Spain

Over the past year, the following significant amendments have been made to Spanish law on the taxation of companies:

Royal Decree-Law 18/2026

On 30 June 2026, the Official State Gazette (BOE) published Royal Decree-Law 18/2026, of 29 June 2026, adopting certain measures within the framework of the Comprehensive Response Plan to the Middle East Crisis. The Royal Decree-Law primarily extends, adapts and phases out temporary energy-tax measures introduced by Royal Decree-Law 7/2026. Although most of these measures relate to indirect taxation or sector-specific aid, they also affect companies, particularly as energy consumers and as operators in the transport, agriculture and livestock sectors.

The main tax and support measures affecting companies are as follows:

• Energy taxes. Reduced Hydrocarbons Tax rates: the 10% VAT rate for certain energy supplies and the 0.5% Electricity Excise Duty rate are extended or adjusted for the relevant months, subject in certain cases to CPI-based conditions.
• Diesel refunds and aid. The partial refund for professional diesel is set at zero euros from 1 July to 30 September 2026, while specific rules are established for agricultural and livestock diesel refunds and for direct aid to agricultural producers and transport operators.
• Tax on the Value of Electricity Production. Temporary reductions to the taxable base apply during 2026, followed by a gradual reduction of the tax rate in 2027 and 2028.

Royal Decree-Law 12/2026

On 27 May 2026, the Official State Gazette (BOE) published Royal Decree-Law 12/2026, of 26 May 2026, declaring various initiatives and programmes to be events of exceptional public interest for the purposes of Article 27 of Law 49/2002, of 23 December, on the tax regime of non-profit entities and tax incentives for patronage. The applicable tax benefits are the maximum benefits provided for under Article 27.3 of that Law, subject to the specific duration and conditions established for each event.

Royal Decree-Law 10/2026

On 29 April 2026, the Official State Gazette (BOE) published Royal Decree-Law 10/2026, of 28 April 2026, approving urgent tax measures and other support measures in response to damage suffered by victims of the DANA storm and other emergency situations. The Royal Decree-Law mainly addresses the tax treatment of aid and compensation paid to affected companies and businesses, and also introduces adjustments to previously approved energy-related measures. The main tax measures affecting companies are as follows:

• Corporate Income Tax. Certain aid granted by the Valencia Regional Government to companies and self-employed workers affected by the DANA storm to promote the maintenance of employment and the reactivation of economic activity is given the same tax treatment as the aid already covered by the exceptional DANA regime and is not included in the Corporate Income Tax taxable base, with effects from 29 October 2024.
• Hydrocarbons Tax. The rule on the partial refund of Hydrocarbons Tax for professional diesel is amended so that, until 30 June 2026, the refund rate is zero euros. However, if the year-on-year CPI variation for fuels in April 2026 does not exceed 15%, the refund rate for June 2026 is set at EUR 49 per 1,000 litres.
• VAT: The VAT reduction to 10% for certain energy products is adjusted. It applies, until 30 June 2026, to electricity supplied to qualifying customers, natural gas, briquettes and pellets from biomass and firewood, subject to automatic suspension in June 2026 if the relevant CPI threshold is not met.

Royal Decree-Law 7/2026

On 21 March 2026, the Official State Gazette (BOE) published Royal Decree-Law 7/2026, of 20 March 2026, approving the Comprehensive Response Plan to the Middle East Crisis. The main tax measures affecting companies are as follows:

• Corporate Income Tax. The free depreciation regime for investments in renewable electricity self-consumption facilities and renewable thermal facilities for own consumption, as well as for electric vehicles and charging infrastructure, is extended to tax periods beginning or ending in 2026, subject to the applicable investment limits and workforce maintenance requirements.
• Energy taxes. The VAT rate for certain supplies of electricity, natural gas, biomass briquettes and pellets, and firewood is temporarily reduced to 10% until 30 June 2026, subject to the relevant CPI condition. The Royal Decree-Law also temporarily reduces Hydrocarbons Tax rates and the Electricity Excise Duty rate and introduces temporary rules for the Tax on the Value of Electricity Production.
• Transfer Tax and Stamp Duty. A new exemption is introduced for transfers of energy savings within the framework of the Energy Savings Certificate System.

Royal Decree-Law 5/2026

On 19 February 2026, the Official State Gazette (BOE) published Royal Decree-Law 5/2026, of 17 February 2026, adopting urgent measures in response to damage caused by various adverse weather events, with particular impact in the Autonomous Communities of Andalusia and Extremadura. The main tax and support measures affecting companies are as follows:

• Direct aid and non-seizability. Direct aid is provided for damage to business establishments and for companies and professionals carrying out economic activities in the affected municipalities of Andalusia and Extremadura. Aid granted under the Royal Decree-Law, as well as tax refunds resulting from its tax measures, are treated as non-seizable.
• Local taxes and fees. A full property tax (IBI) exemption applies to damaged properties meeting the relevant requirements, proportional business activities tax (IAE) reductions are provided for affected businesses, and certain administrative fee exemptions are introduced in connection with the affected areas and circumstances.
• Special reductions for agricultural activities. For agricultural holdings and activities directly affected by the catastrophic events, the Minister of Finance may exceptionally authorise reductions in the net income indices applicable under the objective assessment method for Personal Income Tax and the simplified VAT regime.

Royal Decree-Law 15/2025

On 3 December 2025, the BOE published Royal Decree-Law 15/2025, of 2 December 2025, which adopts urgent measures to promote investment activity by local entities and autonomous communities and amends Royal Decree 1007/2023, of 5 December 2023, approving the Regulation setting the requirements to be adopted by IT and electronic systems supporting invoicing processes for business owners and professionals and standardising the formats of invoicing records.

The principal amendment is the postponement of the entry into force of the Verifactu system, a new standard for secure and traceable invoicing in Spain with an optional real-time transmission channel to the Spanish Tax Agency (AEAT).

As a result, the deadline for CIT payers to implement and adapt their IT systems is deferred from 1 January 2026 to 1 January 2027. In turn, the deadline for the implementation of the Verifactu system is deferred from 1 July 2026 to 1 July 2027 for all other obligated taxpayers.

Law 9/2025, of 3 December 2025, on Sustainable Mobility

On 3 December 2025, the Sustainable Mobility Act was published in the Official State Gazette. The main tax measures affecting corporate taxation include:

• The amendment of Decree 137/1960 to state that the fee for expenses and remuneration related to the management and inspection of works will not apply where such works fall within the scope of the State Road Network.
• The inclusion in the Local Tax Authorities Act (Ley Reguladora de las Haciendas Locales) of the possibility of establishing a fee for circulation within Low-Emission Zones (Zonas de Bajas Emisiones or ZBEs) applicable to vehicles that exceed the maximum thresholds or categories for free circulation set by each ZBE.
• An amendment to the Local Tax Authorities Act setting criteria for determining fees for the private or special use of the local public domain. In the case of circulation within a ZBE that exceeds free-circulation thresholds, it permits using, as a market reference value, the cost that would have been payable if, instead of circulating within the ZBE, the vehicle had been parked in a public car park.

Royal Decree-Law 8/2025

Royal Decree-Law 8/2025, which designates numerous cultural, sports, and other initiatives as events of exceptional public interest and grants them the maximum tax incentives under Article 27.3 of Law 49/2002, was approved on 8 July 2025 and published in the Official State Gazette on 9 July 2025. It also sets each programme’s duration and the certification rules for eligible expenses.