Navarra approves Pillar Two regulations

Key legal instruments

• Council Directive (EU) 2022/2523 – EU Pillar Two directive.

• Ley 7/2024 – Spanish primary legislation for the Global Minimum Tax (‘Impuesto Complementario’).

• Real Decreto 252/2025 – Spanish state Pillar Two regulation.

• Ley 4/2025 – amendment to the Convenio Económico introducing article 27 bis.

• Ley Foral 18/2025 – Navarra’s Pillar Two statute.

• Decreto Foral 13/2026 – Navarra’s Pillar Two regulation.

Legislative background

Spain introduced the global minimum tax at state level through Ley 7/2024 and then adopted the implementing regulation in Real Decreto 252/2025. Navarra subsequently enacted its own substantive Pillar Two statute, Ley Foral 18/2025, and then approved its own implementing regulation by Decreto Foral 13/2026 on March 17, 2026. The Navarra statute and regulation both apply, like the state regime, to periods beginning on or after 31 December 2023, with the under-taxed profits rule generally effective for periods beginning on or after 31 December 2024.

Navarra’s Local Regulations v the State regulation

The key aspect is the Convenio Económico. Article 27 bis, introduced by Ley 4/2025, allocates the Global Minimum Tax to Navarra for taxpayers meeting the relevant connecting factors. Navarra’s own preamble then states expressly that article 27 bis configures the Global Minimum Tax as an autonomous tax regulation. 

In parallel, article 2 of Ley Foral 18/2025 states that the Global Minimum Tax applies across the whole of Spanish territory, but the scope of the Navarra law is determined in accordance with article 27 bis of the Convenio Económico.

As such, Navarra needs its own statute and its own regulation. The tax is territorially Spanish, but the applicable domestic legal regime is divided between common Spanish territory and Navarran territory under the competence-allocation rules of the Convenio Económico.

Is Decreto Foral 13/2026 effectively just the state regulation for Navarra?