Spain's headline corporate income tax (CIT) rate is 25.
The headline personal income tax (PIT) rate is residents up to 47% (regional variation to 54%); non-residents 24% (19% EU/EEA).
The standard VAT/GST (or equivalent consumption tax) rate is 21. Registration thresholds, zero-rated and exempt categories, and reduced rates vary by jurisdiction - see the source link below for the full detail on this jurisdiction.
An individual is a Spanish tax resident if they spend more than 183 days in Spain during a calendar year (occasional absences count toward the total unless residency elsewhere is proven, with extra scrutiny for stays claimed in listed tax havens), or if Spain is their main base or center of economic activities or interests. Residents are taxed on worldwide income; non-residents only on Spain-source income.
Spain's CFC regime (Article 100 LIS for corporate taxpayers, Article 91 LIRPF for individuals) applies where a Spanish resident holds, directly or indirectly - alone or with connected persons (spouse, ascendants, descendants, siblings and their spouses) - more than 50% of the capital, equity, voting rights, or income rights of a foreign entity, and that entity's effective tax burden is below 75% of what the same income would bear in Spain (i.e., below roughly 18.75% given the general 25% corporate rate). Where the foreign entity lacks material human and physical resources, its entire income is attributed to the Spanish resident; where it has substance, only specific passive income categories (dividends, interest, royalties, real estate income, capital gains, and certain related-party transactions) are attributed - taxable whether or not distributed.
Spain repealed its formal debt-to-equity thin capitalization rule; interest deductibility is instead governed by a general limitation under Article 16 LIS (implementing ATAD): net financial expense is capped at 30% of tax-EBITDA, with an automatic EUR 1 million minimum deduction regardless of EBITDA. Effective January 1, 2024 (Law 13/2023), the EBITDA calculation explicitly excludes income, expenses, or amounts not included in the taxable base. Excess capacity may be carried forward five years; disallowed interest carries forward with no time limit. A separate, stricter rule denies deduction entirely for intra-group debt used to acquire participations or make contributions to other group entities, absent valid economic reasons.
Spain has more than 90 double tax treaties in force, most following the OECD Model Convention. The BEPS Multilateral Instrument (MLI) took effect for 49 of Spain's covered treaties on January 1, 2023, and for 5 further treaties on January 1, 2024. To claim treaty-reduced withholding, non-resident recipients must provide a valid tax residency certificate specifically referencing the applicable treaty - Spain's tax authority (AEAT) has been rejecting generic residency certificates on audit.