Minimum Corporate Taxation

With effects for tax periods starting from 01-01-2022, minimum taxation of 15% is established in Corporation Tax. This amendment in the Law affects the following taxpayers:

  • Companies with revenues are at least 20 million Euros during the 12 months before the date on which the tax period begins and,
  • Companies that are taxed in the fiscal consolidation regime, regardless of the amount of the revenues.

In these cases, the net amount of Corporation Tax may not be less than the result of applying 15% to the tax base,  reduced or increased by the equalization reserve and reduced in the Reserve for Canary Islands Investments.

Calculation of the tax liability


  • In the first place, the full quota is reduced in the applicable tax allowances.
  • Secondly, apply double taxation deductions 

Once the tax allowances and double taxation deductions have been applied, if the result is less than the minimum liquid quota, this result will be considered a minimum liquid quota.

The remaining deductions that are applicable can be applied until the amount of minimum liquid quota.


This modification in taxation will not affect taxpayers who pay taxes at the tax rates of 0%, 1% or 10%. Neither will it affect SOCIMI.

Special rules

  • For newly created companies, the percentage to be applied is 10%
  • For entities with a tax rate of 30% (credit institutions and hydrocarbon research and exploration entities), the percentage to be applied is 18%.
  • In the case of cooperatives, the minimum liquid quota cannot be less than the result of applying 60% to the full quota calculated following the provisions of their special regime.
  • In ZEC entities, the positive tax base on which the percentage is applied does not include the part corresponding to the transactions carried out materially and effectively in the geographical scope of the ZEC that is taxed at the special tax rate.


If you have any questions regarding this topic, please contact our tax advisors in Barcelona by phone or email.

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