What Spanish corporation tax is, and the rate you actually pay

What it charges and who pays it

Spanish corporation tax charges the income of companies resident in Spain. It is the corporate equivalent of personal income tax: where an individual is taxed on what they earn, a company is taxed on its profit. A self-employed person never pays it on their activity, however much they invoice, because their income goes to personal income tax and to the form 130 and form 111 they already know.

It is paid by resident legal persons, with the exception of civil-law partnerships that have no commercial object, and also by some entities with no legal personality of their own, such as investment funds, temporary business joint ventures or pension funds¹. And one thing is worth saying early, because it surprises people: the duty to file does not depend on having made money. A dormant company, or one making losses, files form 200 exactly like the one paying dividends.

The tax's official name is «Impuesto sobre Sociedades», not «Impuesto de Sociedades». The statute is Law 27/2014, del Impuesto sobre Sociedades. In practice both forms are used interchangeably and nobody is confused, but it helps to know the real name when looking the rules up.

The base is not the profit: it is the profit corrected

This is where the tax parts company with almost every other one. Article 10.3 says the taxable base is worked out by "corrigiendo, mediante la aplicación de los preceptos establecidos en esta Ley, el resultado contable determinado de acuerdo con las normas previstas en el Código de Comercio"¹.

Put another way: you start from the bottom line of the profit and loss account and add and subtract things. Articles 11 to 24 are that list of corrections, known in the trade as ajustes extracontables. Some are obvious once you think for a moment: a traffic fine is an accounting expense but is not deductible, and corporation tax itself is not deductible either. Others are technical and expensive, such as the limits on the deductibility of finance costs or the treatment of impairments.

The practical consequence is that no tool can work this tax out from your turnover, or even from your profit. It can work it out from the base before reliefs, which is your profit already corrected, and that figure comes from your accounts and your adviser. It is why the calculator on this page asks for a base rather than for revenue.

The rate you are charged is not the one in article 29.1

This is the point on which most pages about this tax are wrong today, and not through carelessness: they are quoting the statute.

Article 29.1 says the general rate is 25 per cent, that a company with under a million euros of turnover in the previous year applies a scale of 17 per cent on the first 50,000 euros of base and 20 on the rest, and that a small company pays 20 per cent¹. All of that is true and neither reduced figure is being paid yet.

Law 7/2024 of 20 December added a forty-fourth transitional provision to the Act that phases the cut over five years²:

Note the asymmetry, because it is the provision's own structure and it explains the table: paragraphs 3 and 4, the ones covering 2027 and 2028, mention only the small-company rate. The micro-company scale is left with no transitional rule from 2027, so it reaches its destination two years before the single rate does. The general 25 per cent, meanwhile, never moved.

The return filed in July 2026 was the one for 2025, on the 21 and 22 per cent scale and the 24 per cent rate. The period a company is living through as you read this is 2026, at 19 and 21 per cent and 23.

The one-million cliff

The micro-company scale and the small-company rate are not two steps of the same staircase, and there is a jump between them that almost nobody points out.

In 2026, a company that turned over 900,000 euros last year applies 19 per cent to the first 50,000 euros of base and 21 to the rest. One that turned over 1,100,000 applies 23 per cent to all of it. On a base of 200,000 euros the first pays 41,000 euros and the second 46,000.

Two hundred thousand euros more of turnover makes the profit five thousand euros dearer in tax, and it does so in the direction nobody expects: the upper band goes from 21 to 23 per cent and the cheap band disappears altogether. There is no error-de-salto correction to soften the step either, the way Spanish inheritance tax has one. If your turnover is near a million, next year's rate depends on a figure you can still move.

There is one more case that runs against intuition in the same direction. The closing paragraph of article 29.1 says the 20, 17 and 15 per cent rates "no resultarán de aplicación a aquellas entidades que tengan la consideración de entidad patrimonial"¹, and article 5.2 calls a company asset-holding where more than half of its assets are securities or are not used in an economic activity. A company set up to hold flats for letting, with no employee on a full-time contract, pays 25 per cent even if it turns over forty thousand euros and even if it was incorporated last year.

The capitalisation reserve, reformed in 2025

Article 25 offers a bargain: if you do not distribute the profit, you take part of it out of the base.

