On June 4, 2024, the Spanish Council of Ministers approved a draft bill to implement the Pillar 2 global minimum tax, following Council Directive (EU) 2022/2523 from December 14, 2022. The bill includes provisions for the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR), ensuring a minimum tax rate of 15% for multinational enterprise (MNE) groups with annual consolidated revenue exceeding EUR 750 million in at least two of the last four financial years. Additionally, the bill introduces a qualified domestic minimum top-up tax (QDMTT). If approved and published in the Official Gazette, the IIR and QDMTT will apply to tax years starting on or after December 31, 2023, while the UTPR will generally apply to tax years starting on or after December 31, 2024.
