SPAIN Trends and Developments Contributed by: Raúl Salas, Elena Ferrer-Sama and Cristina Cavero, RocaJunyent
(a Royal Decree-Law) was not an adequate means for amending the CIT. In 2024, the Spanish Parliament again approved the tax loss limitations, but only for the year 2024 and following. Those limitations are applicable as follows: • to all companies regardless of size – this limit pre - vents the offsetting of CFTL in an amount exceed - ing 70% of the taxable income for the period; • only to large companies (those entities that in the previous financial year had a turnover of at least EUR20 million) – under which such companies are subject to a stricter limit of 50% of the taxable income for the period; and • a third limit for very large companies – those whose turnover in the previous financial year reached EUR60 million, whereby they could not offset more than 25% of the positive taxable income for the period with CFTL.
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