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The Tax Agency regularised tax bases for 5,578 million, 81% more, in 112 checks on the international taxation of large multinational companies.

2021 balance sheet of tax control results

  • 540 million euros, 23.6% more, were paid to high net worth taxpayers in a total of 1,165 cases (+57%).
  • The tool based on 'big data' analysis for the detection of false non-residents with relevant assets has already led to the liquidation of 24.5 million to 69 taxpayers who were artificially located in almost thirty countries.
  • 36,600 control actions have been carried out on large companies, assets, corporate abuses and the underground economy, a 23.8% increase.
  • In 2021, the Tax Agency has obtained 14,956 million in homogeneous terms (16,896 million in total) as a result of its control work, 17% more, and has reduced negative bases, deductions pending application and quotas to be offset with an impact of 5,000 million, 56% of which corresponds to actions by the Central Delegation of Large Taxpayers.

21 July 2022.- Last year, the Tax Agency regularised taxable bases amounting to 5,578 million euros in a total of 112 tax audits on the international taxation of large multinational companies carried out by the Central Delegation of Large Taxpayers and the other delegations of the Agency with the support of the National Office of International Taxation (ONFI).

The amount of these regularised tax bases, 81.3% higher than in 2020, includes a large file that conditions the year-on-year comparison, although, even excluding it, the amount of the regularisations would still be more than 35% higher than in 2020.In turn, ONFI participated in 2021 in the management of 28 Preliminary Valuation Agreements (APAs) with an estimatory result, which means guaranteeing future taxable bases for an amount of more than 3,000 million euros.

Control actions above pre-pandemic levels

These results form part of all the control activity carried out by the Tax Agency in 2021, which concluded with 1,795,000 actions, 10.4% more than the previous year and 7.9% more than in 2019, also exceeding pre-pandemic levels in practically all the major types of actions.

Of this total, 36,599 control actions were carried out in relation to large companies and estates, corporate abuses and the underground economy, 23.8% more than last year.These are resource-intensive actions, characterised, moreover, by their high level of qualification.

Specifically, 26,989 actions were carried out on large companies, multinationals and corporate groups, an increase of 24.2%;2,899 for equity and corporate analysis (+38.2%);5,317 in relation to concealment of activity and abuse of corporate forms (+22.3%).The figure of 26,989 verifications is completed by 1,394 actions that have brought to light hidden sales within the framework of the control of economic activities (the rest of the actions to uncover sales are already included in the two previous headings).

Recovery and reduction of bases

In overall collection terms, and as a result of its work in the prevention and fight against fraud, in 2021 the Agency obtained a homogeneous result of 14,956 million euros (16,896 million euros in total), 17% more than the previous year.These results do not include the reduction of instalments (1,940 million euros in 2021 and 4,487 million euros in 2020), which will be difficult to repeat in the future and therefore prevent a homogeneous comparison of the series.

9,037 million in direct revenues, 11.7% more than the previous year;5,164 million for the reduction of refunds (not counting instalment payment files), an increase of 28.4%;755 million, an increase of 11.5%, and induced revenue (extemporaneous declarations without prior request).

The Tax Agency also made reductions in negative tax bases, deductions in tax liability pending application and amounts to be offset, with an effect in terms of an increase in tax liability of almost 5,000 million euros, 56% of which corresponded to actions by the Central Delegation of Large Taxpayers.

These are very important actions which, although they do not count in the control results, as they do not imply income or a reduction in refunds, are of great importance in widening future tax bases and increasing tax collection.

High net worth and bogus non-residents

Last year, the Tax Agency once again increased the number of control actions on the large estates of individuals deployed by the different delegations, with a total of 1,165 actions in relation to large fortunes, 57% more than in the previous year, which led to the settlement of debts amounting to 540 million, 23.6% more.From 2018 - the year of the creation of the Central Unit for the Coordination of the Control of Relevant Assets - until 2021, more than 1.9 billion in more than 3,200 verification files have been settled in this area.

However, in addition to supporting the large fortune settlements carried out in each territorial area of the Agency, the Unit has promoted various projects to further strengthen and update the control systems in this field.The most innovative of these, implemented two years ago, is the incorporation of a tool based on 'big data' analysis for the detection of false non-residents with relevant assets.

In 2021, the checks initiated have already been extended to 223 taxpayers (there were 126 in 2020), and of these, proceedings have been finalised for a total settled amount of €24.5 million on 69 taxpayers who were artificially located in almost thirty countries and for whom it has been determined that they actually had effective residence in Spain.

