The Spanish government on December 3, 2016, passed Royal Decree Law 3/2016, amending certain provisions of the corporate income (CIT) and other tax laws. Similar to the recently approved amendment regarding estimated CIT payments, these measures aim to increase revenues to meet the deficit level agreed upon with the European Union.
For entities treated as ‘large taxpayers’, Law 3/2016 introduces more restrictive limitations on net operating loss (NOL) carryforwards and foreign tax credits (FTCs). For all taxpayers, Law 3/2016 introduces measures that reinforce the nondeductibility of tax losses incurred on the transfer of shares.
In addition, the government expressed its commitment to the current 25% CIT rate. Contrary to previous speculation, the holding company regime (known as ETVE) has not been modified and the 100% participation exemption for dividends and capital gains still applies.
Source & more info: PwC