A conflict in the application of tax provisions procedure requires a prior favorable report by the consultative committee as specified in article 159 of the General Taxation Law (LGT). Any assessments issued without implementing these guarantee mechanisms must be deemed null and void.
The law includes a 15% minimum corporate income tax rate and nonresident income tax rate (for taxpayers with a permanent establishment), a €1,500 cap placed on the reduction for individual pension plans and restrictions introduced for access to the increased €10.000 reduction for employer pension plans; and, as happens every year, a new set of events of exceptional public interest is determined.
These proposals, presented on December 22, 2021, have their respective origins in the work of the OECD and G20, for the implementation of a global minimum tax rate (known as Pillar 2) and in the communication on business taxation for the 21st century (revision of the ATAD Directive to include measures to counter shell companies).