3. Corporate Tax

In 2025, 42,266 million was collected from Corporate Income Tax, an increase of 8.1% compared to the amount collected the previous year (Table 3.1). In 2025, regulatory changes took center stage, adding 3.641 billion to revenue (Table 1.5), especially due to the contents of Law 7/2024, applicable to the annual declaration of 2024, which was mostly paid in 2025, and to the installment payments of 2025. The two measures with the greatest impact on revenue were the limitation on the consolidation of losses in groups (in force in the 2025 payments, but not in those of 2024) and the recovery of the limits on the compensation of negative tax bases from previous periods for companies with a turnover of more than 20 million euros. On the other hand, it should be noted that income was negatively affected by the sharp increase in refunds from previous periods, such as those linked to refund requests for the 2023 fiscal year (with a high amount and which were completed at the beginning of 2025) and the extraordinary ones related to the ruling on the RDL 3/2016.

It is estimated that corporate profits (excluding those taxed at rates of 0% and 1%) increased by 11.3% in 2025, marking five consecutive years of high rates with an average increase of over 13%. The growth in profits declared by Large Companies and groups in their installment payments was lower, at 6.1% (5.1% in Large Companies not belonging to groups and 7.5% in the latter; Table 3.2 ).

Installment payments, the main component of the tax, increased by 8.1%, a consequence of the evolution of profits and the boost derived from regulatory changes. Of the 3.169 billion in additional revenue in 2025, 3.066 billion are due to installment payments. Withholdings on capital income contributed nearly 260 million more to revenue, far from the more than 860 million they added in 2024, thanks to the aforementioned rebound experienced then in withholdings on movable capital income and the intense increase in withholdings on investment funds. The contribution from the result of the annual declaration (of the 2024 financial year) was also positive, at almost 560 million. Revenues increased by 16.9%, partly driven by regulatory changes, although refunds also grew significantly as a large part of those requested in 2024 for the 2023 financial year were paid in 2025 (Table 3.3). On the other hand, the higher volume of extraordinary refunds and the lower income from settlements carried out by the Administration reduced the revenue by almost 770 million.

The consolidated tax base Corporate income tax grew by 11.6%, a high rate but one that represents a significant moderation compared to the 23.1% recorded in 2024, favored by the regulatory changes at that time (50% limit on the consolidation of losses in groups and the recovery of limits on the compensation of negative tax bases from previous periods). This base has shown an average increase of close to 20% over the last five years, even surpassing the already positive evolution of profits (Table 3.1 and Figure 3.1). In 2025, another all-time high was recorded in the tax base, surpassing once again the record of 2023, the year in which the previous high reached in 2006 was exceeded for the first time. Furthermore, the tax accrued is also expected to exceed, for the first time, the maximum observed then (Chart 1.25). The detailed evolution of the tax since 1995 can be analyzed with Table 8.5 .

It is expected that the effective rate The tax base will decrease slightly in 2025 (-0.3%) after growing by 1.3% in 2024 due to the effect of regulatory changes (Graph 3.5). The varying impact of regulatory changes over the past five years, during which a significant increase in the tax base has been observed, has resulted in a very moderate increase (0.4%) in the average rate for the period 2021 to 2025. It is expected that in 2025 the rate on profits, excluding companies that pay taxes at rates of 0% and 1%, will remain practically stable (-0.1%). These companies, mostly financial firms, are not included in the calculation of the rate due to the high variability of their profits, as they are linked to the valuation of their assets which, in turn, depends on changes in interest rates and the reactions of the financial markets. This fact has a significant impact on the variation of profits and, therefore, on the variation of the rate (Graph 3.2), but it hardly affects the tax given its low or non-existent taxation.

It is expected that the Corporate Income Tax accrued It will increase by 11.2% in 2025 (7.9% without differential fee), thanks to the 7.7% increase in installment payments and the expected good performance of the annual declaration result. In consolidated groups, the increase in payments was 7.5%, with greater growth in those associated with the tax base (8.7%) than in those derived from the minimum payment (6.3%). The existence of regulatory measures (the limitation to 50% of losses in the consolidation of companies belonging to the group) explains why the advance of these payments was greater than the increase in profits (estimated at 5.1%). The peculiarity of this year was the irregular trajectory in the three payments, with high growth in the first, an adjustment in the second due to the moderation of profits in the middle part of the year and a recovery at the end of the year. In large companies not belonging to groups, payments increased by 5.4%. In these societies, the increase tends to be concentrated in payments that are determined according to the base, unlike what happens in groups where the weight of the minimum payment calculated from the benefit is very relevant. The distinct pattern can be clearly seen in Charts 3.3 and 3.4. Meanwhile, in the SMEs A rate of 14% was reached, with strong increases both in those who paid taxes according to their last annual fee (11.7%), and in companies that declared according to the profits of the year (21.1%).

The income In terms of cash they grew by 8.1% (Table 3.1), in line with the evolution of installment payments. Both withholdings on movable capital and those associated with investment funds continued to grow at a good pace (7.0% and 12.2% respectively), although at a sharp slowdown after the high levels reached a year earlier. The increase in withholdings on leases was somewhat smaller, as well as its moderation compared to 2024 (5.4% in 2025, 5.7% previously).

The net result of the annual declaration associated with the settlement of the 2024 fiscal year added almost 560 million in additional revenue to the collection, resulting from the growth of gross income (16.9%), driven both by the good performance of profits and by regulatory changes (Table 3.3). The refunds made also exceeded those paid in 2024, although it should be noted that these refunds always mix refunds from two years, those corresponding to 2024 and those of 2023, in addition to the extraordinary ones. The former decreased by 4.9% because the same regulatory changes that favored the increase in the amounts to be paid, led to a lower growth in refund requests. In contrast, the second ones, those from the 2023 fiscal year paid at the beginning of 2025, were very high because the applications for that fiscal year were also high. And to these two must be added extraordinary refunds derived from the judgment annulling the RDL 3/2016. The end result of all this was an increase in the total refunds from the annual tax return.