We have always been surprised to observe the political passivity for decades, despite publicly condemning the uncharitable financial and fiscal engineering that drained the profits of large companies out of the territories where they operated to transfer them to jurisdictions with zero or low taxation or, in other words, to tax havens.
There is a historical and popular demand to opt for a reinvention of the international tax system, eliminating money havens and laying the foundations for a more balanced world.
That’s why it was absolutely astonishing that at a meeting held on October 30, 2021 in Rome, at a time when it seemed that COVID was uniting half the planet in goodwill, there was talk of seeking a fair and equitable tax system, where no one acted alone, especially when the participants in that meeting were the countries of G20 that is, the group of industrialized and emerging countries that represent 85% of world GDP and 66% of the population, which included, among others, Brazil, Germany, Australia, Canada, China, Japan, Mexico, India, and the USA. JOE BIDEN at the head, who stated:
“This is more than a tax agreement: it is diplomacy that reshapes our global economy and benefits our citizens.”
Along with the ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT (OECD) They proposed the PILLAR 2 Initiative: the adoption of a GLOBAL MINIMUM TAX OF 15% for large companies (specifically those with a turnover of at least 750 million euros).
MODEL RULES were published in December 2021, and in Spain, the LAW 7/2024 transposed the EU Directive 2022/2523 of the EUROPEAN COUNCIL incorporating what is known as the SUPPLEMENTARY TAX, applicable to fiscal years beginning on or after December 31, 2023, to ensure that multinationals do not pay less than 15% in taxes in each country in which they operate, and is already a reality in our country for multinationals that may have been established, or are already located.
The idea is that wealth will be better distributed, have an impact on the areas where it is produced, and investments will grow.
This is a novel development, considering that, for example, over the last 100 years, the brands that dominate global trade have done everything possible to negotiate special deals or avoid being subject to the same rules that other companies follow. Clearly, they have been solely and exclusively pursuing their own interests.
Implementing regulations always brings practical implications, requiring harmonization with existing systems, such as registration, internal protocols, system adaptation, and ensuring all formal aspects are aligned with the regulations of each country where they may be applied. This process, of course, takes time to resolve and for all parties involved to accept it.
Of course, there are also critical voices that question whether this minimum obligation will affect the end customer, because these large companies can raise the price of their products or services to compensate for the increased cost resulting from a higher tax payment.
How many companies exceed 750 million in revenue?
If we refer exclusively to Spain, there is no data available on the exact number of companies of these characteristics in 2025.
In 2021, according EUROPA PRESS In Spain, there were 123 multinationals that exceeded that turnover and, moreover, declared that they had paid an average of only 2.9% of their global profit in Corporate Income Tax that year, as published on the website of the TAX AGENCY, where information was offered on these groups with 13,699 subsidiaries, of which 4,333 had their tax domicile in Spain, and 9,366 abroad.
While it can be said that they represent a small fraction of the total number of companies in our country, they play a significant role in the national economy and thus, for example, in 2023, 0.16% of the total were responsible for a third (34.09%) of business employment.
And the Canary Islands?
The Canary Islands has a FINANCIAL AND FISCAL SYSTEM differentiated by being considered as an OUTER PERIPHERAL ZONE, according to the ARTICLES 349 & 355 of the TREATY ON THE FUNCTIONING OF THE EUROPEAN UNION (TFEU).
The tax incentives of the Canary Islands (such as the Canary Islands Investment Reserve, the Bonus for Production of Tangible Goods, the Deduction for New Fixed Assets, the Canary Islands Special Zone, etc.) are not affected by this minimum taxation of 15%, so they can continue to be applied according to their own limits
The reason is that the portion of the taxable base (the benefit of submiting the supplementary tax) is subject to the so-called concept of substance exclusion, meaning that the profit is reduced in consideration of the cost of workers and the value of the tangible assets that the company employs.
Today, more than ever, the financial and fiscal model of the islands is even more attractive than that of Luxembourg, Andorra, or Ireland.
The president of the Canary Islands Special Zone Consortium (ZEC), PABLO HERNÁNDEZ In December 2023, stated:
“We are pleased because, in relative terms, the Canary Islands are gaining competitiveness because our bonus mechanisms are different from those used by tax havens.”
And in the rest of the world?
DONALD TRUMP with his return to the White House, has broken the Global Agreement and nullified the commitment, stating that it has no force or effect in the United States, to which he has added a tariff war with the entire planet, with consequences yet to be assessed, as if it were an episode of THE X-FILES, that legendary series that had a most prophetic slogan:
“The truth is out there.”
Now it’s up to us to find out what that truth is, because every day it appears more complicated and tangled, its contradictions rising to the nth degree, so that what is one today can be a hundred tomorrow, as if it were a bad joke.
To all this has been added the current owner of X, ELON MUSK who has broken with what seemed to be his new great friend upon realizing that the measures he himself had helped to implement are turning against him, since they are hitting the waterline of his own businesses.
Hadn’t you noticed until now? Really?
As QUEVEDO would say:
“Money is a powerful gentleman.”
Clarification for younger staff: The quote is from the famous Golden Age writer and author of the satirical poem. Not to be confused with the famous CANARY ISLAND SINGER internationally impactful with their urban music.
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