Specifically it lets you reduce the base by a percentage of the year's increase in own funds, measured as the difference between own funds at the close and at the start, in both cases excluding the result, and leaving out shareholder contributions, capital increases by set-off of debts and legal or statutory reserves¹. That percentage was 10 per cent when the relief was created, went to 15 in 2024, and since 2025 runs on a scale tied to employment²:

The middle figure is worth reading slowly: the statute says 26.5 per cent, not 26. It is a case where a repeatedly copied rounded number has travelled further than the original text.

The cap is 20 per cent of the positive base before reliefs, or 25 per cent where turnover stayed below a million during the twelve months before the period began, and what does not fit can be used in the next two periods¹. In exchange there are two obligations that are not small: keeping the increase in own funds for three years, and booking an undistributable reserve for the amount of the reduction, shown on the balance sheet under its own heading. If you also used the headcount scale, that headcount increase must be kept for three years too. Breaching either means paying back what was relieved, with late-payment interest.

One point that sometimes costs money: this is not an employment-conditional relief. With no headcount growth, or with a fall, the 20 per cent reduction still exists. Headcount only improves it.

Losses, and the ordering almost nobody respects

When a company loses money, the loss is not thrown away: it becomes a negative taxable base that is kept with no time limit and set against future profits. What is capped is how much can be set off each year.

Article 26.1 fixes that cap at 70 per cent, and the fifteenth additional provision lowers it to 50 per cent for anyone turning over at least twenty million euros and to 25 for anyone at sixty million or more¹. Beneath those percentages there is a floor that rescues almost every mid-sized company: "en todo caso, se podrán compensar en el período impositivo bases imponibles negativas hasta el importe de 1 millón de euros". Where the percentage comes out below a million, the million governs.

And now the part that decides the answer. The capitalisation reserve is applied before the loss relief, so the temptation is to take 70 per cent of what is left after the reserve. Article 26.1 says something else, literally: the cap is 70 per cent of "la base imponible previa a la aplicación de la reserva de capitalización establecida en el artículo 25 de esta Ley y a su compensación"¹. And article 25 itself measures its own cap on that same magnitude, the positive base before the reduction and before the loss relief.

The two reliefs run in sequence and are measured in parallel. Neither shrinks the other. The only thing that does bind afterwards is article 30.2, which stops the net tax from being negative: the base cannot fall below zero however much loss is still carried forward.

Two constitutional facts behind those percentages

The 50 and 25 per cent limits have a history worth knowing, because it explains the date the fifteenth additional provision carries.

Royal Decree-Law 3/2016 introduced them, and in January 2024 the Constitutional Court annulled them. Judgment 11/2024 of 18 January decided a question referred by the Audiencia Nacional and held that the fifteenth additional provision and paragraph three of the sixteenth transitional provision of the Act, as worded by article 3.1 of that decree-law, "son inconstitucionales y nulos"³. The ground was not the substance but the form: a decree-law may not touch an essential element of a tax.

Eleven months later, Law 7/2024 re-enacted those same limits, this time by ordinary statute, with effect for periods starting from 1 January 2024 that had not ended when it came into force². The consolidated text of the Act now carries both notes on the same block, one under the other: the one saying the provision was annulled, and the one saying it was added again.

It is the plusvalía municipal pattern in a different register. There it was coefficients raised by decree-law and a resolution of the Congreso that left them without effect; here it is limits imposed by decree-law and a court that annulled them. The operational lesson is identical: for any Spanish tax measure introduced by decree-law, check whether it survived, and check whether it came back.

The 15 per cent minimum tax

After the rate come the rebates and credits, which are deducted from the gross tax and give the net tax. There are many of them and some are large: double taxation, research and development, film production, job creation.

Article 30 bis puts a floor under all of it. The net tax cannot fall below 15 per cent of the taxable base, and it reaches only companies that turned over at least twenty million euros in the preceding twelve months or that file in a tax group, whatever their turnover¹. The percentage drops to 10 per cent for newly created companies and rises to 18 for banks and hydrocarbons companies.

There is a fourth paragraph, also added by Law 7/2024, that almost nobody computes. For a micro or small company caught by the article because it belongs to a consolidated group, the minimum percentage is its rate multiplied "por quince veinticincoavos, redondeado por exceso"¹. The formula checks itself: 25 times fifteen twenty-fifths is 15, which is the general percentage the same article states, and 30 times fifteen twenty-fifths is 18, which is the one it states for banks. With the 23 per cent of 2026 it gives 13.8, which rounded up is 14.

One detail the formula does not explain: the 10 per cent for newly created companies does not come from it. Fifteen twenty-fifths of 15 is 9, and the statute says 10. It is an expressly stated figure, not an arithmetic result.

