On 30 June 2026, Royal Decree-Law 18/2026 of 29 June was published in the Spanish Official Gazette (BOE), introducing a number of measures under the Comprehensive Response Plan to the Middle East Crisis.
This new legislation extends, on a gradual and conditional basis, certain measures previously introduced by Royal Decree-Law 7/2026 of 20 March, with the aim of mitigating the impact of the current geopolitical crisis on energy markets and avoiding an abrupt withdrawal of the tax relief measures benefiting households, businesses and sectors particularly exposed to rising energy costs.
In particular, Royal Decree-Law 18/2026 establishes a phased withdrawal of the temporary tax reductions applicable to certain energy products, introduces safeguard mechanisms allowing the temporary reinstatement of the reduced VAT and Electricity Excise Duty rates in the event of significant increases in the Consumer Price Index (CPI), and, most notably, amends the tax rate applicable to the Tax on the Value of Electricity Production (IVPEE), setting it at 3.5% for 2027 and 0% with effect from 1 January 2028 on an indefinite basis.
The main tax measures introduced by the Royal Decree-Law are summarised below:
- Hydrocarbons Excise Duty: Gradual Reduction of Tax Rates
With respect to Hydrocarbons Excise Duty, the new legislation provides for a temporary reduction in the tax rates applicable to the most widely consumed fuel products, particularly diesel and unleaded petrol.
The reduction will apply progressively during July, August and September 2026 as follows:
- EUR 0.15 per litre during July 2026.
- EUR 0.10 per litre during August 2026.
- EUR 0.05 per litre during September 2026.
The Royal Decree-Law also includes a safeguard mechanism should the CPI for petrol or diesel increase significantly. In such circumstances, the tax reductions could be increased to as much as EUR 0.20 per litre during August or September, depending on the evolution of the relevant CPI indices.
For the remaining energy products falling within the scope of Hydrocarbons Excise Duty, whose tax rates had already been reduced under Royal Decree-Law 7/2026, the new legislation provides for a gradual return to the standard tax rates, while also allowing for enhanced reductions should exceptional CPI increases occur.
- VAT on Electricity, Natural Gas, Biomass and Firewood
Royal Decree-Law 7/2026 had temporarily reduced the VAT rate from 21% to 10% on certain supplies, imports and intra-Community acquisitions of energy products.
Royal Decree-Law 18/2026 does not automatically extend this reduced rate beyond June. Instead, it introduces a safeguard mechanism allowing the temporary reinstatement of the 10% VAT rate during August and September 2026 if the CPI for the relevant energy products shows an unfavourable evolution.
Where the relevant conditions are met, the 10% VAT rate may apply to:
- Supplies, imports and intra-Community acquisitions of electricity made to customers with a contracted capacity of up to 10 kW.
- Electricity supplies to recipients of the Spanish social electricity bonus qualifying as severely vulnerable consumers or consumers at risk of social exclusion.
- Supplies, imports and intra-Community acquisitions of natural gas.
- Biomass briquettes and pellets.
The application of the reduced VAT rate is conditional upon the CPI for the relevant category (electricity or natural gas, as applicable) exceeding by more than 15% the CPI recorded in the same month of the previous year.
- Electricity Excise Duty
Royal Decree-Law 7/2026 had temporarily reduced the Electricity Excise Duty rate from 5.11269632% to 0.5%, while maintaining compliance with the minimum taxation levels required under EU legislation.
Royal Decree-Law 18/2026 introduces an equivalent safeguard mechanism for August and September 2026. Accordingly, where the CPI for electricity exceeds by more than 15% the CPI for the corresponding month of the previous year, the Electricity Excise Duty rate will be reduced to 0.5% for the relevant month.
However, the resulting tax liability may not fall below:
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- EUR 0.5 per MWh where electricity is used for industrial purposes, by vessels moored in port (other than private pleasure craft), or for railway transport.
