Foral Corporate Tax in Spain

Who this applies to

For 2026, the agreements use the EUR 12 million preceding-period operations threshold. Annualise operations for a short period and use estimated first-year operations until actual figures are known. Operations means VAT-exclusive consideration for business supplies, excluding the equivalence surcharge; it is not automatically accounting turnover or assets. At or below EUR 12 million, the ordinary single company pays the administration of its fiscal domicile. Above it, collection follows the current year's territorial operations, with the percentage rounded to two decimals. Calculate one company's taxable income under the selected governing law, then allocate its liability. Do not apply each territory's headline rate separately to its sales. CE arts.14–18; CN arts.18–23., Navarra Economic Agreement

For a Basque-domiciled company, Basque law governs unless preceding operations exceed EUR 12 million and at least 75% took place in common territory. A common-territory company above EUR 12 million uses Basque law if at least 75% of preceding operations took place in the Basque Country; a common-domiciled fiscal-group member needs 100% there. Select the province under that province's art.2: domicile normally controls; if all Basque operations occurred outside the domicile province, use the sole operating province or the province with the larger share of the other two; a common-territory company coming into Basque law uses the province with the largest Basque operations share. Record all three provincial percentages, the common-territory percentage and preceding/current years separately. CE art.14; B/A/G art.2., Bizkaia NF11/2013, Álava NF37/2013, Gipuzkoa NF2/2014

For Navarra, exclusive Navarra collection entails Navarra law. A company paying both Navarra and the State uses domicile law, except a Navarra-domiciled company with at least 75% preceding operations in common territory uses common law; a common-domiciled company with at least 75% in Navarra uses Navarra law, with the art.18 fiscal-group exception. Keep a case involving both Navarra and one or more Basque provinces for a specific agreement analysis rather than treating Navarra as a fourth Basque province. CN arts.18–19.

Build the operations ledger from the statutory connecting factors: goods generally where made available or where dispatch starts; transformed goods at the final transformation; industrial installations use the preparation/manufacturing place if installation cost does not exceed 15%; electricity at generating plants; immovable supplies and related services where the property is; ordinary services where performed from. Agriculture/fishing products, transport and leasing transport equipment have domicile rules; allocate foreign operations proportionately to the remaining operations. Customer address alone does not supply this analysis. CE art.16; CN arts.20–21., Navarra Economic Agreement

Advance payments use the last return's allocation, subject to the agreement's change-notification routes; deduct the instalment actually paid to each administration from its share. File with every administration entitled to collection. The governing law determines the instalment method even where another administration collects part of it. A State-law company allocating tax to a foral treasury must therefore retain State instalment calculations. CE arts.17–18; CN arts.22–24., Navarra Economic Agreement

Rates, bands and thresholds

Item	2026 rule	Primary law
Basque ordinary micro/small	20% if all size/activity tests pass	B/A/G art.56, Álava NF37/2013, Gipuzkoa NF2/2014
Basque general	24%	B/A/G art.56, Álava NF37/2013, Gipuzkoa NF2/2014
Navarra ordinary rates	28% general, conditional25%;23% small/19% micro	N art.51
Connecting threshold	12million preceding-period operations; law and collection are separate	CE arts.14–18;CN arts.18–23, Navarra Economic Agreement

The base

Parts of this computation held in separate Guides

These parts were moved unchanged on 6 November 2026 so that each Guide stays within the size the site can deliver. Use them at the credit and quota steps below.

• es-foral-corporate-tax-credits: investment, research and employment credits, and the ordinary social, commuting and environmental credits. The credit sequence and limits stay here.
• es-foral-corporate-tax-extraordinary-profit-surcharge: the 2026–2030 Basque extraordinary-profit surcharge, including the Álava own-law net-result worksheet.

Size and economic-activity tests

Test	Bizkaia, Álava and Gipuzkoa	Navarra
Micro	Economic operation; assets or operations at most EUR 2m; average staff below 10; ownership condition below	Small company with prior net turnover at most EUR 1m, subject to group/ownership aggregation
Small	Economic operation; assets or operations at most EUR 10m; average staff below 50	Economic activity; prior net turnover below EUR 20m; ownership condition below
Medium	Economic operation; assets at most EUR 43m or operations at most EUR 50m; average staff below 250	No corresponding general medium rate band in art.51
Ownership	Direct/indirect holding of 25% or more by an entity failing either the relevant quantitative asset-or-operations condition or the workforce condition disqualifies, subject to the statutory venture-capital exception. Article 13.5 imports only letters b/c for the shareholder; it does not require that shareholder to satisfy the taxpayer company's own economic-operation test	A holding of more than 25% by entities failing the relevant turnover condition disqualifies, subject to public/venture-capital exceptions
Period	Prior period; startup/restarting inactive company uses current period. Annualise operations, not assets or staff. FTE average, with part time proportionate. Group totals with consolidation eliminations	Prior period; annualise short period. New company's first actual activity period; aggregate Code-of-Commerce groups and the statutory family-control case, and add acquired business/branch turnover where required

Sources: B/A/G art.13; N art.12, Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016. These conditions are cumulative apart from the expressly alternative asset/operations test. Navarra AIEs and UTEs cannot obtain small status. Navarra's 19%/23% trading rates also require current net turnover at least 50% of current taxable income and exclude patrimonial companies. An EUR 800,000-turnover company is not automatically a 19% company if it has a large investment gain. N arts.12,51.1.b.

For the Basque ownership test, apply the shareholder's relevant quantitative size and workforce conditions under article 13.5, while testing the taxpayer company's own economic operation separately under article 13.1–4. An ordinary trading company that meets all its own micro conditions is not disqualified merely because a 25% corporate shareholder is passive, if that shareholder satisfies the relevant quantitative tests and no separate group rule changes the figures. For example, with the shareholder's assets 1.5 million, operations below 2 million and zero employees, its passive activity alone does not deny micro status to the otherwise qualifying company. A 25% shareholder with both assets and operations above 2 million, or average staff reaching 10, fails the relevant micro quantitative test. Do not remove the taxpayer company's own 85%-business-income or other statutory conditions. Sources: the current article 13.5 of each Basque law linked above.

For the Basque 85%-business-income condition, trace qualifying revenue and the local passive-income exclusions and look-through participation conditions. The property-business threshold differs: Bizkaia art.13.4 requires an average of at least three exclusive full-time unrelated employees; Álava art.13.4 requires five, with permitted related-entity staff aggregation; Gipuzkoa art.13.4 and DA 10 refer to its PIT art.24.3, which requires at least one exclusive full-time employee and excludes the specified related people. Do not import one province's employment threshold into another. B/A/G art.13.4; G DA 10; Gipuzkoa PIT NF 3/2014 art.24.3., Álava NF37/2013, Gipuzkoa NF2/2014

Before granting trading-company methods, test patrimonial status under B/A/G art.14 and N art.8.2. The Basque rules include the asset mix, the 90-day period, the 75%-ownership composition, exceptions for qualifying participation/business reinvestment and the treatment of inactive companies. The Basque patrimonial computation uses art.32's restricted expenses and the art.56.2 progressive savings scale; it is not the ordinary 20% or 24% computation. Navarra patrimonial entities lose the art.51.1.b reduced rates. The dedicated patrimonial calculation and restructuring/group regimes remain separate branches.

Taxable-base reconciliation

Start with the accounting result, add back local non-deductible expenses, reverse exempt income and timing differences, replace accounting depreciation with allowed tax depreciation, and apply local special deductions, reserves and eligible carried losses in their statutory order. Navarra art.42 puts the art.43 loss reduction before the art.44 investment-reserve reduction. Preserve a tax-basis register for each asset and a year-by-year register of deferred amounts. This sequence comes from B/A/G arts.15–55 and N arts.14–46; a State-law adjustment cannot be assumed to exist under a foral law.