When it is paid, and why 25 July is not always 25 July

The tax is settled once a year on form 200, but it is paid three times before that on form 202. Article 40 places those instalments in the first twenty days of April, October and December, and offers two ways of computing them: 18 per cent of the tax for the last period filed, or a percentage on the base for the first three, nine or eleven months of the year, compulsory for anyone turning over more than six million euros¹. That second percentage is the rate multiplied "por cinco séptimos, redondeado por defecto", so on the general 25 per cent it gives 17.

It is worth setting that rule beside the previous one. In the same statute, article 30 bis multiplies by fifteen twenty-fifths and rounds up, and article 40 multiplies by five sevenths and rounds down. Two fractions and two rounding directions, each in the direction that suits the Treasury.

The annual return has a deadline that is a calculation rather than a date. Article 124.1 grants "el plazo de los 25 días naturales siguientes a los 6 meses posteriores a la conclusión del período impositivo"¹. For a year ending 31 December that gives 1 to 25 July, and that is where the 25 July printed everywhere comes from.

In 2026 that day fell on a Saturday, so the 2025 form 200 fell due on Monday 27 July, which is exactly where the Spanish tax agency's taxpayer calendar puts it⁵. In 2027 it will fall on a Sunday and be due on Monday the 26th. And the direct-debit window moves with it under a rule that lives in a different instrument: article 3.2.b) of Order EHA/1658/2009 extends it by "el mismo número de días que resulte ampliado el plazo de presentación", and requires that "un mínimo de tres días hábiles o cinco naturales" remain between the close of the direct debit and the close of filing⁴. In 2026 that gave 22 July, which is what the agency published⁶, and both floors were met exactly at their minimum: from the 22nd to the 27th there are five calendar days and three working days.

One footnote remains that almost nobody quotes. Annex II of that same order marks form 200 with an asterisk whose text reads: "Sólo cuando el período impositivo finalice el día 31 de diciembre"⁴. A company whose year ends in June files in January and cannot direct-debit the payment at all.

The deadline, the obligation to file and the price of being late have a page of their own: when Spanish corporation tax is filed, with the form 200 calculator that computes the date from your year end and the surcharge from your filing date.

A worked example with real numbers

An ordinary company turned over 900,000 euros in 2025 and closes the 2026 period with a base before reliefs of 200,000 euros, no losses carried forward and no capitalisation reserve claimed.

Because it does not reach a million, the 2026 micro-company scale applies: the first 50,000 euros at 19 per cent is 9,500 euros, and the remaining 150,000 at 21 per cent is 31,500. The gross tax is 41,000 euros and the effective average rate 20.5 per cent. A guide applying the 17 and 20 of article 29.1 would have said 38,500 euros, two and a half thousand short of what has to be paid.

Now change the scale of the example and the second finding appears. A company that turned over 5,000,000 euros reaches the same period with a base before reliefs of 2,000,000, an increase in own funds of 1,000,000 and 3,000,000 of losses carried forward.

The capitalisation reserve takes off 20 per cent of the increase, 200,000 euros, well under its 400,000 cap. Loss relief admits 1,400,000 euros, which is 70 per cent of the 2,000,000 base before reliefs, and not 70 per cent of the 1,800,000 left after the reserve. The taxable base comes to 400,000 euros and the tax, at the 23 per cent small-company rate, to 92,000.

Computed in cascade, the relief would have been capped at 1,260,000 euros, the base would have been 540,000 and the tax 124,200. Thirty-two thousand two hundred euros of difference for reading one sentence of article 26.1 all the way through.

What this page does not cover

Three regimes are deliberately out of scope, and it is worth saying why.

Co-operatives enjoying protected tax status, because article 29.2 cuts three points off the rates of the previous paragraph "siempre que el tipo resultante no supere el 20 por ciento"¹, and on the general 25 per cent that proviso admits two readings that give different answers. The regime also separates co-operative from non-co-operative results under Law 20/1990⁷, which is the statute to read before relying on any figure for a co-operative.

Tax consolidation, because a group is taxed as a single taxpayer and its base is built with eliminations and reincorporations that no general calculator can hold. And the Impuesto Complementario that Law 7/2024 itself created to guarantee a global minimum level of taxation for multinational groups, which is not this tax but another, with its own base and its own form.

Finally, this page describes the common-territory regime. Álava, Bizkaia, Gipuzkoa and the Chartered Community of Navarre levy their own corporate income tax, with their own rates, incentives, forms and deadlines.