- EUR 1 per MWh in all other cases.
- Electricity Production Tax (IVPEE): New Rules for 2026 and Progressive Reduction of the Tax Rate
One of the most significant developments introduced by the Royal Decree-Law concerns the Tax on the Value of Electricity Production (IVPEE).
For fiscal year 2026, the legislation introduces new rules for calculating both the taxable base and the advance payments of the tax. In particular, the following amounts will be excluded from the taxable base:
- 30% of the remuneration received from electricity generation and injection into the grid during the third quarter of 2026.
- 40% of the remuneration received during the fourth quarter of 2026.
These measures are in addition to those already applicable to the first and second quarters of 2026 under Royal Decree-Law 7/2026.
Furthermore, the Royal Decree-Law amends Law 15/2012 on Tax Measures for Energy Sustainability by introducing a progressive reduction of the IVPEE tax rate:
- 5% for fiscal year 2027.
- 0% from fiscal year 2028 onwards.
This amendment represents a structural change in the taxation of electricity generation by establishing a 3.5% tax rate for 2027 and a 0% rate with effect from 1 January 2028 on an indefinite basis. The legislation also provides for an update of the remuneration parameters applicable to renewable energy, cogeneration and waste-to-energy installations in order to reflect this amendment.
- Public Information Requirements
The Royal Decree-Law also introduces obligations for fuel stations and other retail fuel suppliers to provide appropriate information to customers regarding the temporary energy tax measures.
These requirements aim to ensure that consumers are properly informed of the applicable tax reductions and to enhance transparency regarding the pass-through of those reductions into final retail prices.
- Recommended Actions
In light of the new regulatory framework, businesses should consider taking the following actions:
- Assess the impact of the gradual reduction in Hydrocarbons Excise Duty on supply costs and pricing policies.
- Determine whether they may benefit from the conditional application of the reduced VAT and Electricity Excise Duty rates during August and September 2026.
- Review the impact of the new IVPEE taxable base and advance payment calculation rules for fiscal year 2026.
- Assess the implications of the reduction of the IVPEE rate to 3.5% in 2027 and to 0% from 2028 onwards.
- Review energy supply agreements, hedging arrangements and forward pricing mechanisms in light of the IVPEE reform.
- Ensure compliance with any applicable transparency and information obligations relating to the temporary energy tax measures.
How can we assist you?
We recommend reviewing the impact of these measures on your company’s energy tax position, including their effect on supply agreements, invoicing procedures and internal energy cost monitoring processes.
With more than 30 years’ experience in indirect taxation, Salinas & Partners remains at your disposal should you require any further information or assistance.
On 21 March 2026, Royal Decree-Law 7/2026 of 20 March (ratified on 26 March) was published in the Official State Gazette, approving the Comprehensive Plan to Address the Crisis in the Middle East, which includes, amongst other measures, various tax measures aimed at mitigating the impact of rising prices for energy and electricity products resulting from the international energy crisis.
The main measures approved in this Royal Decree in relation to the Excise Duty on Hydrocarbons, the Excise Duty on Electricity and Value Added Tax are detailed below.
- Reduction of Hydrocarbon Excise Duty rates
The Hydrocarbon Excise Duty rates applicable to the main energy products are reduced, bringing them to the minimum levels permitted by Directive 2003/96/EC restructuring the EU Community framework for the taxation of energy products and electricity.
This reduction applies, amongst others, to products such as leaded and unleaded petrol, general-purpose diesel, fuel oil, LPG, natural gas, kerosene and biofuels.
- Reduction in the rates of the Excise Duty on Electricity
The Royal Decree-Law establishes a reduction in the rate of the Excise Duty on Electricity, which is lowered from the general rate of 5.11269632% to 0.5%. However, minimum rates of €0.50 per megawatt-hour are set for industrial uses, agricultural irrigation, rail transport and certain vessels, and €1.00 per megawatt-hour for all other cases.
