Tax Control Plan 2026: AEAT priorities, tax risks and new compliance obligations
Tax control in 2026: key insights for businesses operating in Spain
On March 12, the Annual Tax and Customs Control Plan 2026 was published, setting out the main priorities of the Spanish Tax Authorities (AEAT). It confirms a shift toward a more intensive, digitalized and proactive tax control model.
While not a break from previous years, it reinforces trends such as greater data availability and enhanced control of complex structures, increasing tax exposure.
The Plan is structured around five pillars: assistance, prevention, investigation, collection control and inter-administrative cooperation.
Data as a key control tool
A major change is the availability of extensive financial data collected on a regular basis, including bank accounts, POS transactions and digital payments.
Advanced analytics will strengthen the consistency between declared data and economic reality.
International taxation and large companies
The AEAT will intensify control over multinational groups and transfer pricing, as well as intra-group transactions and financing.
The implementation of the global minimum tax (Pillar 2) begins, alongside stronger international cooperation.
High-net-worth individuals and corporate structures
The Plan increases scrutiny on high-net-worth individuals and discrepancies between lifestyle and reported income, as well as misuse of corporate structures.
Digital economy
Activities involving crypto-assets, digital platforms and neobanks will remain under close monitoring, supported by blockchain traceability tools.
Real estate sector
The real estate sector will be closely monitored, particularly regarding valuation, cost deductibility and rental income control.
VAT, non-residents and compliance obligations
There will be continued focus on VAT fraud and cross-border transactions, as well as payments to non-residents.
Projects such as mandatory e-invoicing and VERI*FACTU systems will require technical adaptations.
Enhanced collection phase control
The Plan strengthens tax collection controls through risk analysis and digital tools, including debtor classification and asset tracking.
The Tax Control Plan 2026 confirms a more demanding tax environment. Companies should anticipate risks, review tax consistency and adapt internal systems to new requirements.
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