Spain: corporate tax guide

What the tax system covers

Resident companies are within Spanish corporation tax on worldwide income. A foreign legal form does not establish nonresidence where the actual management is in Spain; permanent establishments and withholding are separate connections.

When a company becomes tax resident

A company is resident where it is formed under Spanish law, has its registered office in Spain, or has its place of effective management in Spain. Effective management concerns direction and control of the overall activity. The statutory presumption for some entities in noncooperative jurisdictions requires separate review. Fiscal domicile is an administrative location and should not be confused with the substantive residence tests.

Rates and the tax base

25% general rate. In 2026 qualifying microbusinesses under EUR1 million turnover can use 19% on the first EUR50,000 of base and 21% above; qualifying reduced-size entities have a 23% rate. Eligibility and exclusions matter; regional foral systems are separate.

Outbound dividends, interest and royalties

Dividends: 19%. Domestic nonresident rate, before treaty relief or applicable domestic/EU exemptions. This is separate from the Spanish company’s tax on its profits and from the recipient’s residence-country tax.

Interest: 19%. Domestic nonresident rate, before treaty relief or applicable domestic/EU exemptions. This is separate from the Spanish company’s tax on its profits and from the recipient’s residence-country tax.

Royalties: 24%; 19% eligible EU/EEA residents. General nonresident royalty rate is 24%; the AEAT guide specifies 19% for EU, Iceland, Norway and Liechtenstein residents. Domestic directive exemptions and treaty limitations require their own conditions.

Foreign companies and retained profits require review

A company can be Spanish resident through Spanish incorporation, its registered office or effective management in Spain. A founder making the central business decisions from a Spanish home may therefore create a corporate problem even where invoices and accounts remain overseas. A permanent establishment is another possible connection and should not be reduced to the same test as company residence.

Spain’s international fiscal-transparency rules can attribute specified low-tax foreign-entity income before it is distributed. Personal Article 91 and corporate Article 100 are separate provisions. Control, related holdings, the level of comparable foreign tax, the entity’s activity and statutory exceptions require a documented review. Leaving earnings in an overseas company is not itself a solution. The special impatriate framework also needs its own treatment; do not mechanically apply an ordinary-resident calculation to an elected taxpayer.

Retained Spanish assets and companies still need compliance

Nonresident ownership of Spanish property can produce continuing income and wealth-tax obligations. Review rental income, disposals, relevant deemed income and the wealth or solidarity-tax scope with the applicable deductions and treaty position. A statement that the individual is no longer resident does not mean all Spanish filings stop.

If the owner continues directing a Spanish or foreign company, document where management now occurs and whether a Spanish office, staff or other business presence remains. Close or amend payroll and registrations only when the underlying activity supports the change. Tell banks the accurate new tax residence and retain prior election and filing evidence. A citizenship application depending on continuous Spanish residence also needs a separate immigration review before a prolonged absence.

Foreign companies and income attribution

International fiscal transparency can attribute specified foreign income to individuals as well as companies, subject to control, low-tax and other conditions.

Departure, migration and continuing obligations

Individuals can face unrealised share-gain taxation after 10 of 15 tax periods and above statutory share-value/ownership thresholds. Corporate exit rules are separate.