Recurring item	Basque ordinary method	Navarra ordinary method
Corporate tax, penalties, distributions	Add back income-tax expense, fines/sanctions and the specified surcharges, distributions of own funds, gifts except statutory business-purpose exceptions, bribery and specified unlawful/cash-restricted expenses	Apply art.23's own exclusions and limits; interest on tax arrears is expressly included in deductible financing under art.24 subject to its ceiling
Client hospitality/travel	Deduct 50% of qualifying public-relations restaurant/hotel/travel costs, capped together at 5% of operations; business gifts up to EUR 300 per recipient/year with recipient evidence	Apply art.23.2's 50% qualifying expense deduction capped at 1% of net turnover, plus the EUR 300-per-recipient gift rule. This differs from the Basque 5%-operations ceiling
Ordinary passenger vehicle	Apply the local art.31.3 split and annual lease/depreciation, running-cost and financing caps; do not infer full business deduction from VAT treatment	Apply art.23.3–4, with vehicle/person and partial-year rules; retained source has the full method
Net financing costs	Generally limited to 30% of operating profit, with EUR 3 m annual allowance (prorated short period), own statutory adjustments to operating profit, indefinite expense carry and five-year unused capacity	30% operating profit with EUR 1m annual allowance (prorated), 15-year disallowed-expense carry and five-year unused capacity
Dividend/participation income	Arts.33–35: determine exemption conditions locally; ordinary participation at least 5%, or 3% listed, one-year holding; subject/non-exempt payer, qualifying business-income condition and exclusions including nominal tax below 10%, deductible distributions and patrimonial payer/recipient. If full art.33.1 exemption fails for Spanish-resident payer dividends, apply art.33.2's 50%-integration fallback, subject to art.33.3; see the separate method below	Arts.35–36 require their own 5%/one-year test and foreign-tax conditions. The 5% management-expense reduction in art.35must be considered; this is not the Basque full qualifying-income exclusion

Sources: B/A/G arts.25 bis,31–35; N arts.23–24,35–36, Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016. The Basque financing rules exclude, among others, qualifying standalone companies with no related entities/foreign PE, credit/insurance entities and final extinction outside restructuring, and contain group-equity and acquisition-debt rules. Navarra's exemption list differs. Apply the acquisition-debt additional 30% ceiling before deciding the final allowed cost; its escape requires at most 70% acquisition debt and scheduled reduction towards 30% over eight years. Document both general and acquisition ceilings. B/A/G art.25 bis; N art.24., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016

Basque domestic-dividend fallback

In Bizkaia, Álava and Gipuzkoa, failing the full article 33.1 participation-exemption conditions does not automatically make a dividend fully taxable. For dividends from a Spanish-resident payer, article 33.2 ordinarily integrates 50% of the dividend into the recipient's tax base; Gipuzkoa expressly includes direct or indirect receipts. Dividends from the specifically named general-insurance mutuals, social-provision entities, mutual-guarantee companies or associations instead have zero integration under that paragraph. This domestic fallback is not a 50% rule for foreign dividends and is not Navarra's separate method. Sources: B/A/G article 33.2, in the current corporate laws linked above.

Apply article 33.3 before either the full exemption or the domestic fallback. Its exclusions include a distribution deductible to the payer or an equivalent benefit, payer nominal taxation below 10%, dividends from profits generated during the payer's patrimonial periods, a patrimonial recipient, and the specified deductible pass-through under a securities contract (with the actual recipient's own statutory conditions). Bizkaia/Álava also have article 33.3(f)'s three-year restriction after the specified tax-neutral contribution by an individual/non-PE non-resident who lacked dividend double-tax relief; test its stated reinvestment, onward-distribution or disposal exceptions. Do not import that extra paragraph into Gipuzkoa's article 33.3. Retain the distribution's profit/reserve origin and make the required article 33.6 return disclosure.

For example, an ordinary non-patrimonial company receives EUR 10,000 on a 1% holding in an unlisted Spanish trading company, taxed at a nominal rate of at least 10%. Assume no deductible distribution, pass-through or other article 33.3 exclusion. The 1% holding fails the ordinary 5% full-exemption threshold, but article 33.2 integrates only 10,000 × 50% = EUR 5,000. If the full dividend is in accounting profit, the reconciliation deducts EUR 5,000. At the ordinary 24% rate the resulting incremental gross quota is EUR 1,200 before other adjustments, credits and minimum tax; integrating the full dividend would give EUR 2,400, and full exemption would give zero. If an article 33.3 exclusion applies, the 50% fallback does not cure it.

Ordinary receivable impairment

For an ordinary nonfinancial company, start with a genuine receivable impairment booked in the accounts; overdue status alone does not create an additional expense. Test the selected territory's timing and exclusions before leaving that expense in the tax base. Sources: B/A/G article 22 and article 54.3/6; N article 20.1 and article 15.5/6, in the current corporate laws linked above.

Territory	Ordinary individual-debtor test	Separate timing extension
Bizkaia	By the last permissible date for formulating annual accounts, either six months have elapsed from contractual maturity, the debtor is declared bankrupt, the debtor or its company administrator/representative is prosecuted for concealment of assets, or collection is subject to the specified judicial claim, litigation or arbitration	Article 22.1 uses the accounts-formulation deadline; do not replace it with tax-year end or import Álava's additional extension
Álava	The same four alternatives, tested at the last permissible accounts-formulation date	Bankruptcy or the specified judicial/litigation/arbitration circumstance also qualifies when it arises before the return-filing window begins; this extension does not move the six-month age test to that later date
Gipuzkoa	The same four alternatives, normally tested at tax accrual	Bankruptcy or the specified judicial/litigation/arbitration circumstance also qualifies when it arises before the return-filing window begins; the six-month age test remains at tax accrual
Navarra	The same four alternatives, tested at tax accrual, under article 20.1.1º	Do not import a Basque accounts-formulation or pre-return-window extension

The Basque article 22.2 exclusions cover public-body debts/guarantees, bank or mutual-guarantee cover, real security/title-retention/retention rights, credit insurance and expressly renewed or extended debts, with the stated exception for arbitration or litigation over the debt's existence or amount and the stated lost/impaired-security exception. Related-party impairments require judicially declared insolvency. Navarra article 20.1.2º has its own exclusions: public-body debts, public/bank/mutual guarantees and credit insurance (to the covered amount), real security except lost/impaired security, and express renewal/extension; apply its specified judicial/arbitral exception rather than assuming that six months overrides a guarantee. Its related-party exception requires bankruptcy and judicial opening of liquidation, not merely a bankruptcy declaration. Retain evidence of maturity, court events, guarantees and relationships for each balance. Special regulated financial entities follow the separate statutory route.

Basque article 22.3 permits a separate global impairment for qualifying article 13 micro, small and medium companies, limited to 1% of eligible closing debtor balances. Remove balances already individually impaired under article 22.1 and those whose impairments are excluded by article 22.2(a)/(b). The closing allowance balance, not a fresh annual addition on top of the old balance, cannot exceed that ceiling. On leaving the eligible size category, later impairments are non-deductible up to the existing global-allowance balance, as article 22.3 provides. Navarra article 20.1.2º(g) excludes global customer/debtor risk estimates; there is no ordinary Basque-style 1% election in that provision.

