Spain

CIT ~25% Pillar Two ✓

25% headline rate. PERTE Chip is the largest national semiconductor funding envelope in the EU by announced volume and includes a dedicated design pillar; execution has been slower than announced.

✓ 3 Jul 2026

Instruments (4)

Grant program Active Discretionary (call-based)

PERTE Chip

Spain's strategic project for microelectronics and semiconductors — the largest announced national semiconductor envelope in the EU (~€12.25bn), structured in four axes including a dedicated €1.33bn design pillar. Execution has lagged well behind the announced budget (~7% deployed by late 2025).

Total budget: ~€12.25bn
Design pillar: €1.33bn — dedicated chip-design strategy axis
Other axes: Scientific reinforcement €1.17bn · ICT industry €0.4bn · fabrication plants €9.35bn
Execution: ~€880M deployed by Sept 2025 (~7% of budget)

✓ 3 Jul 2026

R&D tax credit Active Rule-based entitlement

R&D&I tax deduction (Deducción por I+D+i)

One of Europe's most generous R&D tax credits: 25% of R&D expenditure (42% on the amount above the prior two-year average), plus uplifts for dedicated researchers and R&D assets. A monetisation option allows a cash refund at a 20% discount.

R&D rate: 25% base; 42% on spend above the 2-year average
Extra deductions: +17% qualified-researcher payroll; +8% R&D assets
Innovation (IT): 12% on technological-innovation expenditure
Monetisation: Cash refund available with a 20% discount

✓ 3 Jul 2026

IP box Active Rule-based entitlement

Patent Box (reducción de rentas de intangibles)

Spain's nexus-conform patent box: up to a 60% reduction of net income from qualifying intangibles (patents, utility models, registered advanced software), lowering the effective rate on that income to about 10%.

Reduction: Up to 60% of net qualifying IP income
Effective rate: ~10% on qualifying IP income
Qualifying IP: Patents, utility models, registered advanced software, SPCs
Nexus: Modified nexus ratio applies

✓ 3 Jul 2026

Expat tax ruling Active Rule-based entitlement

Beckham Law (special impatriate regime)

Special tax regime for workers relocating to Spain: a flat 24% income-tax rate up to €600,000 (47% above), taxation only on Spanish-source income, and exemption from wealth tax on worldwide assets, for the arrival year plus 5 more.

Flat rate: 24% up to €600,000; 47% above
Scope: Broadly Spanish-source income only during the regime
Duration: Arrival year + 5 years (6 total)
Extras: Wealth-tax exemption on worldwide assets; now open to startup workers/entrepreneurs

✓ 3 Jul 2026

FDI screening & export control

⚠ Semiconductors in scope

Threshold: 10% of share capital or effective management control, for a non-Spanish investor into a sensitive-sector target; temporarily extended to EU/EFTA investors for deals >€500M or listed targets through end of 2026
Authority: Consejo de Ministros, via the Dirección General de Comercio Internacional e Inversiones
Timeline: Several months for a full authorization; can extend materially for complex/contested cases

Semiconductors are explicitly listed among the critical technologies and dual-use products covered. As elsewhere, the regime is built around acquiring a stake/control in an existing Spanish target — a new subsidiary formed from scratch is generally not itself the trigger, but any acquisition, JV, or asset deal involving Spanish semiconductor capability should be checked against current guidance.

Legal basis: Law 19/2003, Art. 7 bis; Royal Decree 571/2023; extended by Real Decreto-ley 1/2025 — source ↗ ✓ 3 Jul 2026

Labor law snapshot

Works council: Comité de empresa mandatory at 50+ employees; delegados de personal (staff delegates) for 6–49
Notice periods: Statutory minimum 15 calendar days (Estatuto de los Trabajadores), but 86.7% of the workforce is covered by a convenio colectivo that often extends this to 30 days–3 months
Bargaining: Very influential — sector convenios colectivos largely set salary grids and conditions; statutory severance is 20 days' salary/year (objective dismissal, capped at 12 months) or 33 days/year (unfair dismissal, capped at 24 months)

✓ 3 Jul 2026 · orientation only, verify with local counsel

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