The relevance of external information

In recent years, the Agency's various delegations have seen their capacity for action on undeclared income strengthened by successive European directives on automatic exchange of information, standardised OECD mechanisms and other agreements.

Last year, the inspection control over taxpayers for whom information on financial accounts abroad has been received through the European 'DAC2' directive, the OECD CRS standard and the 'Fatca' agreement with the US allowed for the settlement of 132 million euros to 382 taxpayers, so that since 2017, the year in which this information began to be received, the Agency's Inspection area has already settled 762 million euros to 2,280 taxpayers.

At the same time, last year these inspection actions continued to be complemented with controls on income reported through a previous European directive, the so-called 'DAC1', information that the Agency has also been using to encourage voluntary compliance in the personal income tax return campaign through the 'warnings' in tax data.

In this phase of management verification, the actions carried out have generated settlements by the Tax Agency and extemporaneous taxpayer returns for a combined amount of 51 million euros through more than 43,000 files, so that the accumulated figures for the three-year period 2019-2021 in which this information has been used extensively now total more than 150 million euros and more than 84,000 files.

Also with a view to uncovering funds hidden abroad, the information gathered by the National Fraud Investigation Office, the ONIF, on the use of cards issued abroad ('offshore cards') has enabled the Agency's various territorial units to settle debts amounting to 79 million euros last year, while files were registered affecting 43 taxpayers with 'offshore' cards, which will provide additional results in the future.

Shadow economy

In parallel to all the above actions, the Agency has continued its control activity in the past year in order to uncover hidden economic activity.Thus, in 2021, it carried out more than 2,200 inspections under different verification programmes (the aforementioned 1,394 in the area of control of economic activities and the rest in other programmes) in which it discovered hidden sales, regularising quotas amounting to 400 million euros.

173 million in almost 3,000 taxpayers who had previously been subject to entry and search procedures with the support of the IT Audit Units (UAI).These units were involved in more than 1,200 computer dumps last year, which facilitate the discovery of hidden income, improve the gathering of evidence and reduce the duration of checks.

Also of particular relevance in the fight against undeclared activity is the control of undeclared rentals, where the induced effect of sending tax information notices to alleged landlords during the latest income tax campaigns continues to stand out.

Taking into account both the full effect in the initial year of each notice and the marginal impact in each year of the previous campaigns, in the last six years these notices have led to the incorporation of more than one million returns that include income from real estate capital, with a higher tax base declared of more than 7,100 million euros and a collection associated with these campaigns of more than 860 million euros.

Collection control

In the area of the control necessary to secure the collection of debts, the Agency's Collection Department has continued to promote the most qualified actions to achieve the effective collection of settlements and to fight fraud in the collection phase.Of particular note is the new strong growth (78.9%) in the number of legal actions (1,036) brought last year to recover debts.These actions, which have already grown by almost 150% compared to the figures for 2019, and especially criminal actions, judicialise the demand for recovery in particularly serious situations of apparent insolvency, fraud and, in general, complex concealment practices.

There were also 29,078 liability referrals, 8.7% more than in the previous year and 23.5% more than in 2019;and 5,049 precautionary measures have been taken, including 1,208 agreements to prohibit the disposal of real estate belonging to companies whose shares or stocks have been mostly seized because they belong to a debtor.The latter actions, which are essential to avoid asset stripping, are 84.4% higher than in 2020 and 240% higher in three years.

Asset investigations continued to increase in 2021, with more than 88,500 investigation files on financial movements, 22.2% more than in 2021 and already four times the levels of the middle of the last decade.These actions are aimed at the use of various fraudulent schemes, such as the use of companies or front men.Meanwhile, requests for information or seizure from foreign authorities for debt collection grew by 15.4% with respect to 2021, with a total of 1,964 requests, and by 152% in four years.

Fight against smuggling

During the past year, the usual tasks of control of excise and environmental taxes, customs control and in the field of smuggling, drug trafficking, money laundering and other economic crimes were also carried out.In the area of smuggling, 31.3 tonnes of cocaine and 167 tonnes of hashish were seized, 2.8 million cigarette packets and 80 tonnes of tobacco and other tobacco products were seized, while almost 2.2 million counterfeit products were seized.

At the same time, the Tax Agency has maintained its usual activity of collaboration with the justice system and with other administrations at national and international level, and fraud prevention has been promoted through the information and assistance tools and the cooperative forums in which the Agency participates.