11.9.1.4 Quantification of tax debt

For tax periods beginning in 2019, the tax rate applicable to the tax base will be 25 percent, except for hydrocarbon research and exploitation activities, where it will be 30 percent.

Permanent establishments may apply the deductions and bonuses provided for in the Corporate Income Tax Law to the full amount, with the exception of the deduction provided for to avoid international double taxation. To the extent that they have suffered withholdings in the development of their activities, they can apply them to the quota resulting from the previous operation, as well as the payments on account and fractional payments that have been carried out.

When permanent establishments of non-resident entities (not natural persons) transfer income abroad, an additional tax of 19% will also be payable on the amounts transferred from the income of the permanent establishment, including the payments referred to in article 18.1.a) of the LIRNR , which have not been deductible expenses for the purposes of determining the tax base of the permanent establishment. However, this tax will not apply to income obtained in Spanish territory through permanent establishments of entities with their tax residence in another State of the European Union, unless it is a country or territory considered a tax haven, nor to income obtained in Spanish territory through permanent establishments by entities that have their tax residence in a State that has signed an agreement with Spain to avoid double taxation, in which nothing else is expressly established, provided that there is, in this last case, a reciprocal treatment.