business activities.
- 2025 Filing Campaign – Changes to Tax Return Form 200
- The classification of a company’s main business activity has been updated to reflect the new National Classification of Economic Activities 2025 (CNAE-2025).
- New sections have been added to identify whether an entity is the subsidiary or ultimate parent company of a multinational group or a large domestic group. In line with this change, the “Corporate Group” section on page 1 bis has been amended to facilitate the application of Law 7/2024 of 20 December, which introduces a complementary tax designed to ensure a global minimum level of taxation for multinational groups and large domestic groups.
- New validation and warning messages have been incorporated to verify returns filed using Tax Period Type 3, where the tax period is shorter than 12 months.
- The Capitalisation Reserve section has been updated.
- Procedural changes have been introduced regarding amended self-assessments.
- Improvements have been made to the reporting requirements applicable to Economic Interest Groupings (AIEs) and Temporary Joint Ventures (UTEs).
- Taxpayers subject to regional (foral) tax regulations: Taxpayers subject to regional (foral) tax regulations will now be able to file returns in a machine-readable XML format through the Spanish Tax Agency’s electronic filing platform, where the file will subsequently be converted for processing.
At PLANA VENTURA GARCÉS, we are avaialble to assist you with any matters relating to the current Corporate Income Tax filing campaign, as well as with your tax planning and compliance obligations.
