The tax due on a taxpayer shall be zero for any tax period starts on or before 31 December 2026 without the inclusion of tax periods ended after 30 June 2028 in one of the following cases:

1. If the following two requirements have been met:

   1. The total revenues of the taxable entities in the group are less than 10 million euros or its equivalent.

   2. The total income of the taxable entities in the group is less than one million euros or its equivalent. The aggregate is calculated for the mentioned tax period based on the exchange of reports between the state and other states or jurisdictions.

2. If the effective tax rate for the taxpayer for the mentioned tax period equals or exceeds 16% for tax periods starting in 2025 and 17% for tax periods starting in 2026, based on the exchange of reports between the state and other states or jurisdictions.

3. The taxpayer's profit or loss for the mentioned tax period is equal to or less than the amount of excluded income based on the significance of the activity, according to the provisions of Article 10 of this law, based on the exchange of reports between the state and other states or jurisdictions.

The provisions of this Article shall not apply to the following:

1. Entities not affiliated to any state or jurisdiction.

2. Groups of multinational entities owned by several ultimate parent entities which don't include information about these groups in the exchanged reports between the state and other states or jurisdictions.

3. If the exchanged report between the state and other countries or jurisdictions is not qualified according to the controls defined by the executive regulations.

The executive regulations specify the controls and conditions related to the application of the provisions of this Article.