Spanish Tax and Customs Audit Plan for 2026: Key Highlights

On 12 March 2026, the Spanish Official Gazette published a resolution of the Spanish Tax Administration Agency, dated 11 March 2026, approving the general guidelines of the Annual Tax and Customs Audit Plan for 2026 (the "Spanish Tax Audit Plan 2026").

This newsletter summarises the main actions envisaged under the Spanish Tax Audit Plan 2026, focusing on key novelties and areas of continued attention by the Spanish Tax Agency.

1. New areas of focus for 2026

The Spanish Tax Audit Plan 2026 introduces the following new priorities:

• Enhanced information-gathering capabilities. The Spanish Tax Agency will reinforce the information it collects — some of it on a monthly basis — concerning ownership of bank accounts, income obtained through POS (point of sale) terminals or mobile phones, e-money and central bank digital currencies. Additionally, a new tool will be created to consolidate all telephone enquiries made by taxpayers.
• Emerging sectors under scrutiny. Special attention will be paid to the digital economy, cryptocurrency, neobanks, e-commerce and influencers.
• Pillar II – Global Minimum Tax. The Spanish Tax Agency will begin collecting the information necessary to ensure that the 15% global minimum tax under Pillar II is effectively levied on large corporate groups.

2. Ongoing areas of attention

In line with previous years, the Spanish Tax Agency will continue to focus on the following areas:

• Transfer pricing. Intra-group transactions, corporate restructuring, transfer of intangible assets and services between related parties will remain a key focus.
• Corporate Income Tax. The Spanish Tax Agency will continue to scrutinise carried-forward tax losses, tax credits pending to be offset or applied, tax deductions and the participation exemption.
• Non-Resident Income Tax. Particular attention will be given to dividends, interest and royalties, with the primary objective of identifying their ultimate beneficial owner.
• VAT fraud. The Spanish Tax Agency will target intra-Community transactions and carousel fraud (particularly in the vehicle sector), as well as irregular invoicing through shell companies, unjustified refunds and misuse of reduced rates.
• Instrumental companies and tax residency. Controls will continue over the abusive use of instrumental companies and tax residency shopping among Spanish Regions and foreign countries, including the inpatriate programme.
• In-person visits. Tax inspectors will continue to carry out on-site visits to the places where economic activity is conducted.
• Third-party liability. Efforts will continue to identify third liable parties in order to initiate tax liability referral processes.
• International cooperation. The Spanish Tax Agency will continue to promote Mutual Agreement Procedures and Advance Pricing Agreements to ensure the elimination of double taxation

3. Sectors and areas of intensified attention

The Spanish Tax Audit Plan 2026 identifies the real estate sector, the mineral oil sector, customs and excise duties and environmental taxes as areas requiring intensified attention.

In particular, the real estate sector will be the focus of much Spanish Tax Agency's attention. The areas on which its investigations will centre are the following:

• Development, construction and marketing phases. Reinforced controls will be applied over the development, construction and marketing of real estate properties.
• Related-party valuations. The correct valuation of properties in transactions between related parties or within corporate structures will be closely monitored.
• Tax-driven real estate structures. Specific follow-up will be conducted on real estate corporate structures in order to detect schemes aimed at reducing tax payments.
• Financial expenses and outsourcing. The deductibility of financial expenses and the abusive use of outsourcing arrangements will be subject to further scrutiny.
• Marketing and brokerage services. Controls will extend to marketing and brokerage services related to the sale and leasing of real estate.
• Tourist apartments and seasonal leases. In-person visits will continue to detect fraudulent practices in the rental of tourist apartments and seasonal leases.
• Consolidated property-use mapping. A consolidated map will be created to track the use of real estate properties.
• Spanish REITs. Compliance with investment requirements and dividend distribution obligations by Spanish REITs will be closely monitored.

Should you need any further clarification or additional information, please do not hesitate to contact us.