Foral Corporate Tax Credits in Spain

This Guide holds part of es-foral-corporate-tax, moved here unchanged on 6 November 2026 so that each Guide stays within the size the site can deliver. Built from the law; not yet approved by an accountant.

Who this applies to

An ordinary trading company taxed under Bizkaia, Álava, Gipuzkoa or Navarra corporate tax law under the tests in es-foral-corporate-tax. Compute the base, the nominal rate, the minimum taxation and the credit sequence there first; the rows below generate credits that sequence then limits.

Rates, bands and thresholds

Investment, research and employment

Determine eligibility before applying the quota limits above. For every claim retain invoices, asset commissioning dates, project/worker certification, grants, related-party information and continued-eligibility evidence.

The Basque art.67.3 general credit base excludes interest, indirect taxes/surcharges, construction margin, tendering technical costs, dismantling/removal costs and land. Cap it at market value, require accounting recognition and ordinarily subtract the grant amount multiplied by (100% minus the company's rate). Apply express special overrides: Álava/Gipuzkoa art.65.3 environmental credits and the applicable bicycle provisions subtract grants in full. Bizkaia art.65 does not contain that environmental subsidy override, so its ordinary art.67.3 reduction is the grant multiplied by (100% minus the company's tax rate). Álava art.62.3 expressly overrides art.67 for the funded investments within its R&D base. B/G art.64 and A art.64 also exclude listed travel, training, project-documentation/management-certification, administration and overhead costs from R&D/innovation bases. Investment credits normally arise on commissioning; the long-order payment election has the one-month contract-notification requirement. Maintain eligible assets for five years, or three for movables, unless useful life is shorter, with the specified three-month replacement exception; earlier disqualification recovers the credit plus interest. Navarra chapter-III bases instead subtract grants in full under art.67.2 and use its own retention/time rules. B/A/G arts.62–64,67; N arts.58–67., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016

Credit	Bizkaia / Álava / Gipuzkoa	Navarra
New fixed business assets	Art.61:10% qualifying new assets, qualifying rehabilitated industrial premises, software and specified concession infrastructure;5% qualifying improvements/operating-lease fit-out. Account as fixed asset; ordinarily at least five-year table life except computers; vehicle eligibility restrictions; qualifying investment must exceed 10% of pre-existing net qualifying assets or EUR 5m. Industrial rehabilitation has a 25%-cost condition	Arts.58–59:10% new tangible business assets, excluding land and disallowed passenger vehicles; investment at leastEUR 6,000 and over 10% of preceding net tangible assets, reduced to 5% if investment exceedsEUR 300,000; commissioning generates credit except long-order special timing
R&D expense	Art.62:30% ordinary spend,50% excess over previous two-year average; qualifying substantial environmental-reduction projects 35%/55%. Additional 20% designated exclusive researchers/approved research-contract costs and local categories.10% exclusive R&D tangible/intangible investment excluding real estate/land	Art.61:40% qualifying R&D spend plus 10% designated exclusive qualified researcher/approved research-provider costs; linked-party purchases limited to substantiated provider cost
Technological innovation	Art.63:15% qualifying engineering/design/advanced-technology costs;20% approved research-provider projects and qualifying innovation-management certification. Advanced-technology acquisition base cappedEUR 1m and excludes related-party purchases	Art.61.3:15%, increased by 5 points for approved research-provider projects and specified certification; advanced technology acquisition base cappedEUR 1m, related-party exclusion
Job creation, ordinary indefinite hire	For indefinite hires formalised in 2026: Bizkaia art.66 as overlaid by B26 art.5:35% gross annual salary capped 60% annual SMI; the special-difficulty third-paragraph route including under 30/over 45 retains 50% gross salary capped annual SMI. Álava/Gipuzkoa art.66 as overlaid by A26 art.2/G26 art.5: EUR 7,700 per eligible hire, doubled to EUR 15,400 for prescribed special-difficulty groups	Current ordinary LF 26/2016 has no equivalent general Basque art.66 job-creation amount. Use its specific employer-pension credit and any separately eligible special incentives

Sources: B/A/G arts.61–66; B26 art.5; A26 art.2; G26 art.5; N arts.58–61,66, Álava NF37/2013, Gipuzkoa NF2/2014, Bizkaia DFN1/2026, Álava DNUF2/2026, Gipuzkoa DF-Norma2/2026, Navarra LF26/2016. Basque qualifying hire salary must exceed 170% of SMI at hiring; scale part-time relief, verify the indefinite-headcount increase and maintenance for the next three concluding periods, salary maintenance, related-entity aggregation, replacement rules and recapture. Álava additionally requires the administrator's equal-pay declaration. A replacement preserving an old claim cannot produce a duplicate credit. Use the SMI applicable at hiring, not an unsourced frozen annual amount. B/A/G art.66., Álava NF37/2013, Gipuzkoa NF2/2014

