Main changes in tax legislation introduced by various regulations in December 2023
Today, the 2024 General State Budget Law is still in the negotiation and processing phase, however, in December 2023 various tax-related regulations were approved, introducing modifications to several taxes and creating new obligations in the procedures and computer systems of businessmen and professionals.
The amendments introduced in some cases are effective in the year 2023 itself, without this implying, unlike what happened at the end of 2022, the creation of new taxes or tax levies with retroactive effect.
On this occasion, these are either pending regulatory developments on aspects modified by law previously, or extensions of special regimes or existing incentives such as those associated with investments and actions that generate energy savings, or, in some cases, such as the modifications to the so-called "Patronage Law", favourable technical modifications are incorporated which, in part, will be applicable with effect from 2023 itself.
In other cases, the amendments will take effect in 2024 or 2025.
Noteworthy for their relevance are the regulatory development that had been pending since the modification at the end of 2022 of the personal income tax impatriate regime or "Beckham regime", and the expected improvements in the regulation governing the tax regime applicable to non-profit organisations and collaboration agreements (colloquially known as the "Patronage Law").
While these are the most important changes, there are many other changes to the main taxes.
We will try to summarise the content of all of them in this Tax Alert.
Finally, we cannot fail to mention the publication on 27 December 2023 of the Preliminary Draft Bill establishing a supplementary tax to guarantee an overall minimum level of taxation for multinational groups and large domestic groups (Pillar 2).
On that date, the public information procedure was initiated and the text is currently in the phase of processing the comments received from the Tax Administration.
This is going to be a very significant modification to the Spanish tax system, affecting entities that form part of multinational and national groups with a turnover of at least 750 million euros and is expected to be transposed into our legislation within this year in accordance with the provisions of EU Directive 2022/2523.
In due course, we will provide you with the most relevant information.
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