Is there a minimum corporate tax rate?

With effect for tax periods beginning on or after 1 January 2022, for taxpayers whose net turnover is at least €20 million during the 12 months prior to the start of the tax period or who are taxed under the special consolidation regime, regardless of their net turnover, the net quota may not be less than the result of applying 15 percent to the tax base, reduced or increased, where appropriate and as appropriate, by the levelling reserve, and reduced by the investment reserve regulated in article 27 of Law 19/1994, of 6 July, amending the Economic and Tax Regime of the Canary Islands. This quota will have the character of a minimum net quota.

The minimum net rate will not apply to taxpayers who pay the tax rates provided for in sections 3, 4 and 5 of article 29 of Law 27/2014 or to entities under Law 11/2009, of October 26, which regulates Listed Public Limited Companies for Investment in the Real Estate Market.

For taxpayers who pay taxes at the rate of 15 percent in accordance with the provisions of section 1 of article 29 of Law 27/2014, because they are newly created entities, the minimum net rate will be 10 percent of the taxable base.

Taxpayers who pay taxes at the rate provided for in the first paragraph of section 6 of article 29 of Law 27/2014, that is, credit institutions, as well as entities dedicated to the exploration, research and exploitation of hydrocarbon deposits and underground storage facilities in the terms established in Law 34/1998, of October 7, of the hydrocarbon sector, the minimum net rate will be 18 percent of the taxable base.

In cooperative entities, the minimum net quota may not be less than the result of applying 60 percent to the full quota calculated in accordance with the provisions of Law 20/1990, of December 19, on the Tax Regime of Cooperatives.

For entities in the Canary Islands Special Zone, the positive tax base on which the percentage is applied will not include the part thereof corresponding to operations carried out materially and effectively within the geographical area of said Zone that is taxed at the special tax rate regulated in article 43 of Law 19/1994, of July 6, amending the Economic and Fiscal Regime of the Canary Islands.