The tax authorities commented on April 14, 2026, on the Council of State's decision of March 13, 2025, which clarified the eligibility conditions for the reduced corporate income tax rate. Moving forward, to determine if a company meets the €10 million turnover threshold criterion, the turnover of the entire group holding the eligible company must be considered, whether or not this group is fiscally integrated. Companies that wrongly benefited from it have until May 20, 2026, to file amended returns for their 2023 and 2024 fiscal years.

In this issue

- The reduced corporate income tax rate
- The Council of State's decision of March 13, 2025
- The implications of this decision
- The adjustments to be implemented

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