Spain’s General Guidelines of the 2026 Annual Tax and Customs Control Plan, published on 12 March 2026, reflect the continued evolution of an increasingly anticipatory, technology driven and internationally coordinated enforcement model. The guidelines set out the strategic lines of action the Spanish tax authorities (STA) will implement to prevent and combat tax fraud.
The guidelines confirm the consolidation of a control framework built on early risk detection, extensive data integration and enhanced administrative cooperation. Through the use of advanced technological tools and expanding information sources, the STA aims to reinforce compliance in an economic environment that is progressively more digitalised and globalised.
The guidelines are structured around five core pillars:
A central development is the strengthened use of large‑scale data as a foundational element of tax control. Key information sources include:
To advance administrative simplification, the STA will promote clearer and more direct communication formats with taxpayers, with particular emphasis on nonresident income tax.
The preventive model is reinforced through two main pillars: early risk analysis and promotion of voluntary compliance. This approach relies on the intensive use of available information and targeted preventive communications directed at specific taxpayers and recurring risk sectors, such as e‑commerce, leasing and certain corporate structures.
The principle of “control from the outset” will be enhanced through census reviews and scrutiny of the commencement of activities, with particular focus on the correct identification of foreign operators and nonresident entities.
In international trade, the digitalisation of customs processes and automatic exchange of information will continue to expand, with enhanced coordination with EU authorities. Controls over sensitive imports and exports will intensify, especially in relation to customs valuation, intra‑EU movements of goods and cross‑border e‑commerce.
The third pillar focuses on reinforcing audit and investigation activities targeting taxpayers and sectors with greater economic complexity or elevated tax risk.
In connection with the forthcoming transposition of DAC8 into Spanish law, new financial products—including electronic money and central bank digital currencies—will fall within the scope of automatic financial account information exchange.
Priority will be given to multinational groups, large enterprises and tax groups with complex intragroup structures, particularly where the declared activity does not align with operational reality or where intragroup transactions do not justify the tax configuration. Increased attention will also be directed at taxpayers with significant wealth.
The 2026 guidelines clearly signal an increase in the scrutiny of transfer pricing and related audits, specifically in the areas of corporate restructurings; the valuation of intragroup transfers or licences of assets (especially intangibles); deductions with high base erosion potential (e.g., royalties or intragroup services); recurring losses; and financially linked transactions. Entities characterised as having low declared business risk will continue to be reviewed.
The STA will intensify oversight of base erosion structures involving offshore entities designed to retain profits that should be taxed in Spain, as well as the use of interposed entities to channel personal income, avoid personal income tax or wealth tax, or simulate transactions without effective taxation.
Scrutiny of the special tax rollover regime for corporate restructurings will increase, especially where transactions are structured to allow indirect access to profits without the corresponding taxation.
In the real estate sector, controls over Spanish listed real estate investment companies will be reinforced, including oversight of investor-level income and the valuation of real estate transactions, particularly where related parties or complex corporate structures are involved.
The review of tax loss carry forwards, deductions and tax credits will intensify.
In the VAT sphere, efforts will increase to detect irregular invoicing and combat intra‑EU VAT fraud, including carousel fraud and vehicle-related avoidance schemes and improper VAT refunds linked to investment goods.
The STA will focus on the abusive use of economic interest groupings (AIEs in Spain) to artificially generate tax losses or credits where clearly abusive purposes are identified.
Finally, controls will be strengthened in emerging risk areas such as crypto assets, neo‑banks, unregistered operators and nonresidents, particularly regarding withholding taxes on dividends, interest and royalties. The authorities will verify the correct application of tax treaties and EU law, and the existence of genuine beneficial owners.
Control at the collection stage will be reinforced not only to ensure debt recovery, but also as a preventive mechanism influencing taxpayer behaviour.
The STA will intensify efforts to detect concealed assets, interposed entities and new financial instruments, with particular focus on crypto assets and cross‑border payments. Enforcement measures will be strengthened through new procedures targeting bank accounts, point of sale (POS) terminals and trade receivables, supported by technological advances.
Actions against tax crimes, asset stripping and third‑party liability will increase, alongside the use of precautionary measures and judicial avenues, including insolvency proceedings, to secure recovery of public debt.
The final pillar emphasises closer cooperation at both the domestic and international levels. The STA will continue to expand information exchange with European administrations, international organisations and other domestic authorities, strengthening efforts to combat tax fraud and recover debts.
Collectively, these measures confirm the consolidation of a highly specialised tax and customs control model based on international cooperation, advanced data analytics and a focus on complex, high‑risk scenarios, where formal compliance on its own may not be sufficient. Taxpayers should be prepared for:
Proactive and preventive tax management is essential for overall tax coherence, to minimise contingent risks and maintain compliance in an environment characterised by growing automation and administrative cooperation.
Jessica Kinnear
BDO in Spain
The guidelines confirm the consolidation of a control framework built on early risk detection, extensive data integration and enhanced administrative cooperation. Through the use of advanced technological tools and expanding information sources, the STA aims to reinforce compliance in an economic environment that is progressively more digitalised and globalised.