In addition, reductions are introduced in the tax base for the Tax on the Value of Electricity Production for the 2026 financial year, to offset the costs being borne by companies. These reductions will be implemented by reducing the tax base by a percentage of the revenue corresponding to the electricity fed into the system during the first two quarters of the year, with the aim of reducing electricity generation costs and promoting more competitive prices in the wholesale market, which are expected to result in lower electricity prices for the end consumer.
- Reduction in VAT rates on certain energy products
In the area of Value Added Tax, the VAT rate applicable to supplies, imports and intra-Community acquisitions of goods relating to electricity supplied to contract holders with a contracted power of less than 10 kW, electricity supplied to beneficiaries of the social tariff who are classified as severely vulnerable or severely vulnerable at risk of social exclusion, natural gas, briquettes and pellets derived from biomass, firewood, petrol, diesel and biofuels intended for use as motor fuels.
- Key dates
All these measures are temporary in nature and come into force from their publication in the Official State Gazette (21 March 2026) until 30 June 2026. However, as these are exceptional measures, their application is subject to the change in the CPI during the month of April; therefore, if the change in the CPI for these products does not exceed that of the same month of the previous year by more than 15%, the reduction will cease to apply in June 2026.
How can we assist you?
Our team of specialists in indirect taxation and excise duties can advise you on analysing the impact of these measures, the correct application of the new tax rates and compliance with the tax obligations arising from the new regulations.
Salinas & Partners, with over 30 years’ experience in excise duties and VAT, is at your disposal to answer any queries you may have.
The Spanish 2026 Annual Tax and Customs Control Plan was published on 12 March (Official State Gazette, Resolution of 11 March), setting out the lines of action and strategies to be implemented by the Tax Agency during the 2026 financial year for the effective application of the state tax and customs system.
In this briefing, we highlight the main actions to be undertaken, both to prevent and to correct tax irregularities in the areas of customs and indirect taxation.
Notwithstanding the above, by way of introduction, we consider it relevant to highlight the following actions:
- Corrective self-assessments and prevention of non-compliance:
We will continue to promote the use of corrective self-assessments for the main taxes, facilitating voluntary regularisation by taxpayers and reducing administrative burdens. - Electronic invoicing and invoicing systems:
During 2026, progress will be made on the regulation and implementation of mandatory electronic invoicing between businesses and professionals, as well as on the information and support strategy associated with the Public Electronic Invoicing Solution. Furthermore, the Tax Agency will continue to promote the implementation of systems derived from the VERI*FACTU Regulation, including the submission, consultation and download of invoicing records, the QR code verification system on invoices, and the availability of a free invoicing app for businesses and professionals with simple invoicing processes - Civic and tax education and simplification of language:
Training initiatives will continue to be developed in both schools and universities to encourage voluntary compliance with tax obligations. Furthermore, the Administration will continue to work on simplifying the documents issued, particularly in relation to VAT and Corporation Tax penalty procedures, with the aim of facilitating voluntary compliance with tax obligations.
Below, we identify the risk profiles and list the control activities that will be subject to verification during the 2026 financial year, in the areas of customs and indirect taxation:
Customs
- Greater control over e-commerce, particularly following the removal of the €150 customs duty exemption, with a particular focus on digital platforms and distance sales of imported goods.
- Digitisation and modernisation of customs clearance.
- There will be greater control over imports, particularly in cases of fraud such as the undervaluation of goods or the abuse of VAT exemptions, requiring payment or a guarantee of duties prior to release.
- Controls on customs suspensive procedures, particularly transit, are being strengthened to prevent the irregular introduction of goods into the territory of the European Union.
- International cooperation is being promoted, mainly with neighbouring countries and bodies such as the European Anti-Fraud Office (OLAF), to improve the fight against fraud and compliance with international sanctions.
- Customs surveillance operations will be stepped up, with particular focus on drug trafficking (cocaine and hashish), money laundering and the use of new financial methods such as neobanks.
