Corporate Income Tax

Non deductible costs

If a taxpayer did not file the statement of commencement of activity, any document issued is disallowed as a tax deductible cost at the level of the acquirer.

Patent Box regime

The deduction to the taxable profit of the income from the transfer or temporary use of industrial property rights will increase to 85% (formerly, 50%).

Special payment on account

Special payments on account are extinguished.

Lack of filing the CIT return

Lack of filing the CIT return (“Modelo 22”) shall now imply the assessment of the taxable income based on the information in possession of the tax authority, under the rules of the simplified tax regime, by applying a coefficient of 0.35.

Autonomous taxation – transitional rules

In the tax year 2022, the aggravated autonomous rate of 10 p.p. will not apply to cooperatives, micro, small and medium sized companies, if the following requirements are met:

(i) The taxpayers assessed taxable profit in one of the three previous tax years, having filed timely the CIT return and the Company’s Simplified Information/Annual Statement (“IES”) in the two previous tax years;

(ii) The tax year of commencement of activity, or one of the two following tax years, corresponds to the tax year 2022.