For example, a calendar-2026 company books an impairment of EUR 10,000 on an unrelated, unsecured receivable due 31 August 2026, with no bankruptcy, prosecution or collection proceedings. Assume its applicable latest accounts-formulation date is 31 March 2027. Six months have elapsed by that date, so the ordinary individual age test is satisfied in Bizkaia/Álava, subject to the other conditions. At 31 December 2026 only four months have elapsed: Gipuzkoa/Navarra require a EUR 10,000 add-back for 2026 on these facts. A later qualifying year requires a tracked reversal of that add-back, not a second book expense.

For an eligible Basque SME with EUR 500,000 closing debtors, EUR 100,000 already individually impaired and EUR 50,000 excluded secured/related balances, the global ceiling is (500,000 - 100,000 - 50,000) × 1% = EUR 3,500. If EUR 2,000 of global allowance is already outstanding, the available increase is EUR 1,500, subject to the booked amount; it is not another EUR 3,500. Keep a tax register of individually deducted amounts, disallowed balances and the separate global allowance. Tax-deducted impairment recoveries enter the reversal year's tax base under B/A/G article 54.6 or N article 15.6; reconcile previously disallowed amounts so that the same expense or recovery is not counted twice.

Basque ordinary disposal monetary correction

Basque disposal monetary correction (art.40.9). For positive income on disposal of tangible fixed assets, intangible fixed assets or investment property, including those assets subsequently classified as non-current assets held for sale, calculate the monetary-depreciation deduction before integrating the disposal income into the tax base. Ordinary property held as trading inventory does not enter this asset population. Use the selected province's CIT, not PIT, coefficient table for tax periods beginning during2026 in the separate2026 PE/CIT table. Start from the last authorised legal revaluation, or acquisition if later; the following ordinary calculation assumes no previous legal revaluation.

1. Calculate the disposal income under the ordinary accounting-to-tax reconciliation, retaining any separate tax-depreciation reversals or other fiscal adjustments. If that disposal income is zero or negative, art.40.9 gives no monetary-depreciation deduction.
2. Multiply acquisition/production cost by its year coefficient, each improvement by the coefficient for its own year, and each year's accounted depreciation by that year's coefficient. Let indexed_net = indexed_costs − indexed_accumulated_depreciation.
3. Calculate monetary_depreciation = indexed_net − unindexed_carrying_value_of_the_disposed_asset. The statute subtracts the asset's carrying value here. The indexed net amount is an intermediate calculation, not a new general tax basis replacing the depreciation/fiscal reconciliation.
4. Deduct the resulting positive monetary depreciation, capped at the positive disposal income. The correction cannot create or increase a disposal loss. Continue the existing corporate base, loss, rate, minimum-tax and credit sequence on the resulting income. Apply a special statutory vehicle limitation only where that vehicle provision actually governs.

Example, applicable to the identical2026 coefficients in all three provinces: an ordinary investment building acquired2023 for100,000, first brought into use2024, has accounted and tax-deducted depreciation3,000 in2024 and3,000 in2025; dispose at the opening of2026 for net proceeds150,000, with no2026 depreciation, prior revaluation or other fiscal adjustment. Carrying value is94,000 and pre-correction income56,000. Indexed cost is100,000×1.071=107,100; indexed depreciation is3,000×1.040+3,000×1.020=6,180; indexed net is100,920. Monetary correction is100,920−94,000=6,920; corrected taxable disposal income is49,080. If the otherwise identical transaction has positive disposal income only5,000, deduct5,000 and integrate zero. If it produces a loss, deduct zero under40.9.

Authorities: Bizkaia NF11/2013 art.40.9, Álava NF37/2013 art.40.9, Gipuzkoa NF2/2014 art.40.9. Coefficient timing: B DF115/2025 art.2, A DF41/2025 art.2, G DF27/2025 DA2.

Passenger-vehicle expense computation

For an ordinary non-exclusively-business car, use the actual eligible expense first and then the statutory ceiling. In Bizkaia/Álava the usual lease/depreciation deduction is the least of 50% actual expense, EUR 3,000 and 50% of the taxpayer's depreciation rate times EUR 30,000 (the last comparator applies where depreciated); use EUR 4,000/EUR 40,000 for the named BEV/REEV/FCV/FCHV electric vehicles. Other running expenses are 50%, capped at EUR 3,600. Financing separately uses 50% of interest multiplied by min(1, EUR 30,000/acquisition price), or EUR 40,000 for the electric class. Proved exclusive business use or the valid benefit-in-kind election permits the 100% route: EUR 6,000/EUR 30,000 depreciation or lease comparator, EUR 7,200 other costs, and the corresponding full proportionate financing; electric comparators are EUR 8,000/EUR 40,000. Apply person/year and partial-year conditions. B/A art.31.3.a., Álava NF37/2013

Gipuzkoa art.31.3.a/b has the same 50%/100%, EUR 3,000/6,000, EUR 30,000 and electric EUR 4,000/8,000/EUR 40,000 depreciation comparators and EUR 3,600/7,200 other-cost ceilings, but its own disposal-loss/monetary-correction method. Its statute does not separately reproduce the Bizkaia/Álava proportionate-financing formula in those clauses. Preserve that difference rather than inserting it by analogy. Special-purpose goods/passenger transport, manufacturer testing, driving instruction, surveillance and genuine rental vehicles have their expressly defined deduction exceptions. Sales representatives have a separate rule and a linked-person restriction; Gipuzkoa specifically retains the art.31.3.b.a' depreciation limit for those cars. G art.31.3; B/A art.31.3.b/c., Bizkaia NF11/2013, Álava NF37/2013

Navarra art.23.3 uses 50% of eligible ordinary expenses with a depreciation/lease ceiling of 50% of the regulatory depreciation rate times EUR 25,000, and EUR 4,000 for other costs including financing. Its proved exclusive-use or benefit-in-kind route uses 100% with the depreciation-rate-times-EUR 25,000 ceiling and EUR 7,000 other-cost ceiling. The rate is the regulatory-table rate; prorate partial years and aggregate simultaneous vehicles by person. The art.23.3.e listed exclusive special activities have their own full-cost exception. The VAT deduction percentage does not decide this corporate expense. N art.23.3–4.

Depreciation and goodwill

Ordinary straight-line asset	Basque annual maximum	Navarra annual maximum / maximum period
Offices/services/commercial buildings/housing	3%	4% / 38 years
Industrial buildings	5%	5% / 30 years
Installations	20%	15% / 10 years
Industrial machinery	20%	15% / 10 years
Other machinery	15%	15% / 10 years
Furniture	15%	15% / 10 years
Computers	33.33%	25% / 6 years
Buses/trucks/vans	20%	20% / 8 years
Moulds/models/dies	33.33%	33% / 5 years
Other tangible property	10%	10% / 15 years

Sources: B/A/G art.17; NR art.3, Álava NF37/2013, Gipuzkoa NF2/2014, Navarra DF114/2017. Start when available for use; exclude land. Basque general maximum periods are 15 years, 50 for real estate and 25 for ships/aircraft, with approved special plans available. Navarra useful-life/table and timing rules are those of N art.16 and NR arts.2–8. Track additions, disposals, days in use and any separate improvement cost.