R&D is scientific/technological activity, not any software expenditure. Exclude routine maintenance, ordinary production, minor aesthetic changes, market surveys and staff training outside statutory qualifying activity. Basque non-EU/EEA work is bounded by the principal-EU/EEA activity and 25%-of-total conditions; Navarra requires eligible work in Spain/EU/EEA. Navarra applicants must submit the project and detailed budget to the competent innovation authority, request the report, and, for unsubsidised projects, file expense substantiation by the return deadline; a missing required submission loses the claim. Follow the special two-prior-period generation timing and negative-report recovery rules. Basque binding-report/financing methods require their own arts.64/64 bis and regulation workflow. B/A/G arts.62–64 bis; N art.61., Álava NF37/2013, Gipuzkoa NF2/2014, Navarra LF26/2016

Navarra's employer-pension credit is 10% of qualifying contributions imputed to employees with gross pay below EUR 27,000; for pay at/above EUR 27,000, use the contribution proportion attributable to EUR 27,000. Test art.66's RETA top-up restriction separately. It is an ordinary quota credit in the combined 25% bucket, not an increase in the corporation's nominal tax rate or a second deduction of wages. N arts.66–67.

Navarra declared-social-interest sponsorship credits are marginal 30% throughEUR 30,000,35% on the nextEUR 30,000 and 40% above EUR 60,000, with 40% on qualifying women-only sport sponsorship, recipient reporting and the gambling exclusion. Renewable-energy investment starts at 15%, with uplifts capped at 30%: ten points for zero-GHG electricity generation, ten for qualifying storage over2kWh, five for a microgrid with two renewable sources, five for shared self-consumption/energy communities; thermal hydraulic heating/hot-water connection adds five points and replacing gas with renewable hydrogen adds up to fifteen according to the qualifying use. Apply the mandatory-building-installation exclusions, special70%-of-cost mixed hot-water/heating rule and heat-pump renewable-share calculation, supported by the energy-authority report; new qualifying electric vehicles 30%, plug-in hybrids 5%, with category base capsEUR 35,000(M1/N1), EUR 5,000(L1e/L2e), EUR 10,000(L3e/L4e/L5e), EUR 15,000(L6e/L7e), EUR 150,000(N 2/N 3). Charging systems give 15%, plus five points for public access, two points for 7.4–22 kW or five points over 22 kW; the base ceilings are EUR 5,000 normal-power, EUR 25,000 high-power up to 50 kW and EUR 200,000 above 50 kW, supported by the energy-authority report. The excess over the relevant vehicle/charger base cap can qualify separately under art.58, avoiding duplicate base. The new 2026 decarbonisation credit is 15% of qualifying new tangible business investment achieving at least 30,000 kWh/year final-energy savings, less the amount received for transferring the energy savings; cap the credit at EUR 1.5m. Generation follows the resolution registering the energy-saving certificates, supported by the competent energy authority's report. Keep art.64 investments separately identified as fixed assets for five years or shorter useful life and apply the statutory leasing, retention and clawback conditions. Separate these from real-estate energy improvements and from the personal income-tax vehicle credit. N arts.63–64.

Ordinary social, commuting and environmental credits

The separate women/under-36 indefinite-hire method is B art.66 decies and A/G art.66 octies. For contracts formalised in 2026 the emergency instruments raise the salary percentage from 35% to 45%, retaining the annual-SMI credit cap. Starting pay must exceed SMI by at least 10%, and the statutory three-year follow-through must reach pay exceeding then-current SMI by at least 70%. Increase and maintain the required indefinite workforce for the next three concluding periods; apply the part-time fractions, suspension/replacement rules, related-entity anti-duplication and recapture plus interest. Gipuzkoa expressly makes this credit incompatible with art.66; B/A art.67.6 also prevents two chapter-III credits for the same expense. Do not add this to the ordinary-hire credit on the same salary. B art.66 decies; A/G art.66 octies; B26 art.5; A26 art.2; G26 art.5., Álava NF37/2013, Gipuzkoa NF2/2014, Bizkaia DFN1/2026, Álava DNUF2/2026, Gipuzkoa DF-Norma2/2026

All three provinces provide a new conciliation-plan credit: 5% of liquid quota in the introduction year capped EUR 2,500; 15% in the first year at least one third of staff use a qualifying measure capped EUR 7,500. Micro/small companies increase the two percentages by five points to 10%/20%, retaining those caps. The plan must contain new flexible-hours, continuous-day, telework, leave/reduced-hours, free childcare or commuting measures beyond legally mandatory minimums, available to every eligible worker; supply the required responsible declaration. Calculate the two separate statutory trigger years and apply the ordinary art.67 bucket/minimum. B art.66 sexies; A art.66 quinquies; G art.66 quater; their current implementing regulations., Álava NF37/2013, Gipuzkoa NF2/2014

