Corporate Income Tax 2025: What Changes for Businesses

The 2025 Corporate Income Tax filing season introduces significant changes affecting both the taxation of companies and certain tax incentives, as well as formal aspects of the tax return. Among the most notable developments are the amendments to the capitalisation reserve, the gradual reduction of corporate income tax rates for certain entities, changes to the minimum taxation regime, the extension of specific accelerated depreciation incentives, and various technical updates to Form 200.

One of the most significant measures strengthens the capitalisation reserve, a tax incentive designed to encourage corporate self-financing through increases in shareholders’ equity.

As a general rule, the reduction applicable to the taxable base increases from 15% to 20% of the increase in shareholders’ equity generated during the financial year. Likewise, the maximum reduction limit has also been increased and now stands, in general, at 20% of the positive taxable base prior to the application of the reserve. This limit may reach 25% for entities whose net turnover during the twelve months preceding the beginning of the tax period is below €1 million.

In addition, the legislation introduces enhanced reduction percentages of 23%, 26.5% and 30% where the increase in shareholders’ equity is accompanied by an increase in the company’s average workforce, provided that such increase in employment is maintained for a minimum period of three years.

The Corporate Income Tax Act continues the gradual reduction of tax rates applicable to certain entities through a transitional regime.

For the 2025 tax year, microenterprises will be taxed at 21% on the first €50,000 of taxable income and at 22% on the remaining taxable income. Small companies (entities qualifying as empresas de reducida dimensión under Spanish tax law) will generally be subject to a 24% tax rate, unless a different specific rate applies under the applicable legislation.

The tax rates applicable to protected cooperative societies, credit cooperatives and rural savings banks have also been amended, adapting the taxation of both cooperative and non-cooperative income.

The amendments to the corporate income tax rates are also reflected in the minimum taxation regime established under Article 30 bis of the Spanish Corporate Income Tax Act.

For entities whose net turnover in the previous tax period is below €1 million, as well as for small companies, the percentage used to determine the minimum net tax liability has been adjusted to reflect the new tax rates, applying the calculation method established by law.

The possibility of applying accelerated depreciation to certain investments linked to the energy transition and electric mobility remains available during the 2025 tax year.

In particular, this incentive applies to investments in renewable energy self-consumption facilities, as well as thermal installations replacing fossil fuel-based systems with renewable energy technologies, provided that they meet the statutory requirements and become operational within the periods established by law.

Furthermore, accelerated depreciation continues to apply to certain electric vehicles and new charging infrastructure, provided that both the vehicles and the charging facilities are used in the course of an economic activity.

The 2025 filing campaign also introduces several specific amendments to the Canary Islands Economic and Tax Regime (REF) and confirms the tax exemption applicable to certain aid granted by the Valencian Regional Government (Generalitat Valenciana) to support employment and economic recovery for self-employed individuals and businesses affected by the DANA weather event.

From a procedural perspective, the Spanish Tax Agency has introduced several updates to Form 200 for the 2025 tax year.

Among the most significant changes are the adaptation of the principal business activity classification to the new National Classification of Economic Activities (CNAE-2025), amendments to the section relating to corporate groups to include new categories of entities, the update of the capitalisation reserve schedule, and various technical improvements to the completion of the tax return.

In addition, changes have been introduced regarding amended tax returns, together with specific improvements affecting Economic Interest Groupings (AIEs) and Temporary Business Associations (UTEs). New electronic filing options in XML format have also been introduced for taxpayers subject to Spain’s regional (foral) tax regimes.

Finally, it should be noted that the Spanish Tax Agency continues to provide access to Corporate Income Tax data through its electronic headquarters, together with the Sociedades WEB Open (Simulator) tool, which enables taxpayers to review the contents of their Corporate Income Tax return before filing.

The changes introduced to the 2025 Corporate Income Tax regime affect not only the completion of Form 200 but may also have a direct impact on companies’ tax liabilities and future investment planning. Properly assessing incentives such as the capitalisation reserve, accelerated depreciation and the new corporate tax rates can result in significant tax savings while reducing potential tax risks before the Spanish Tax Agency.

At ILIA ETL GLOBAL, our specialist corporate tax team advises companies of all sizes on compliance with their tax obligations, tax planning and the optimisation of their tax position, delivering tailored solutions that meet the specific needs of each business.

Article prepared by our colleague Xavier Vilalta.

To receive specialized advice on this matter, you may contact specialists at ILIA ETL GLOBAL, or alternatively reach out through our contact form.