Basque micro/small companies can freely depreciate qualifying new tangible assets excluding buildings and specified passenger vehicles; unit-cost assets at most EUR 1,500 have a separate free-depreciation route. Medium companies can multiply the normal maximum by 1.5 for qualifying new assets. Microcompanies can elect a 25%-of-opening-net-tax-value pool over the eligible asset population, replacing accounting depreciation/impairment and retaining the election while micro status continues; that pooling excludes the art.21.1 free-depreciation methods. Bizkaia/Álava art21 provide their specified EUR20,000/EUR40,000 total-deduction limits. Gipuzkoa art21.1(g)/(h)/21.4 instead uses its own qualifying vehicle/charging and art31 restrictions; do not import the Bizkaia/Álava EUR20,000 total cap into that separate route. Navarra small companies use 1.5 times the normal maximum for qualifying new tangible assets and new investment property, with the construction/delivery conditions in art.16.7. Its separate free-depreciation cases include tangible assets of unit cost at most EUR 1,800 and exclusive permanent R&D assets/capitalised R&D, plus the conditional early-year labour-company and priority-agricultural cases; art.18.4 excludes combining its free depreciation with other tax incentives except art.61 R&D credit. B/A/G art.21; N arts.16–18., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016

For finite-life intangibles, use useful life; if unreliable, the ordinary local annual maximum is one tenth. Basque goodwill is not accounting amortisation automatically: art.25 gives its own one-eighth acquisition-price ceiling and acquisition/group conditions. Navarra art.17 allows goodwill up to one tenth annually. Keep the tax deduction and later disposal basis separately. B/A/G arts.20,25; N art.17., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016

2026 temporary depreciation and payroll-related overlay

The separately enacted emergency measures in B26 art.4, A26 art.4 and G26 art.4 permit 1.5 times the normal maximum depreciation for qualifying new tangible assets acquired in 2026, excluding buildings and the specified restricted transport assets. This ordinary-company measure is additional to the eligibility routes already present in art.21; it does not mean multiplying an already accelerated rate by another 1.5. Apply the new statutory coefficient from commissioning, with the local contract/construction and delivery-within-twelve-months provisions. Maintain that chosen tax-basis schedule through the asset's eligible life. The same separate instruments change 2026 hiring credits as set out below. January consolidations alone therefore omit a material 2026 overlay. B26 arts.4–5; A26 arts.2,4; G26 arts.4–5., Álava DNUF2/2026, Gipuzkoa DF-Norma2/2026

All three emergency instruments also remove the business-income Q 1 2026 instalment obligation, with valid voluntary payments expressly not refundable as undue payments. That relief concerns PIT, not corporate-tax instalments. B26 art.3; A26 art.3; G26 art.3., Álava DNUF2/2026, Gipuzkoa DF-Norma2/2026

Micro deduction and reserves

The three Basque laws allow an eligible microcompany to deduct 15% of its positive pre-deduction ordinary base under art.32.4; remove the specified CFC/special imputations from its calculation and apply the exact local ordering, with Álava/Gipuzkoa expressly using the pre-loss base. This option is incompatible with the arts.51–53 result-application corrections. Thus an ordinary eligible EUR 100,000 pre-option base becomes EUR 85,000 before losses, rather than applying a blanket 15% tax discount after credits. B/A/G art.32.4., Álava NF37/2013, Gipuzkoa NF2/2014

The alternative capitalisation correction is 15% of the increase in fiscal equity, increased to 20% for micro/small companies; maintain the fiscal equity and a reserve equal to the qualifying increase for five years, except the capitalised portion and loss exception. Each province's art.51.2 exclusions define fiscal equity differently, including contributions and exempt/foreign/nonbusiness assets. Do not use the raw balance-sheet increase. The correction cannot create/increase a tax loss; insufficient-base amounts carry with the local five-year maintenance commencement. B/A/G art.51., Álava NF37/2013, Gipuzkoa NF2/2014

The Basque equalisation reserve normally allows a deduction bounded by 10% of freely distributable accounting profit, 15% of the specified taxable base and a reserve balance of 25% of fiscal equity. Eligible micro/small companies add five percentage points to each of those three limits (15%,20%,30%). Match amounts against losses over ten years. The expiry uplift is 20% in Bizkaia and 30% in Álava/Gipuzkoa on the unused amount. Earlier unlawful reserve disposal has a different 5%-per-year clawback. Record origin years individually. B/A/G art.52., Álava NF37/2013, Gipuzkoa NF2/2014

The Basque productive/business reserve in art.53 provides a separate local reserve/materialisation method. Álava's current rates are a 65%-of-dotations reduction capped at 45% of taxable base and a 50%-of-fiscal-equity reserve balance, with the three-year investment categories, double-investment requirement for new art.61 assets and prior approval for the specified participation route. Bizkaia also uses 65%/45%/50%; Gipuzkoa uses 60%/45%/50% with its expressly pre-corrections/pre-loss base ceiling. The local business-angel route has its own eligibility and EUR 100,000-per-project ceiling; participation investments ordinarily require five-year retention, and the specified industrial-project participation route requires prior administrative approval. The three-year materialisation failure reverses the corresponding reduction with its separate 15% uplift; unlawful disposal has the separate 5%-per-year rule. Do not combine the micro 15% option with these reserves or claim a credit on the same investment used to materialise an incompatible reserve. A art.53; B/G arts.32.4,53,67.6., Bizkaia NF11/2013, Gipuzkoa NF2/2014

Navarra's special investment reserve reduces positive base by 45% of the qualifying allocation, or 60% for microcompanies, subject to 40% of the base after the specified art.42 reductions. Minimum allocation EUR 50,000. Maintain the equity increase and reserve, materialise in qualifying new tangible assets/investment property excluding land, normally from the preceding year through two years after the profit year's close, and retain the investment and reserve under art.46. DLF 1/2026 extends reinvestment deadlines ending in 2026 by one year and reserve-materialisation deadlines ending in 2026–27 to 31 December 2027. Keep the original deadline and statutory extension in the computation. N arts.44–46; N26 sole article., Navarra DLF1/2026

Losses

Basque losses carry for 30 subsequent concluding periods. Outside the micro/small exception the normal utilisation ceiling is 50% of the positive pre-loss base. Current micro/small ordinary companies can use 100%; Álava excludes fiscal-consolidation cases from that exception. No State EUR 1m minimum is stated in these rules. Startups may begin the 30-year count at their first positive period. Apply debt-waiver/extinction and loss-trafficking rules, and the local patrimonial restrictions. Bizkaia additionally states the specified 90%-impairment-reversal exception. B/A/G art.55., Álava NF37/2013, Gipuzkoa NF2/2014

An elected Basque block of five consecutive periods allows use up to 100% in the first four, but cumulatively only 50% of positive bases over the block. In year five, restore any excess plus 15% of that excess to taxable base. Elect in the first return, do not overlap blocks and align the block with an elected credit-limit block. This is a timing election with a year-five liability, not permanent full loss relief. B/A/G art.55.1., Álava NF37/2013, Gipuzkoa NF2/2014

Navarra losses carry 15 years; normal utilisation is at most 70% of positive base after the specified art.42 reductions, but at least EUR 1m is usable, prorated for a short year and always bounded by available base and losses. New companies have no percentage ceiling in their first three positive periods and count the carry period from the first positive period. Apply the debt-waiver/extinction exceptions and anti-trafficking tests in art.43; they differ from the Basque six-month inactive-company test. N art.43.

Rate, minimum and credit sequence

Ordinary trading company	Bizkaia	Álava	Gipuzkoa	Navarra
Micro/small passing all tests	20%	20%	20%	19% micro / 23% small
General	24%	24%	24%	28%; optional 25% only with all art.51.1.a conditions
Credit/qualifying bank group	28%	28%	28%	Apply art.51's applicable category

Sources: B/A/G art.56; N art.51, Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016. Navarra's new 25% election requires year-end employee headcount at least the average of the previous three year ends, no economic-cause ERTE suspension/reduction during the year, no final serious/very-serious occupational-safety sanction during the year and compliance with the equality-plan/registration obligation at accrual. It is not a universal 2026 rate cut. Special co-op, labour-company, nonprofit, investment and pension-fund rates require their own statutory category.

