Spain: A Tax: Barcelona Overview

Geopolitical and Domestic Economic Context Shaping the Spanish Tax Landscape

To date in 2026, the Spanish Parliament has not approved any tax measures due to the paralysis of Spanish legislative bodies. The situation may change in the coming months, in which case any new tax measures (if approved during 2026) will mostly be applied retroactively as of 1 January 2026.

The 2026 Tax and Customs Control Plan ("the Plan", published by the Spanish Tax Authorities in March 2026) reinforces the strategic use of information by improving data collection mechanisms. The Plan places strong emphasis on international taxation and cross-border transparency, thanks to the information obtained through EU Directives, Common Reporting Standards, the Foreign Account Tax Compliance Act, the Central Electronic System of Payment, country-by-country reporting (PCbCR) and Pillar Two compliance. The Plan also expands controls over platforms, payment providers, and financial institutions.

Regarding international taxation, the Plan strengthens control over withholding taxes on dividends, interest, royalties, and capital gains – particularly where treaty benefits or EU directives are claimed. Special attention is given to beneficial ownership, abusive treaty-shopping structures, incorrect applications of reduced withholding rates, and simulated changes of tax residence. Spanish Digital Service Tax will also be under special scrutiny.

Pillar Two tax forms

2026 will be the first year where Pillar Two tax forms must be submitted in Spain (affecting tax periods commenced as of 31 December 2023). Form 240 enables a group to designate either the Ultimate Parent Entity or another domestic or foreign entity to submit the GloBE Information Return (GIR) on behalf of all Spanish constituent entities. Form 241 corresponds to the GIR itself, generally to be filed within 15 months following the end of the fiscal year, or within 18 months for the transition year. Form 242 is the domestic top-up tax return, to be filed within 25 calendar days following the GIR filing deadline. This top-up tax return is an entity-level filing – ie, each Spanish constituent entity in an multinational enterprise group must file a separate return with the tax authorities. These returns must be submitted even if the Transitional CbCR Harbour conditions are met for Spain.

EU PCbCR has been implemented via the Spanish Auditing Law, targeting multinational groups that exceed EUR750 million of consolidated revenue in each of the last two consecutive financial years and if they meet the relevant EU and EEA conditions. The report requires annual public disclosure of corporate income tax-related information, presented on a country-by-country basis for EU member states and for jurisdictions included in the EU list of non-cooperative jurisdictions, while permitting aggregation for the remaining jurisdictions. Spanish implementation is very particular and unique in terms of filing deadlines. Publication is required within six months from the relevant financial year end, as opposed to the applicable regulations in other member states, for which there is an established 12-month filing deadline. This leaves little room for a purely reactive process and forces early mobilisation across finance, tax, legal, and communications teams.

The report must be filed with the Commercial Registry and must be publicly available on the group’s website for five years, which raises the bar on traceability and consistency between the figures and the narrative, and on alignment with other public disclosures, including broader tax transparency and ESG messaging. Ultimately, PCbCR in Spain is best understood as part of a wider shift towards tax transparency, where the real challenge is not only meeting the technical requirements, but also ensuring that what is made public is coherent, explainable and resilient under external scrutiny.

From a tax controversy perspective, the Spanish tax authorities continue to focus on transfer pricing adjustments. A recent Supreme Court decision on cash pooling agreements has led to transfer pricing adjustments in cash pooling interest rates by multinationals. Interest rates applicable in cash pooling schemes must be the same in credit and debit positions and must be aligned with the group credit rating, rather than to the local entity credit rating.

Invoicing

Spain is in the process of implementing a mandatory electronic invoicing system, which will significantly alter the invoicing processes for nearly all companies in Spain. It will be compulsory for all invoices to be submitted via a public e-invoicing solution managed by the Spanish tax authorities and voluntarily through private e-invoice platforms, enabling real-time monitoring of payment deadlines and invoice statuses.

The Spanish government has also introduced changes in the new invoicing software (IS), which is compulsory for taxpayers not using the electronic VAT books system (SII system). Obligation to use such IS for taxpayers has been delayed until 1 January 2027 for corporate Income taxpayers and until 1 July 2027 for other taxpayers.

Trade

The trade environment remains unstable in 2026, affecting tax and customs decisions for Spanish companies. Recent changes in US tariff policy have reduced predictability around duty levels, timing and duration, while at EU level some pending steps linked to the 2025 framework have been put on hold as institutions reassess the situation. For Spanish businesses, the challenge is less about a specific tariff and more about the difficulty of planning landed costs, pricing clauses and sourcing strategies with sufficient certainty.

This coincides with a clear increase in customs and excise scrutiny in Spain, with greater attention on customs risk areas, particularly e‑commerce flows as low‑value reliefs disappear, together with stronger surveillance, more data‑driven risk selection and closer co-operation between authorities. At the same time, the Carbon Border Adjustment Mechanism enters its definitive phase in 2026, making emissions data a standing requirement for certain imports and an operational factor in supply‑chain management.

Combined with ongoing geopolitical tensions that continue to pressure freight, fuel and insurance costs, and with tighter requirements around sanctions screening and export‑control compliance for certain goods and destinations, customs and supply‑chain configuration are becoming important risk areas within the Spanish tax and operational landscape in 2026.

Final remarks

In summary, the evolving geopolitical landscape and domestic economic conditions are significantly shaping Spain's tax framework. The introduction of new tax measures, including the implementation of electronic invoicing and the Global Minimum Tax Law, reflects the government's commitment to enhancing tax compliance. Overall, these developments present both challenges and opportunities for Spanish businesses in a complex and changing landscape.