Preferred EPSV employer contributions under collective bargaining generate 15% credit when imputed contributions are at least 1.5% but below 2.5% of annual gross pay, 20% from 2.5% to below 4%, and 25% at least 4% or for the specified under-36 employee contributions. Other eligible employment social-provision systems generate 10% where contributions reach at least 1.5% of annual gross pay or favour under-36 employees, including qualifying EU/EEA equivalents. Use the local regulatory annual-gross-pay denominator and the age-at-accrual provisions; the base is qualifying contributions actually imputed from collective bargaining. These permanent methods apply in 2026; the larger credits expressly confined to 2025 do not. B arts.66 septies/octies and DA 31–33; A arts.66 sexies/septies; G arts.66 quinquies/sexies and implementing regulations., Álava NF37/2013, Gipuzkoa NF2/2014

For tax periods beginning from 1 January 2025 through 31 December 2029, qualifying tax-imputed collective-bargaining contributions below 1.5% of the employer's annual gross pay generate a 10% credit for preferred EPSV plans or 5% for other employment systems. Apply articles 59 and 67, including the quota limits and the prohibition on claiming two chapter-III credits for the same expense. Keep the permanent under-36 treatment when applicable; do not add a transitional credit on the same contribution. A plan outside the preferred EPSV form, including an EU/EEA employment system, follows the preferred permanent bands and preferred 10% transitional route if its specifications satisfy the statutory preferred-plan requirements. Foreign location alone does not establish that equivalence. Sources: B DA 31–33, A DA 28–30 and G DA 26–28 in the current laws linked above.

For example, assume a 2026 period, an employee aged 40, an established annual-gross-pay denominator of EUR 100,000 and EUR 1,000 of qualifying imputed employer contributions. The contribution ratio is 1%, so the generated credit is EUR 100 for the preferred or qualifying preferred-equivalent route, and EUR 50 for an ordinary other employment system. At exactly EUR 1,500 of contributions, the permanent 1.5% threshold is met: preferred credit is EUR 225 and the other-system credit is EUR 150. These are generated amounts before the separate articles 59/67 usage limits; a below-1.5% contribution is not automatically a zero-credit case.

Commuter bicycles in all three provinces give 10% of qualifying fixed-asset investment: per-bike base maximum EUR 3,000 for the prescribed electric-assisted bicycle and EUR 500 otherwise; total bike base EUR 15,000 for micro/small companies, EUR 20,000 otherwise. Deduct grants in full and record these assets separately. Bizkaia/Gipuzkoa also include parking installations at 10%, base capped EUR 10,000. Álava's art.61 bis covers bicycles and its separate art.61 ter charging-point credit is 15%, plus five points for public access, plus two points for 7.4–22 kW or five for over 22–under 50 kW; the access and applicable power uplift can cumulate. Charging base is capped EUR 5,000 normal/EUR 25,000 high-power per point and total annual credit EUR 10,000. Observe the technical commissioning rules. B art.66 nonies; A arts.61 bis/61 ter; G art.66 septies., Álava NF37/2013, Gipuzkoa NF2/2014

The environmental art.65 credit in each province is 35% for qualifying new renewable/hydrogen/renewable-fuel generation, consumption, distribution, clean-technology-list equipment, carbon capture for the named permitted destinations, and material recycling/circularity investments. The separate 15% branch covers approved contaminated-soil work and the named applied projects (energy recovery where material recovery is unavailable, voluntary ecosystem regeneration beyond compulsory measures, water saving/treatment, best/emerging techniques and eligible sustainable transport). Match the project to a statutory category, obtain the specified regional/provincial certification or reasoned report, apply Bizkaia's art.67.3 subsidy reduction or Álava/Gipuzkoa's express full-grant reduction in art.65.3, prevent incompatible category overlap and apply the 50%-of-residual-quota bucket/minimum exception. Bizkaia and Álava state a EUR 40,000 clean-list passenger-car base cap; Gipuzkoa excludes principal waste-management businesses from the named energy-recovery branch. Financed-credit transfers under art.65 bis need their own signed contract, certification, communication and recipient limit and do not let both project owner and financer claim the transferred amount. B/A/G arts.65–65 bis; G26 art.8 for revised timing of financed costs., Álava NF37/2013, Gipuzkoa NF2/2014, Gipuzkoa DF-Norma2/2026

For the environmental subsidy calculation, assume EUR 100,000 of otherwise eligible non-vehicle investment, a EUR 20,000 funding grant and a company taxed at 24%. Bizkaia's ordinary article 67.3 reduction is 20,000 × (100% - 24%) = EUR 15,200; the base is EUR 84,800 and its generated 35% credit is EUR 29,680. Álava/Gipuzkoa article 65.3 instead subtract the full EUR 20,000: base EUR 80,000 and generated credit EUR 28,000. The EUR 1,680 difference is a territorial base rule, before quota limits. Sources: each province's article 65 and Bizkaia article 67.3, in the current corporate laws linked above.