Basque ordinary calculation

1. Compute the positive taxable base after chosen corrections and usable losses; apply the art.56 rate. Deal separately with any 2026–30 extraordinary-profit surcharge below.
2. Subtract art.60 foreign double-tax credits, limited under the local country/source calculation. Carry insufficient amounts for the local 30-year period, keeping treaty limits and taxes actually borne. Under B/A/G art.60.7, excess foreign tax over the attributable-quota limit is not a deductible expense; Navarra's separate art.56.2 conditional business-expense treatment cannot be imported here. The resulting QL (cuota líquida) is never negative. Álava art.58 and Bizkaia/Gipuzkoa art.58 have different additional cross-references for port/temporary-reversal deductions.
3. Split chapter-III credits by local art.67 bucket. Use prior-year credits before current-year credits within each bucket. Ordinary bucket: at most 35% of QL. R&D/innovation bucket: at most 70% of the remaining QL after the ordinary bucket. Environmental/culture bucket: at most 50% of the remaining QL after both previous buckets. These are sequential remaining-quota limits, not 35%+70%+50% of the original quota. Exact article mapping below.
4. Apply art.59's local minimum to credits subject to it. The minimum restricts the reduction caused by those credits; it does not automatically replace a quota already below that level because of a prior-stage double-tax credit. Credits expressly excepted from the minimum remain subject to their own art.67 bucket. Keep minimum-exempt and minimum-subject credits distinct when allocating claims and carries.
5. Effective tax cannot be negative. Deduct withholding, payments on account and instalments actually paid. Excess advance payments are refundable, rather than converting unused investment credits into a cash refund. Apply territorial allocation and the final return obligations. B/A/G arts.57–68,127–130 bis., Álava NF37/2013, Gipuzkoa NF2/2014

Art.67 credit bucket	Bizkaia	Álava	Gipuzkoa
70% of residual quota	arts.62–64 bis	arts.62–64 bis	arts.62–64 bis
50% of residual quota	arts.65,65 bis,66 quater,66 quinquies	arts.65,65 bis,66 ter,66 quater	arts.65,65 bis,66 bis
35% ordinary	Other chapter-III credits	Other chapter-III credits	Other chapter-III credits, subject to any express credit-specific rule
Express art.59minimum exceptions	arts.62–64,64 bis,65,65 bis,66 quater,66 quinquies	arts.62–64,64 bis,65,65 bis,66 ter,66 quater	arts.62–64,64 bis,65,65 bis,66 bis

The article numbers are deliberately province-specific. Gipuzkoa's separate culture-financing art.66 ter has its own conditions and cannot silently be put into another province's article bucket. Unused chapter-III credits carry for 30 years; asset retention, subsidised base, accounting, no-double-use and recovery conditions in art.67 still apply. B/A/G arts.59,67., Álava NF37/2013, Gipuzkoa NF2/2014

Minimum restricting ordinary credits	Bizkaia	Álava	Gipuzkoa
General 24% company, no qualifying staff/investment condition	19% base	19% base	19% base
General company with maintained average indefinite staff or qualifying arts.61–65 investment	17% base	17% base	17% base
General company with maintained staff and investment, or increased average indefinite staff	15% base	15% base	15% base
Micro/small default	15% base	15% base	15% base
Micro/small with employees and maintained/increased average indefinite staff	13% base	15% base	13% base

Sources: B/A/G art.59, Álava NF37/2013, Gipuzkoa NF2/2014. Additional bank/partially-exempt/hydrocarbon minima are in art.59. Do not describe this as the Pillar Two 15% top-up tax: the precise complementary-tax exception is province-specific. Bizkaia art.59.6 refers to preceding paragraphs3–5 and Álava art.59.5 to paragraphs3–4; Gipuzkoa art.59.6 literally refers to the preceding two paragraphs4–5. Do not silently extend the Gipuzkoa wording to paragraph3 without a supported interpretation. Keep a large-group case for the corresponding local and complementary-tax analysis. A five-year art.67 credit-block election recomputes the corresponding local minimum across that block and adds any year-five shortfall plus 5%; the election does not extinguish the floor.

For Bizkaia and Gipuzkoa, regulation article 33 bis expressly separates the article 59.4 investment test from full entitlement to the corresponding articles 61–65 credit. Making an investment of a type described in those articles can satisfy the investment limb even where the conditions required to claim that credit are not fulfilled. Test the investment and workforce limbs independently, and calculate any generated credit separately. For example, assume an ordinary 24% company with no staff-maintenance/increase limb, positive base EUR 100,000, and EUR 5,000 of new business machinery of an article 61 asset type. If preceding net qualifying assets are EUR 100,000 and there are no other investments, EUR 5,000 fails the over-10%-or-over-EUR-5m article 61.3(d) credit threshold, so this investment generates no article 61 credit. It can nevertheless establish the article 59.4 investment limb under B/G regulation article 33 bis: the applicable ordinary-credit floor is EUR 17,000 rather than EUR 19,000. With a separately eligible EUR 6,000 ordinary-bucket credit, gross quota EUR 24,000 and bucket capacity EUR 8,400, a EUR 6,000 claim leaves EUR 18,000 and satisfies the 17% floor. This illustration creates no credit on the EUR 5,000 investment. An enacted Álava equivalent to the broader B/G33bis deeming rule has not been established; the narrow own-statutory amount-threshold method below does not assume one. Sources: B/G article 59.4, article 61.3(d), and BR/GR article 33 bis in the laws/regulations linked in Sources.

Álava: the ordinary amount-threshold investment case

Source-derived interpretation, limited to the amount gate. Álava article 59.4 tests whether an actual investment is capable of generating an article 61–65 credit, separately from calculating and using that credit. For an ordinary company taxed at the general 24% rate, an otherwise qualifying new business machine meets that investment limb where the only failed credit-generation condition is article 61.3(d)'s aggregate amount threshold. This is the identified interpretation of Álava's own potential-investment wording and article 61.1/3, not a B/G article 33 bis transplant or an express enacted Álava deeming rule. Its own article 53.2 and operative regulation article 32 bis expressly require actual-credit eligibility and all conditions for the separate productive reserve; that different test is not imported into article 59.4. Do not extend this amount-only method to a private, nonbusiness, used, land, unproved or otherwise unsuitable asset. Own NF 37/2013 articles 53/59/61, own DF 41/2014 article 32 bis.

Assume taxable base EUR 100,000, unadjusted liquid quota EUR 24,000, current indefinite staff 1 against prior 2, no staff increase, no complementary-tax exclusion, no surcharge or other quota adjustment, no minimum-exempt credit and no five-period block election. A new business machine costing EUR 5,000 meets the other article 61 asset conditions. Relevant prior net assets of EUR 100,000 and no other investment make it fail the strictly-over-10%-or-over-EUR-5m credit threshold. Generated article 61 credit is zero. Under the stated source-derived investment interpretation, the floor is EUR 17,000 instead of EUR 19,000. A separately entitled, unexpired EUR 6,000 ordinary-bucket credit fits the EUR 8,400 article 67 capacity and leaves EUR 18,000; without the investment limb only EUR 5,000 could be used and EUR 1,000 would carry. With a separately entitled EUR 8,000 credit, use EUR 7,000 and carry EUR 1,000. The machine itself creates no EUR 500 credit. With no separate credit, quota remains EUR 24,000: 17% is a credit-use floor, not the ordinary tax rate or a cash refund. Actual credit-origin, expiry, asset/workforce and retention evidence remain necessary. Own articles 59/61/67.

The current 19% default for 2026–2035 follows NF 21/2025 article 3.Quinto, despite its separate permanent 17% amendment; NF 3/2025 article 12.Cuatro/DF1 supplies article 59.4's 2026 effect. Álava's July 2026 draft 45/2026 proposes a broader article 33 bis clarification, but enactment has not been established. The amount-only method above does not rely on that draft having legal effect and does not settle other failed-credit-condition populations, excluded taxpayers or block elections.

