Corporate Income Tax 2026: Lower rates for SMEs, new deductions, and the minimum 15% tax for multinationals

The tax landscape for companies in Spain is changing with the progress of tax regulations approved between 2024 and 2025. The modifications to Corporate Income Tax aim to incentivize investment, job creation and the consolidation of new companies, while introducing measures to strengthen revenue collection from large companies and multinationals.

 

Gradual reduction of interest rates for SMEs and micro-enterprises

One of the most notable measures is the gradual reduction of the tax rate for micro-enterprises and SMEs:

• SMEs (revenues between 1 and 10 million euros):
  
  • 2025: general type of 24%
    
  • 2026: 23%
    
  • 2027: 22%
    
  • 2028: 21%
    
  • 2029: 20%
    
    
• Micro-enterprises (income < 1 million euros):
  
  • 2025: 21% on the first €50,000 and 22% on the rest of the taxable base.
    
  • 2026: 19% on the first €50,000 and 21% on the rest.
    
  • 2027: 17% on the first €50,000 and 20% on the rest.
    

These reductions make Corporate Income Tax a more competitive tax, especially for small and medium-sized enterprises.

 

Deductions for increasing capital and expanding staff

The companies that increase their own funds In 2025, a deduction may be applied to this amount. The percentage of the deduction varies depending on the growth of the workforce.

• Base: up to the 20% of the increased equity — higher than the 15% of 2024.
  
• If the workforce grows between 2% and 5%: deduction of 23%.
  
• If it grows between 5% and 10%: 26,5%.
  
• If it exceeds 10%: 30%.
  

Besides, micro-enterprises with revenues below 1 million euros They can apply a deduction of 25%.

To take advantage of these deductions, both the increase in equity and the increase in staff must be maintained for three yearsIf the company does not achieve a sufficient taxable base to apply the deduction in the fiscal year, it may defer it to the following two years.

 

Tax advantages for newly created companies and startups

Newly created companies that obtain tax benefits will be able to apply a reduced type of the 15% in Corporation Tax for two consecutive years. This advantage extends to the startups (companies less than five years old, or seven in strategic sectors such as energy, biotechnology or industry), which will be able to apply the 15% rate in the first year with profits and the next three, favoring the growth and consolidation of these projects.

 

Minimum tax under 15% for multinationals

For the first time, large companies and multinational groups with annual income exceeding 750 million euros they will have to pay a 15% global minimum taxThis tax applies to:

• Matrices based in Spain.
  
• Foreign subsidiaries of Spanish companies.
  
• Subsidiaries in Spain of foreign companies.
  

The first deadline for paying this tax will be between July 1 and 20, 2026, in conjunction with the installment payments of Corporations.

 

Other relevant tax measures

Cooperatives:
They will pay taxes to 20% on profits in 2025reducing to 12% if they are newly created.

Donations and patronage:
Companies will be able to reduce by up to 40% of a donation to NGOs or foundations, with a limit of 15% of the taxable baseIf the donation is repeated for two consecutive years, the deduction can reach 45%.

Electric vehicles:
Investments in electric vehicles and charging infrastructure made in 2024 and 2025 are freely amortizable, although this advantage Expires on December 31, 2025.

Customer service:
Customer service expenses (travel, meals, accommodation) will be tax-deductible up to a maximum of 1% of the income.

 

Limitation on loss compensation

Limits on loss compensation for large companies will remain in place through 2025:

• Income €20M–€60M: compensation limited to 50%.
  
• More than €60M: limit of the 25%.
  

Consolidated groups can deduct uncompensated losses of subsidiaries in ten future fiscal years, in equal parts.

 

Installment payments endorsed by the Constitutional Court

The Constitutional Court confirmed the legality of requiring companies with a turnover of more than 10 million euros to pay a minimum tax rate. 23% in installments, thus consolidating the practice of paying part of the annual tax in advance without bonuses or reductions.

 

R&D&I: uncertainty and fiscal control

Although the Supreme Court has historically protected R&D tax credits, the Central Economic-Administrative Court (TEAC) has clarified that the Treasury may question the deductibility of R&D&I expenses, especially in relation to the impact of these expenses on the main activity.

Currently, the applicable deductions for Corporations are:

• 25% through R&D
  
• 12% through technological innovation
  
• 8% for investment in tangible and intangible fixed assets
  

The joint deduction cannot exceed 25% of the full quota.

 

Salaries of administrators and deductibility

The Tax Agency has allowed the following expenses to be deductible since April 2024: salaries of administrators and managersprovided that it is proven that they correspond to actual services effectively provided for these charges.

 

Accrual rule for expenses

The Supreme Court reiterated that expenses must be deducted in the fiscal year in which they are recorded, respecting the accrual principle, and not retroactively.

 

Conclusion

The changes to Corporate Income Tax for 2026 represent a complex set of incentives and obligations that will have a different impact depending on the size of the company, its income level, investment in R&D&I, hiring and financing strategies.

For SMEs and micro-enterprises, the reduction in tax rates and the deductions for capital increases and staff growth represent a clear opportunity to optimize their tax burden. For large corporations, the minimum tax under Article 15% and the installment payments upheld by the Constitutional Court are key elements to consider in their planning.

If you need to assess how these changes affect your business or design a personalized tax strategyOur team of experts can help you optimize your corporate tax and prepare your tax obligations in accordance with current regulations.