Bizkaia and Álava art.66 bis give 25% of eligible new/recent SME-share investment, increased to 35% for the statutory innovative or silver-economy company category. Only the investment portion within 25% total investor/related-person ownership can form the credit base. Require an eligible unlisted company form, real new business and its people/assets, acquisition at formation or in the following five years (seven for the innovative route, with its high-initial-risk-financing exception), retention longer than five years, the issuing company's certificate and innovation evidence where relevant. Exclude continuation/restructuring without a real new activity, enterprises in difficulty, pending aid-recovery orders and excess risk-finance cases. The same funds cannot generate two claims; recover the credit plus interest on failure. Bizkaia expressly makes this a return election that cannot be changed after the voluntary deadline. Do not give Gipuzkoa this corporate credit by copying art.66 bis, which there is a culture provision. B/A art.66 bis., Álava NF37/2013

Bizkaia's separate silver/care-economy vocational-training credit is 10% of qualifying employee training expense, plus 15% of the excess over the previous two-year average. It requires the statutory sector/activity classification and skills/update/reskilling purpose; exclude employee remuneration and follow the implementing subject/course conditions. B art.66 ter and BR., Bizkaia DF203/2013

Navarra art.62's R&D financing method requires an unrelated financer, a prior signed financing contract identifying parties, project, budget and funding, no financer ownership of project-result IP, a requested/obtained technical report before contract signature, and joint communication of the report/request and contract before the end of the period generating the credit. The financer claims the transferred qualifying credit limited to 1.20 times its paid financing; the project company retains the excess and cannot also claim the transferred portion. The financer brings the positive excess of credit used over financing paid into taxable income. Apply the art.53 minimum and art.67 sequencing to the actual claims. N arts.39,61–62.

Navarra foreign-tax credits in arts.56–57 have a ten-year insufficient-quota carry, unlike chapter-III investment credits' fifteen years. Credit the lower of actually paid equivalent foreign tax (within treaty entitlement) and Navarra tax attributable to the foreign income; gross up the foreign tax in the income and separate country baskets and each PE as required. Any eligible undeducted foreign tax treated as a business expense follows art.56.2. Do not claim participation/PE exemption and foreign credit for the same income. N arts.35–36,56–57.

Culture, credit financing and specialised IP/reinvestment routes remain additional methods, not universal deductions. Use the separately identified eligibility, contract and communication requirements before applying a specialist claim.

Worked example

The text's own control: environmental investment subsidy, Bizkaia against Álava and Gipuzkoa

This is the control stated under "Ordinary social, commuting and environmental credits", recomputed. Otherwise eligible non-vehicle environmental investment 100,000, a 20,000 funding grant and a company taxed at 24%. Bizkaia's ordinary art. 67.3 reduction is 20,000 × (100% − 24%) = 15,200, base 84,800, generated 35% credit 29,680. Álava and Gipuzkoa art. 65.3 subtract the full grant: base 80,000, credit 28,000. The 1,680 difference is a territorial base rule, before quota limits.

name: Environmental investment credit, Bizkaia grant reduction against Álava/Gipuzkoa full reduction
inputs:
  investment: 100000
  grant: 20000
  rate: 0.24
steps:
  bizkaia_reduction: grant * (1 - rate)
  bizkaia_base: investment - bizkaia_reduction
  bizkaia_credit: bizkaia_base * 0.35
  alava_gipuzkoa_credit: (investment - grant) * 0.35
  difference: bizkaia_credit - alava_gipuzkoa_credit
expected:
  bizkaia_reduction: 15200.00
  bizkaia_base: 84800.00
  bizkaia_credit: 29680.00
  alava_gipuzkoa_credit: 28000.00
  difference: 1680.00

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
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
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 DA 31–33; A DA 28–30; G DA 26–28, in the current corporate laws linked above	2025–29 below-1.5% employer-pension credits and preferred-equivalent plan classification, separate from 2025-only enhanced credits	2026-10-28
B art.65/67.3; A/G art.65.3, in the current corporate laws linked above	Environmental investment subsidy reduction differs: Bizkaia general after-tax reduction versus Álava/Gipuzkoa full funding grant	2026-10-28

Official source	Scope read	Read on
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

Not yet confirmed: Specialist culture/financing, IP nexus, reinvestment, patrimonial entities, fiscal groups, co-ops and restructuring require their own complete methods before use. No other item specific to these credits is open beyond those listed in the es-foral-corporate-tax Sources. No accountant attestation is claimed.