Navarra ordinary calculation and 2026 hard floors

Apply the correct rate to BL, the base after reductions/losses, to obtain gross quota. Subtract eligible bonuses and international double-tax credits under arts.54–57. Let Z = BL − bonuses/rate. Art.53's starting minimum is 18%*Z for a general-rate company (including the conditional 25%), 16%*Z for small/qualifying art.51.2 entities, or 13%*Z for microcompanies. Let F be international double-tax credits actually used; let B=film/financing credits actually used + u×R&D/innovation credits actually used, where u=0.5 for general and u=1 for art51.1(b)/51.2. Set p=18%/16%/13% and H=13%/11%/10% for general/small-or-art51.2/micro respectively. If B=0, compute minimum=max(0,p×Z−F): art53.2.4's restriction on reductions3(b)/(c) does not top up a foreign-credit-only case. If B>0, compute minimum=max(0,H×Z,p×Z−F−B). Only credits actually claimed enter B, not unused generated balances. Candidate claims must leave actual effective quota at least that minimum and satisfy art67's separate order/bucket constraints.

For a general company with Z100,000 and foreign credit10,000 alone, the computed minimum is8,000, not13,000. With foreign6,000 and film5,000, the minimum is13,000 and effective quota is28,000−6,000−5,000=17,000. With foreign16,000, liquid quota12,000 is already below13,000: leave film/R&D credits unclaimed if no positive claim can satisfy the result floor, preserving the foreign credit. This is the direct conditional application of art53.2.3(a) versus3(b)/(c) and ordinal4, not an asserted official worked ruling or a universal top-up of foreign relief (Navarra art53, art67).

Apply arts.58,64.B and 66 credits under their combined 25%-of-liquid-quota ceiling (art.58 before activity has its exception), prior carry before current year. Follow with the unlimited credits in art.67.5's statutory order, while respecting the art.53 minimum and the film/R&D amounts used in its computation. Keep a reconciliation of generated credit, claimed credit, expired credit and 15-year carry. Finally deduct withholdings and instalments; refund an advance-payment excess. Do not copy the Basque 35%/70%/50% buckets or 30-year carry. N arts.52–53,67–70.

Deadlines and filing

Basque ordinary non-micro/non-small taxpayers pay one instalment in the first 25 calendar days of October for the period in progress on 1 October:5% of the taxable base in the last return whose deadline expired by 1 October, less withholdings/payments on that period's income. Annualise a shorter reference period. Micro/small companies and the specified 1%/0% entities are excluded; Gipuzkoa also excludes the statutory venture-capital entities. Álava explicitly addresses larger patrimonial/partially-exempt entities and AIE/UTE nonresident-share bases. Retain statutory nonbusiness-day/approved-form rules when scheduling the actual due date. B/A/G art.130 bis., Álava NF37/2013, Gipuzkoa NF2/2014

Navarra's October instalment is due in the first 20 calendar days. Default: 30% multiplied by (effective quota minus withholdings/payments on account) of the last closed period whose return deadline has expired at the first day of that window. A short reference period is topped up proportionately with preceding periods to 12 months. Alternatively elect 20% of the first nine months' taxable base, less that nine-month period's withholdings; a non-calendar company uses the nine months preceding 30 September. Exercise the option expressly through the approved form within the payment window. Limited Nueva Empresa companies have the stated first-two-concluded-period exception; any amount-based exclusion needs the ministerial order. N art.68.

Bizkaia OF 298/2026 now governs web filing for periods starting from 1 January 2025, through the provincial electronic application. A requested draft must be checked, completed and confirmed; its availability is not a filing. Match the version and period in that application and retain its filing receipt. This is a fetched current procedure, whereas operational 2027 changes remain to be checked. BF.

Basque art.126 annual filing is normally within 25 calendar days after six months from year end, subject to the local model-availability provision; pay with the return under art.127. Navarra's art.75 window starts on day 1 of the fifth month after year end and ends on day 25 of the seventh month; it is not only a 25-day July window. A calendar 2026 company therefore has a statutory Navarra window 1 May–25 July 2027, subject to the actual filing-model/nonbusiness-day rules. Check the year-specific local 200/220 and advance-payment models before stating operational 2027 dates as final. B/A/G arts.126–127; N arts.75–76., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016

Penalties and interest

Use the procedure law of the administration assessing the liability. Voluntary correction before a qualifying prior request, an underpayment offence and enforced collection are separate events. Interest uses the applicable period's statutory rate and actual accrual days; do not transplant the common-territory monthly surcharge into a foral return.

Administration	Voluntary late correction and collection	Underpayment offence before conditional reductions	Primary law
Bizkaia	Art. 27's declaration-based assessment surcharge is 5% of assessed payable quota, or 0.5% if the declaration is filed within the next three working days. It preserves the art. 203 exception. Under art. 26.7, late self-assessments accrue interest from the original deadline except when both voluntary filing and payment occur within six months. Art. 28 collection is 5%, reduced to 0.5% for full effective payment in the first three working days of the executive period; 20% applies after the notified enforcement order's extraordinary payment term expires. The two collection surcharges are incompatible.	Art. 196:100–250% of unpaid tax for a culpable self-assessment underpayment; qualifying voluntary regularisation is excluded. Art. 203 ordinary late-return offence:400, with separate census/information amounts and narrowly specified no-request reductions. Do not halve the ordinary400 by borrowing the State rule.	NF 2/2005 arts. 26–28/196/203
Álava	Art. 27:5% within six months without interest; months7–12:5% plus interest from after the sixth month; beyond12months:10% plus interest from after the twelfth month. These voluntary routes exclude sanctions on their conditions. Art. 28 collection stages:5% before enforcement-order notification,10% where debt plus reduced surcharge are paid by its statutory term,20% otherwise.	Art. 195:50–150% without concealment,100–150% with concealment; actually withheld/on-account/repercuted amounts instead75–150%/125–150%. Concealment's debt incidence must exceed10%. The specified later wrong-period regularisation has a separate30% rule.	NF 6/2005 arts. 26–28/195
Gipuzkoa	Art. 27:2% within three months;5% from the fourth through twelfth month;10% after twelve months. Unlike Álava, these exclude sanctions but retain interest from the original deadline. Art. 28 collection:5% before enforcement-order notification; reduced5% where debt plus surcharge are paid within its term;20% otherwise.	Art. 195:50–150% without concealment,80–150% with concealment; actually withheld/on-account/repercuted amounts75–150%/105–150%. Concealment's debt incidence must exceed10%.	NF 2/2005 arts. 26–28/195
Navarra	Art. 52.3:1% within the following month;5% after the first month but before three months have elapsed;10% after three but before twelve;15% beyond twelve plus interest after that twelfth month until payment. The earlier routes exclude interest and sanctions. Identify expressly one tax/return period and include only that period. Unpaid filing can also attract the executive-period collection surcharge. An improper refund has its own amount and clock from receipt.	Arts. 76–77:ordinary serious offences75–180% of the relevant unpaid/unduly obtained amount; actually withheld/on-account/repercuted nonpayment90–200%. The specified later wrong-period regularisation has a separate55% rule. Apply art. 71's graduation and agreement/payment conditions before any reduction.	LF 13/2000 arts. 50/52/68–77

For Álava/Gipuzkoa, filing an unpaid late self-assessment without the prescribed contemporaneous deferral, instalment or compensation request does not prevent executive collection costs. For all four, preserve notice dates, the exact declaration/self-assessment route, payment evidence, correction period and any reduction conditions. Incorrect refunds, false invoices, information omissions and failure to provide an assessment declaration have their own offences. A percentage range is not an automatic assessment: establish culpability, statutory base, classification and applicable reductions under the cited law.