- Specific investigations into customs and environmental fraud are being carried out, including the control of illegal imports of fluorinated greenhouse gases.
VAT
- Voluntary compliance by taxpayers will be encouraged through the use of the Pre303 system, which enables the detection of discrepancies between accounting records and submitted self-assessments, facilitating their rectification via amended self-assessments.
- There will be a greater number of checks to verify that taxpayers registered in the Register of Intra-Community Operators, the Monthly Refund Register and the Register of Tax Warehouse Operators continue to meet the required criteria, as a key measure for preventing tax risk.
- The tax authorities will tighten controls on VAT-exempt imports where goods are destined for other Member States, paying particular attention to the undervaluation of goods and requiring payment or a guarantee of duties before authorising release.
- Measures to combat irregular invoicing are being stepped up through the use of IT tools designed to detect fraud networks, including shell companies or dormant entities that issue fictitious invoices to simulate business activity and obtain undue refunds or illegal deductions.
- Coordination in the fight against organised VAT fraud schemes is being strengthened, both at national and intra-Community level, with particular attention to the vehicle sector and to registration and transfer processes.
- Controls on capital goods will be strengthened, and checks will be carried out to ensure that there are no changes in their destination or use that would render the VAT deduction inapplicable, as well as to prevent the use of intermediary companies to obtain undue deductions.
- Administrative coordination in the application of the special one-stop shop schemes (OSS and IOSS) is being improved, strengthening European cooperation in the fight against VAT fraud.
- Specific measures are being taken to control the misuse of the reduced VAT rate on services that include relevant supplies.
- In the hydrocarbons sector, additional measures are introduced to ensure VAT is paid before products leave tax warehouses, including new records, stricter requirements for operators and the attribution of liability to the owners of such warehouses in the event of non-compliance.
Excise and environmental duties
- There will be greater control over excise duties linked to foreign trade (hydrocarbons, alcohol, tobacco), as well as products linked to the suspension regime or those with tax benefits.
- Surveillance of factories, warehouses and tax warehouses will be stepped up to prevent their use in fraud schemes, particularly in operations relating to VAT or in international schemes that conceal the diversion of goods.
- There will be greater scrutiny of the lawful possession of hydrocarbons, particularly at service stations and transport companies, with special attention paid to cases of product adulteration or purchases from unauthorised operators.
- Supervision of hydrocarbon tax refunds arising from the professional use of diesel will be strengthened, in order to prevent the improper application of tax benefits.
- Products subject to Alcohol and Alcoholic Beverages Tax will be subject to greater control, particularly those linked to the suspension regime or with tax benefits, verifying their correct classification and the proper application of exemptions and refunds.
- An obligation is established to ensure the payment of VAT before hydrocarbons leave tax warehouses, requiring its payment or a guarantee in advance. This measure is supported by the REDEF system, which monitors authorised operators, and strengthens the responsibility of tax warehouse keepers, with the aim of preventing fraud and ensuring tax collection.
- Controls are being strengthened over the import, export and intra-Community movements of tobacco products, the investigation of smuggling and the monitoring of raw tobacco movements to detect possible illegal factories, as well as over the new excise duty applicable to e-cigarettes and related products.
- There will be an increase in investigations into environmental taxes, including the control of illegal imports of fluorinated gases, in collaboration with other agencies and police forces.
How can we assist you?
We recommend proactively ensuring tax compliance in domestic and international transactions with tax implications, and in particular those for which the Tax Agency anticipates imminent audit proceedings.
Salinas & Partners, with over 30 years’ experience in indirect taxation and in preventive and corrective audit procedures, is at your disposal for any queries or comments you may have.
On 17 March, the Tax and Customs Control Plan was published (BOE Resolution of 27 February), which sets out the lines of action and strategies to be carried out by the Tax Agency in 2025 for the effective application of the State tax and customs system
