
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
Qualification Criteria
Portugal has established clear criteria for startups seeking certification. To qualify, a company (i) must have been active for less than 10 years, (ii) have fewer than 250 employees, (iii) have an annual turnover of no more than 50 million euros, (iv) cannot be the result of the transformation or spin-off of a large company and (v) cannot have a majority shareholding in a large company.
These criteria, among others, set the scene for startups seeking to qualify for the benefits of the NHR 2024.
NHR 2024 for employees and board members of startups
Tax residents in Portugal from 2024 onwards enjoy a flat rate of 20% on personal income earned in Portugal and exemption from tax on foreign income from various categories.
Other benefits
In short, the NHR 2024 is more than a tax incentive; it’s a catalyst for growth, innovation and international collaboration. By fostering a welcoming environment for startups, Portugal stands out as a beacon for those seeking not only tax advantages, but also a vibrant ecosystem to boost their entrepreneurial journey.
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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

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