Cross-border points

For B/A/G, art.42 and for Navarra, arts.28–29 require market value even if documentation is exempt. Map 25%-or-greater shareholder relationships, group control, administrators(and exclusion for the functions-as-administrator remuneration), third-degree family and indirect/common-control links; the Basque list additionally expressly includes registered partners and specified PE/cooperative relationships. Document what is supplied, who performs the functions, assets/risks, terms, markets and business strategy. Choose the most reliable supported comparable uncontrolled price, cost-plus, resale-margin, profit-split or transactional-net-margin method, or another generally accepted technique when those cannot apply. Adjust material comparability differences and reconcile the chosen tested-party data to the accounts. Related-party invoicing alone proves neither market value nor deductibility. B/A/G art.42; N arts.28–29; NR art.18., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016, Navarra DF114/2017

Documentation test	Bizkaia,Álava, Gipuzkoa	Navarra
Small aggregate exemption	Micro/small: aggregate related transactions≤EUR 250,000 and≤20% operations; medium:≤EUR 400,000 and≤15% operations	No equivalent Basque aggregate percentage exemption in N art.30
Same-counterparty exemption	Ordinarily≤EUR 500,000 market value, subject to art.43.5.g exceptions for the named SME service/financing/rental route, objective-estimation linked businesses, business/unlisted-share transfers, real estate and intangibles	≤EUR 250,000 aggregate market-value consideration with the same related person/entity under N art.30.3.d
Simplification	Local art.43/regulatory simplified file for eligible micro/small/individual cases; group-master-file duty depends on local size rules	Turnover below EUR 45m: short file under NR art.31.4; N art.12 entities can use prescribed normalised form without comparables; full/special-operation exceptions remain
Normal file	Group structure/business/value chain, functions/risks, intangibles, financing, tax positions and consolidated accounts; local-file counterparty/transactions, comparability, method, allocations and financial reconciliation	NR arts.30–31 master/local detail, including comparables, financials, agreements and valuation-method assumptions

Sources: B/A/G art.43; N art.30; BR/AR/GR related-party chapters; NR arts.18–19,29–32, Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016, Bizkaia DF203/2013, Álava DF41/2014, Gipuzkoa DF17/2015, Navarra DF114/2017. The Basque safe-threshold documentation routes for qualifying SME remuneration, financing and property rent have separate floor, prior-year comparison and regulatory conditions. For example, the remuneration floor is the maximum of EUR 36,000(EUR 60,000 medium), the comparable employee's pay and prior-two-year average; it requires actual monetary remuneration and proportionate part-time treatment. Financing uses the specified official one-year Euribor plus 2 points(or 5 if the related borrower is an individual), compares the prior two-year effective rate and resets after five years; property-rent valuation differs by local land-value system. These are documentation routes, not automatic substitution of an interest rate or salary for a proper arm's-length result. The detailed local declarations/evidence requirements must be met before claiming them. B/A/G art.43.6–9 and corresponding regulations., Álava NF37/2013, Gipuzkoa NF2/2014

Navarra's separately fetched OF84/2018 art.2 requires model232 for same-counterparty related transactions over EUR250,000, specified operations over EUR100,000 per specified category, or same-nature/same-valuation-method transactions exceeding50% of turnover regardless of the counterparty total, subject to the statutory group/AIE/UTE/public-offer exceptions. Related-party intangible-income relief and the named noncooperative-country operations/holdings have separate reporting triggers regardless of amount. File electronically in the month after ten months have elapsed from period end; for a calendar-year period this is November of the following year. This information-return test is separate from preparing and retaining the valuation file. [Navarra OF84/2018 arts.1–6, https://www.lexnavarra.navarra.es/detalle.asp?r=50181.]

Álava's fetched 2026 official calendar confirms its local232 is also electronic in the month after ten months following period end; country-by-country231 is due within twelve months after period end. The calendar confirms deadlines and routes; the separate OF381/2018 art.2 filing triggers and their aggregation method are supplied in the provincial model232 section below. [Álava 2026 filing calendar p.15, https://web.araba.eus/documents/d/araba/b_plazos-de-presentacion_2026_es-pdf.]

Keep the documentation available by the return-deadline endpoint prescribed by each local law/regulation, refresh only changed facts when a prior valid file remains applicable, and retain transaction/valuation evidence even after an exemption. The documentation exemption does not extinguish local information-return requirements. Check the applicable province's current related-party information model and timing separately; do not copy State model 232 by analogy. Country-by-country reporting has the local EUR 750m group-revenue threshold and parent/substitute/reporting-country conditions; the notification and return are separate from the ordinary file. B/A/G art.43; N art.30; NR documentation chapter., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016, Navarra DF114/2017

Provincial model232: information duty is separate from the valuation file

The three Basque model232 triggers differ from common-territory and Navarra triggers. The reporting population is the locally governed corporate taxpayer, local PE and specified foreign attribution entity with local presence. The ordinary information threshold is strictly over36,000 of market value excluding IVA, but aggregation differs:

Competent law	Ordinary aggregation test	Primary provisions
Bizkaia	Aggregate related transactions with the same related person/entity; the art.2 trigger does not impose Álava/Gipuzkoa's same-type/same-method restriction	OF1047/2018 art.2, OF387/2023 current annex amendment
Álava	Aggregate with the same person/entity of the same type and valued using the same method	OF381/2018 art.2
Gipuzkoa	Aggregate with the same person/entity of the same type and valued using the same method	OF444/2018 art.2, current official FAQs

The ordinary boxes exclude the specified same-tax-consolidation-group, qualifying AIE/UTE/member/group and public securities-offer operations; Gipuzkoa also expressly names the qualifying credit-entity institutional-protection-system operations. Related-intangible-income relief and the named noncooperative-jurisdiction operations/holdings have separate boxes irrespective of amount, with their own conditions. The ordinary36,000 threshold does not suppress those separate disclosures. Bizkaia's2023 amendment changes the annex/noncooperative-jurisdiction terminology; it does not rewrite the original art.2 aggregation rule. Retain the actual current filing year's annex/accepted code list.

Report income and payment operations separately; do not net them against one another. Group report rows by counterparty, transaction type and valuation method, preserving the territory's trigger-aggregation distinction. Use accounting accrual for income/expense transactions, and actual transaction date for non-income/expense transactions. A qualifying transaction extending across years is disclosed in its originating year under the orders' specific rule; continued services are tested using each year's value. Do not treat a bank settlement date as the accrual date or repeat the entire original non-recurring transaction each year without testing that rule.

All three orders require electronic filing in the month after ten months have elapsed from period end: an ordinary31December2026 close produces November2027, subject to the competent administration's operational calendar. Bizkaia OF1047 arts.3–7 prescribe its authorised electronic/representation route; Álava OF381 art.5 prescribes its tax-model application/electronic headquarters; Gipuzkoa OF444 art.5 prescribes ZergaBidea. Preserve the submitted information return and acceptance receipt separately from the corporate tax return and market-value documentation. A printable model or an exempt documentation file is not proof that this information duty was discharged.

Boundary control: exactly36,000 does not cross the ordinary trigger;36,000.01 does. If one counterparty has20,000 of services plus20,000 of a genuinely different rental type, Bizkaia's ordinary aggregate is40,000. In Álava/Gipuzkoa, two separate type/method groups of20,000 each do not individually cross36,000, assuming no separate compulsory box or other transaction changes that result. Actual classification and market value remain essential.

