
Pillar Two in Spain: key points on the new Top-up Tax for large groups
The transposition in Spain of Council Directive (EU) 2022/2523 of 15 December 2022, on ensuring a global minimum level of taxation for multinational enterprise groups
The recent approval of Royal Decree-Law 15/2025 has reconfigured the fiscal digitalization timeline, granting a necessary additional margin for the technical transition of billing software.
The new horizon is established as follows:
This postponement makes 2026 the critical period for companies to audit their current systems and ensure their programs guarantee the integrity, preservation, and inalterability of the records required by the regulation.
In the real estate sector, the processing of the Law for the Impulse and Balanced Development of the Region (Ley LIDER) in the Community of Madrid stands out. This regulation is born with the ambitious goal of replacing the current Land Law to unify scattered regulations and offer a framework of total legal certainty to developers and investors.
Ley LIDER introduces planning instruments aimed at drastically reducing administrative approval times, facilitating agility in land management and urban regeneration—key factors for the region’s competitiveness.
One of the most disruptive proposals from the European Union is the creation of a unique corporate framework known as the “28th Regime”. This proposal seeks to eliminate barriers between the 27 national corporate regimes through the creation of the Unified European Company or Societas Europaea Unificata (S.EU).
While its definitive scope (including possible fiscal and labor measures) is still under debate, its implementation—expected starting in 2026-2027—will represent a fundamental advance for startups and emerging companies seeking agile cross-border expansion without bureaucratic friction.
A significant update to Foreign Direct Investment (FDI) controls is expected.

The transposition in Spain of Council Directive (EU) 2022/2523 of 15 December 2022, on ensuring a global minimum level of taxation for multinational enterprise groups

In many commercial negotiations, M&A transactions or due diligence processes, the non-disclosure agreement (or NDA) is signed as a preliminary formality. However, its effectiveness depends

When a foreign company wants to operate on a stable basis in Spain, one of the first decisions is choosing the appropriate structure: incorporating a
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