The guidelines are structured around five core pillars:
- Information and taxpayer assistance;
- Promotion of voluntary compliance and fraud prevention;
- Investigation and audit actions in tax and customs fraud;
- Fraud control at the collection stage; and
- Inter‑administrative cooperation.
Information and Taxpayer Assistance
A central development is the strengthened use of large‑scale data as a foundational element of tax control. Key information sources include:
- Data from payment service providers on cross‑border transactions;
- Information obtained from digital platforms under the EU DAC7 framework; and
- New financial reporting obligations arising from the expansion of the automatic exchange of financial information under DAC8, covering products such as electronic money and central bank digital currencies.
To advance administrative simplification, the STA will promote clearer and more direct communication formats with taxpayers, with particular emphasis on nonresident income tax.
Promotion of Voluntary Compliance and Fraud Prevention
The preventive model is reinforced through two main pillars: early risk analysis and promotion of voluntary compliance. This approach relies on the intensive use of available information and targeted preventive communications directed at specific taxpayers and recurring risk sectors, such as e‑commerce, leasing and certain corporate structures.The principle of “control from the outset” will be enhanced through census reviews and scrutiny of the commencement of activities, with particular focus on the correct identification of foreign operators and nonresident entities.
In international trade, the digitalisation of customs processes and automatic exchange of information will continue to expand, with enhanced coordination with EU authorities. Controls over sensitive imports and exports will intensify, especially in relation to customs valuation, intra‑EU movements of goods and cross‑border e‑commerce.
Investigation and Audit Actions in Tax and Customs Fraud
The third pillar focuses on reinforcing audit and investigation activities targeting taxpayers and sectors with greater economic complexity or elevated tax risk.In connection with the forthcoming transposition of DAC8 into Spanish law, new financial products—including electronic money and central bank digital currencies—will fall within the scope of automatic financial account information exchange.
Priority will be given to multinational groups, large enterprises and tax groups with complex intragroup structures, particularly where the declared activity does not align with operational reality or where intragroup transactions do not justify the tax configuration. Increased attention will also be directed at taxpayers with significant wealth.
The 2026 guidelines clearly signal an increase in the scrutiny of transfer pricing and related audits, specifically in the areas of corporate restructurings; the valuation of intragroup transfers or licences of assets (especially intangibles); deductions with high base erosion potential (e.g., royalties or intragroup services); recurring losses; and financially linked transactions. Entities characterised as having low declared business risk will continue to be reviewed.
The STA will intensify oversight of base erosion structures involving offshore entities designed to retain profits that should be taxed in Spain, as well as the use of interposed entities to channel personal income, avoid personal income tax or wealth tax, or simulate transactions without effective taxation.
Scrutiny of the special tax rollover regime for corporate restructurings will increase, especially where transactions are structured to allow indirect access to profits without the corresponding taxation.
In the real estate sector, controls over Spanish listed real estate investment companies will be reinforced, including oversight of investor-level income and the valuation of real estate transactions, particularly where related parties or complex corporate structures are involved.
The review of tax loss carry forwards, deductions and tax credits will intensify.
In the VAT sphere, efforts will increase to detect irregular invoicing and combat intra‑EU VAT fraud, including carousel fraud and vehicle-related avoidance schemes and improper VAT refunds linked to investment goods.
The STA will focus on the abusive use of economic interest groupings (AIEs in Spain) to artificially generate tax losses or credits where clearly abusive purposes are identified.
Finally, controls will be strengthened in emerging risk areas such as crypto assets, neo‑banks, unregistered operators and nonresidents, particularly regarding withholding taxes on dividends, interest and royalties. The authorities will verify the correct application of tax treaties and EU law, and the existence of genuine beneficial owners.
Fraud Control at the Collection Stage
Control at the collection stage will be reinforced not only to ensure debt recovery, but also as a preventive mechanism influencing taxpayer behaviour.The STA will intensify efforts to detect concealed assets, interposed entities and new financial instruments, with particular focus on crypto assets and cross‑border payments. Enforcement measures will be strengthened through new procedures targeting bank accounts, point of sale (POS) terminals and trade receivables, supported by technological advances.
Actions against tax crimes, asset stripping and third‑party liability will increase, alongside the use of precautionary measures and judicial avenues, including insolvency proceedings, to secure recovery of public debt.
Inter‑Administrative Cooperation
The final pillar emphasises closer cooperation at both the domestic and international levels. The STA will continue to expand information exchange with European administrations, international organisations and other domestic authorities, strengthening efforts to combat tax fraud and recover debts.
Practical Implications for Companies and Taxpayers
Collectively, these measures confirm the consolidation of a highly specialised tax and customs control model based on international cooperation, advanced data analytics and a focus on complex, high‑risk scenarios, where formal compliance on its own may not be sufficient. Taxpayers should be prepared for:
- Increased likelihood of automated requests for information;
- Greater scrutiny of banking movements and financial transactions;
- Heightened documentary requirements for complex transactions, particularly cross‑border or intragroup transactions; and
- Reduced margin for error in tax planning and compliance.
Proactive and preventive tax management is essential for overall tax coherence, to minimise contingent risks and maintain compliance in an environment characterised by growing automation and administrative cooperation.
Jessica Kinnear
BDO in Spain