Two worked examples that recompute

Example 1: Basque microcompany, ordinary credit and default minimum

Assume a qualified ordinary trading microcompany, pre-option base100,000, no foreign credit, eligible6,000 ordinary-bucket investment credit and no staff-maintenance minimum reduction. Elect the15% micro-base deduction rather than incompatible reserves. The20% rate produces17,000. The ordinary35% bucket allows5,950, but the15%-of-base minimum limits this credit to4,250. Actual advance payments10,000 leave2,750 payable and1,750 credit carry. This example assumes no extraordinary-profit surcharge, which excludes this20% ordinary category.

name: Basque2026 micro base and minimum restricted credit
inputs:
  initial_base: 100000
  micro_deduction_rate: 0.15
  tax_rate: 0.20
  credit_generated: 6000
  credit_bucket_rate: 0.35
  minimum_rate: 0.15
  advances: 10000
steps:
  taxable_base: initial_base * (1 - micro_deduction_rate)
  gross_quota: taxable_base * tax_rate
  bucket_limit: gross_quota * credit_bucket_rate
  minimum_quota: taxable_base * minimum_rate
  credit_claimed: min(credit_generated, bucket_limit, max(0, gross_quota - minimum_quota))
  credit_carried: credit_generated - credit_claimed
  effective_tax: gross_quota - credit_claimed
  payable: effective_tax - advances
expected:
  taxable_base: 85000
  gross_quota: 17000
  bucket_limit: 5950
  minimum_quota: 12750
  credit_claimed: 4250
  credit_carried: 1750
  effective_tax: 12750
  payable: 2750

Example 2: Navarra microcompany, ordinary credit and default October instalment

Assume all Navarra micro/activity/turnover tests are met, base100,000,19% rate, no bonuses/foreign/film/R&D credits, eligible8,000 ordinary credit within art.67's25% bucket and current-year advances10,000. The ordinary13% minimum is13,000; the25%-quota bucket4,750 binds before that floor. The separate default October instalment on a last eligible period's effective quota20,000 less2,000 withholding is30%×18,000=5,400. It is not an additional current effective-tax deduction until actually paid and attributable to that period.

name: Navarra2026 micro ordinary credit and reference period instalment
inputs:
  taxable_base: 100000
  tax_rate: 0.19
  credit_generated: 8000
  bucket_rate: 0.25
  minimum_rate: 0.13
  advances: 10000
  reference_effective_quota: 20000
  reference_withholding: 2000
steps:
  gross_quota: taxable_base * tax_rate
  bucket_limit: gross_quota * bucket_rate
  minimum_quota: taxable_base * minimum_rate
  credit_claimed: min(credit_generated, bucket_limit, max(0, gross_quota - minimum_quota))
  credit_carried: credit_generated - credit_claimed
  effective_tax: gross_quota - credit_claimed
  payable: effective_tax - advances
  october_instalment: (reference_effective_quota - reference_withholding) * 0.30
expected:
  gross_quota: 19000
  bucket_limit: 4750
  minimum_quota: 13000
  credit_claimed: 4750
  credit_carried: 3250
  effective_tax: 14250
  payable: 4250
  october_instalment: 5400

Ask the client first

1. What fiscal domicile, prior/current operations and provincial shares select law and collectors?
2. What activity, assets, staff, ownership and group totals establish actual company size?
3. What accounts, tax-basis schedules, financing, losses and reserve elections reconcile the base?
4. What investment/project/worker evidence, grants and carry registers establish each credit and minimum?
5. What foreign taxes, related transactions, prior returns, advances and notices need separate treatment?

Sources

Official source	Provisions read	Read on
Bizkaia NF11/2013	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Álava NF37/2013	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Gipuzkoa NF2/2014	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Navarra LF26/2016	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Bizkaia DF203/2013	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Álava DF41/2014	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Gipuzkoa DF17/2015	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Navarra DF114/2017	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Basque Economic Agreement	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Navarra Economic Agreement	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Navarra DLF1/2026	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Bizkaia DFN1/2026	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Álava DNUF2/2026	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Gipuzkoa DF-Norma2/2026	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Bizkaia OF298/2026	Current provisions cited above; separate2026 amendments read alongside consolidations	2026-10-27
Bizkaia NF2/2005 arts26–28/196/203	Operative procedure/filing provision cited above	2026-10-27
Álava NF6/2005 arts26–28/195	Operative procedure/filing provision cited above	2026-10-27
Gipuzkoa NF2/2005 arts26–28/195	Operative procedure/filing provision cited above	2026-10-27
Navarra LF13/2000 arts50/52/68–77	Operative procedure/filing provision cited above	2026-10-27
Navarra OF84/2018	Operative procedure/filing provision cited above	2026-10-27
Álava2026 filing calendar	Operative procedure/filing provision cited above	2026-10-27
Bizkaia OF1047/2018	Operative procedure/filing provision cited above	2026-10-27
Bizkaia OF387/2023	Operative procedure/filing provision cited above	2026-10-27
Álava OF381/2018	Operative procedure/filing provision cited above	2026-10-27
Gipuzkoa OF444/2018	Operative procedure/filing provision cited above	2026-10-27
Bizkaia DF115/2025 art.2	2026monetary-correction coefficients used through the linked complete table	2026-10-27
Álava DF41/2025 art.2	2026monetary-correction coefficients used through the linked complete table	2026-10-27
Gipuzkoa DF27/2025 DA2	2026monetary-correction coefficients used through the linked complete table	2026-10-27
B current art. 13.5, A current art. 13.5, G current art. 13.5	Quantitative-only conditions imported for the 25%-or-greater corporate-shareholder test, separate from the taxpayer's own activity gate	2026-10-28
B/A/G arts.22,54; N arts.15,20, in the current corporate laws linked above	Ordinary receivable impairment: territory-specific test dates, exclusions, Basque 1% closing allowance and reversal register	2026-10-28
B/A/G art.33.2–3/5–6, in the current corporate laws linked above	Domestic-dividend 50% integration, named zero-integration payers and territory-specific exclusion gates	2026-10-28

Official source	Scope read	Read on
BR/GR art.33 bis; B/G arts.59.4,61.3(d), in the current sources below	Express B/G regulatory investment limb is separate from full credit entitlement; own narrow Álava amount-only method and unestablished broader-rule limit are identified separately	2026-10-28
Álava NF37/2013 arts.53/59/61/67, DF41/2014 art.32bis, NF3/2025 art.12.Cuatro/DF1, NF21/2025 art.3.Quinto	Actual selected operative provisions/effect chain; own source-derived amount-threshold investment interpretation, not enacted33bis or a blanket waiver of all credit conditions	2026-10-28
CN art.24; B/A/G art.60.7, in the current sources below	Correct advance-payment connecting-factor citation and explicit prohibition on deducting excess Basque foreign tax as an expense	2026-10-28
Own Álava NF37/2013 articles 15/31/56–57, NFGT article 11, PGC NRV 13.4 / P&L, NF17/2025 DF1, NF21/2025 article 3.Cuarto, OF380/2026 model 2025	Fresh selected own operative/accounting/amendment reads support the labelled net-result/current-tax attribution worksheet; no special measurement regulation or 2026 software ruling claimed	2026-10-28

Not yet confirmed: Gipuzkoa complementary-tax exception's precise paragraph scope for a large-group case; operational2027 forms beyond the supplied statutory windows and confirmed provincial232 triggers. Specialist culture/financing, IP nexus, reinvestment, patrimonial entities, fiscal groups, co-ops and restructuring require their own complete methods before use. These ordinary limits are not specialist exclusions; art.13 medium companies remain statutorily excluded. The extraordinary-profit surcharge items are on the Not yet confirmed line of es-foral-corporate-tax-extraordinary-profit-surcharge. No accountant attestation is claimed.