Key data
| Regulation | Resolution of June 25, 2026, from the General Secretariat of the Treasury and International Financing |
|---|---|
| Publication | June 27, 2026 |
| Effective date | July 1, 2026 (third quarter of 2026) |
| Affected parties | Investors, financial entities and issuers of financial assets with mixed income |
| Category | Tax News |
| Period | Q3 2026 (July–September 2026) |
| Affected taxes | Personal Income Tax (IRPF) and Corporate Income Tax (IS) |
As of July 1, 2026, any mixed-income financial asset issued or held in portfolio must be compared against the new reference rates published by the General Secretariat of the Treasury. The Resolution of June 25, 2026 (BOE-A-2026-14001) establishes the quarterly thresholds that determine the tax classification of these instruments under both IRPF and Corporate Income Tax.
The practical key is straightforward: if the coupon or explicit income of an asset falls below the reference rate corresponding to its maturity, the Tax Agency may reclassify part of the income as implicit, with different tax consequences for the issuer and the investor.
What does this regulation establish?
Spanish tax regulations distinguish between two types of income in mixed-income financial assets: explicit income (agreed coupon) and implicit income (difference between issue price and redemption price). The tax classification of each part depends on whether the explicit income exceeds or not the official reference rate for the asset's maturity.
The General Secretariat of the Treasury publishes these rates each quarter. For Q3 2026 (July 1 – September 30, 2026), the reference rates for mixed-income financial assets are as follows:
| Asset maturity | Reference rate Q3 2026 |
|---|---|
| Up to 4 years | 2.218% |
| Up to 7 years | 2.358% |
| At 10 years | 2.706% |
| At 15 years | 3.050% |
| At 30 years | 3.292% |
For inflation-indexed public debt, the reference rates are significantly lower, reflecting the inflation protection component already incorporated in the instrument:
| Asset maturity (inflation-indexed) | Reference rate Q3 2026 |
|---|---|
| Up to 4 years | 1.109% |
| Up to 7 years | 1.179% |
| At 10 years | 1.353% |
| At 15 years | 1.525% |
| At 30 years | 1.646% |
These thresholds are exactly half of the rates applicable to non-indexed assets, reflecting the Treasury's technical criterion for this type of instrument.
Economic and operational impact
The correct tax classification of a financial asset is not a minor detail: it directly affects the taxable base of the issuer and the investor, the applicable withholdings, and the way income is integrated into the IRPF or IS declaration.
- For the issuer: if the explicit coupon falls below the reference rate, the difference between redemption price and issue price is classified as implicit income. This can alter the deductibility schedule of financial expenses under IS.
- For the individual investor: implicit income is taxed differently from explicit income under IRPF, with possible impacts on withholdings and integration into the savings base.
- For financial entities: incorrect classification of assets in portfolio can generate tax contingencies in inspections, especially in private fixed-income portfolios with low-coupon structures.
- For issuance structurers: any new private fixed-income issuance maturing in Q3 2026 or later must be designed with these rates as a minimum reference to ensure classification as explicit income.
Who does it affect?
- Companies issuing bonds, obligations or notes with mixed income
- Financial entities (banks, savings banks, credit cooperatives) with private fixed-income portfolios
- Investment funds and asset managers with mixed-income assets in portfolio
- Institutional and individual investors with corporate bonds or inflation-indexed public debt
- Tax advisors and corporate tax departments that structure or review fixed-income issuances
- CFOs and financial directors of companies that have issued or plan to issue private debt in 2026
Practical example
A company issues in July 2026 a bond at 5 years with an explicit coupon of 2.20% annually and a redemption price higher than the issue price.
The applicable reference rate for a maturity of up to 7 years in Q3 2026 is 2.358%. Since the explicit coupon (2.20%) falls below the threshold, the difference between the redemption price and the issue price will be classified as implicit income, not explicit income.
Practical consequence: the investor will not receive withholding on that part of the income at the time of coupon payment, but will be taxed at maturity as implicit income. For the issuer, the deductibility of that financial cost may be deferred or conditional. If the coupon had been 2.40% (above 2.358%), all income would have been classified as explicit, simplifying the tax management for both parties.
The solution: when structuring the issuance, set the explicit coupon at least at 2.358% for that maturity, or review with the tax advisor whether the implicit income structure is tax-efficient for the target investor.
What should companies do now?
- Review all outstanding private fixed-income issuances maturing or with coupons in Q3 2026 and compare the explicit income against the reference rates according to the residual maturity of the asset.
- Verify the portfolio of mixed-income financial assets on the balance sheet: if any asset has a coupon below the corresponding threshold, confirm that the applied tax classification is correct.
- Update the structuring models for new issuances incorporating the Q3 2026 rates as a minimum reference to ensure classification as explicit income.
- Coordinate with the tax advisor any issuance planned for the July–September 2026 period, especially if it is inflation-indexed debt (thresholds from 1.109% to 1.646%).
- Document the verification performed to prove in the event of an inspection that the reference rates in force in the corresponding quarter have been applied.
Frequently asked questions
What exactly are the reference rates for Q3 2026?
For non-indexed mixed-income financial assets: 2.218% (up to 4 years), 2.358% (up to 7 years), 2.706% (at 10 years), 3.050% (at 15 years) and 3.292% (at 30 years). For inflation-indexed public debt: 1.109%, 1.179%, 1.353%, 1.525% and 1.646% respectively. These rates are in force from July 1 to September 30, 2026.
What happens if my bond's coupon is below the reference rate?
If the explicit income (coupon) of a mixed-income financial asset does not exceed the reference rate corresponding to its maturity, the difference between the redemption price and the issue price is classified as implicit income. This has different tax consequences under IRPF and IS: it affects the applicable withholdings, the timing of taxation, and the deductibility of financial expenses for the issuer.
How often are these reference rates updated?
The General Secretariat of the Treasury and International Financing publishes these rates each natural quarter. The rates published on June 27, 2026 are valid exclusively for the third quarter of 2026 (July, August and September). For Q4 2026, a new resolution will be published with the updated rates.
Does this regulation affect inflation-indexed public debt?
Yes, but with significantly lower reference rates. For inflation-indexed public debt, the Q3 2026 thresholds range from 1.109% (up to 4 years) to 1.646% (at 30 years), approximately half of the rates applicable to non-indexed assets. This reflects that the inflation protection component is already incorporated in the instrument.
Where can I consult the official resolution with the Q3 2026 rates?
The complete resolution is published in the BOE with reference BOE-A-2026-14001, accessible at https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-14001. It was published on June 27, 2026 and came into force on July 1, 2026.
Official source
Consult complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-14001