Is there a minimum corporate income tax rate?
With effect for tax periods beginning on or after 1 January 2022, taxpayers whose net turnover is at least 20 million euros during the 12 months prior to the date on which the tax period begins or who pay tax under the special consolidation regime, regardless of their net turnover, the net tax liability may not be less than the result of applying 15% to the taxable base, less or increased, where applicable and as appropriate, by the equalisation reserve, and less the investment reserve regulated in Article 27 of Law 19/1994, of 6 July, amending the Canary Islands Economic and Fiscal System.This liability shall have the character of a minimum net tax liability.
The minimum net tax liability will not be applied to taxpayers who pay tax at the rates provided for in sections 3, 4 and 5 of Article 29 of Law 27/2014 or to the entities of Law 11/2009, of 26 October, governing real estate investment trusts.
Taxpayers who pay tax at the rate of 15 percent in accordance with the provisions of Section 1 of Article 29 of Law 27/2014, as newly created entities, the minimum net tax liability shall be 10 percent of the taxable base.
Taxpayers who pay tax at the rate provided for in the first paragraph of section 6 of article 29 of Law 27/2014, i.e. credit institutions, as well as entities engaged in the exploration, research and exploitation of hydrocarbon deposits and underground storage facilities under the terms established in Law 34/1998, of 7 October, on the hydrocarbon sector, the minimum net tax payable shall be 18 per cent of the taxable base.
In cooperative entities, the minimum net tax liability may not be less than the result of applying 60% to the total tax liability calculated in accordance with the provisions of Law 20/1990, of 19 December 1990, on the Tax System of Cooperatives.
For entities in the Canary Islands Special Zone, the positive tax base on which the percentage is applied shall not include that part of the base corresponding to operations materially and effectively carried out within the geographical area of the said Zone, which is taxed at the special tax rate regulated in Article 43 of Law 19/1994, of 6 July, amending the Canary Islands economic and tax system.