Directives of the Annual Tax Control Plan

• A second phase of administrative language simplification will be launched in 2025, affecting more than four million documents per year for VAT and corporate tax verification, personal income tax penalties, and other procedures in the Revenue and Customs areas.

• The Tax Agency begins studying an AI system to anticipate citizens' need for assistance and adapt to daily demand.

• Control will be intensified on operations that conceal major changes in assets, the fraudulent use of tax advantages designed to preserve the neutrality of corporate restructurings, and the concealment of the beneficial owner of significant economic operations.

• In the area of collection, control will be anticipated and preventive monitoring of collection risks associated with tax crimes and smuggling will be carried out, while the National Bankruptcy Procedures Team is being launched to promote collection management in this area.

• Investigations into neobanks will be conducted in connection with money laundering by criminal organizations.

March 17, 2025.- The Tax Agency will boost research, analysis of asset information, and verification of individuals who show external signs of wealth that clearly differ from the income and assets they declare. This highlighted line of action is included in the general guidelines of the 2025 Tax Control Plan published today in the Official State Gazette (BOE), which also highlights the intention to progressively intensify, starting this year, the control of the most complex tax contingencies, as well as those linked to large companies, tax groups, and significant assets.

In the area of fraud investigation and control, the aim is, among other actions, to intensify surveillance of transactions that may conceal major changes in assets, the fraudulent use of tax advantages designed to preserve the neutrality of corporate restructurings, and the concealment of the beneficial owners of significant economic transactions.

Within this approach, the Tax Agency's Inspection Department includes a specific line of action for those individual taxpayers who, unlike more conventional high-net-worth assets, maintain a significant asymmetry between their actual standard of living and that reported on their tax returns.

These are very specific cases in which the taxpayer maintains a standard of living that is completely inconsistent with their declared income or known assets. To do so, these individuals exploit the abusive use of shell companies to divert personal expenses, place assets in them for their personal use, simulate leasing of goods and services, or conceal income through fictitious loans.

In these cases, the Tax Agency's oversight will focus, among other aspects, on analyzing the structures created, in order to attribute to the individuals as income the amount of all expenses and investments that, being for their exclusive enjoyment, are being declared as deductible expenses or investments of the structures they have created for fraudulent purposes.

Beyond these specific, particularly serious and complex cases, the traditional asset analysis of high-net-worth taxpayers will pay special attention to the use of companies to deduct personal expenses, as well as the free use, or at non-market prices, of company assets by the partner and their family.

Likewise, monitoring will be intensified for certain groups, such as business owners or professionals without credit card payments when credit card payments are common in their sector, or those who simulate economic activity and issue irregular invoices, as well as, especially, the recipients of these invoices, who obtain undue VAT refunds and generate fictitious expenses. The role of investors participating in associative financing structures such as economic interest groups, which channel tax benefits, will also be analyzed.

Furthermore, for non-residents, the regularization of income or profits derived from real estate and under-withholdings on the income of artists and athletes will be promoted. This year, the Agency will also begin adapting its schemes for refunding dividend withholdings for non-resident income tax (IRNR) to the Faster Directive, which includes harmonized rules for issuing and validating residence certificates and procedures for adjusting withholdings.

Submerged economy

The Tax Agency will also maintain a presence in sectors with a high risk of the underground economy, carrying out coordinated actions, among other cases, against taxpayers who use payment methods located abroad and who avoid their obligations to provide information to the Agency.

Likewise, the sector-specific visitor plans will emphasize the control of point-of-sale terminals (POS) and other billing systems, noting the upcoming implementation of new obligations regarding billing systems to prevent the use of "dual-use software."

At the same time, enforcement actions will be implemented against taxpayers who have operated with virtual currencies without declaring the income or profits derived from their possession and transfer.

E-commerce and virtual payment systems

In the area of ​​e-commerce via platforms, this year new information on cross-border payments and customs information linked to the one-stop shop system for detecting VAT underdeclarations will be available for control purposes. Furthermore, from a customs perspective, new technologies will be exploited to improve the identification of shipments with potential undervaluation of merchandise. The international information exchange "DAC7" will also promote the identification of owners and intermediaries in the tourist rental market.

Along with the platform economy, the growth of so-called "neobanks" also poses a challenge for fiscal control. This phenomenon will lead to an intensification of tax controls to prevent alternative payment methods from becoming a means of tax evasion or fraud, but it will also be analyzed from the perspective of investigating money laundering by criminal organizations.

Taxpayer assistance

In turn, the Tax Agency will begin studying a series of projects this year to use artificial intelligence (AI) to enhance the efficiency of its operations. Among them, the Control Plan guidelines indicate the possible use by the Agency of a system that, aided by AI, allows it to predict the demand for assistance that taxpayers may require, so that the provision of assistance through in-person and remote channels is as closely aligned as possible with actual daily demand.

All new AI project proposals submitted by the Agency's various departments and services will be channeled through a working group that will coordinate development requests, ensuring that they meet the criteria and priorities of the Agency's Strategic Plan for the period 2024-2027, which establishes the need for none of the projects under consideration to have AI as the final decision-making authority and for any action to be subject to human oversight.

The study of the AI system to predict demand for assistance is another element of a strategy for continuous improvement of the information and assistance model implemented at the Agency, understanding that improvements in assistance, along with those made to prevent noncompliance, allow for continued progress in promoting voluntary compliance as a key tool in the fight against fraud.

In this regard, a series of improvements have been planned, such as the implementation of same-day telephone appointments as an intermediate option between immediate assistance and appointments for the following day, and this year the creation of the new "Direct Income" option for certain taxpayers to file simple personal income tax returns in the upcoming Income Tax Campaign.

Second phase of document simplification

At the same time, a second phase of administrative language simplification will be launched in 2025, affecting more than 4.1 million documents per year, including VAT and corporate tax verification, personal income tax penalties, and other procedures in the Revenue and Customs departments. This expands the language clarification process, which began in 2023, to include new procedures and processes, with more than 3.7 million documents amended annually.

Work will also be done to convert the "Census Informer" into a "Virtual Census Assistant" and to launch "Web Census," a service that will make it easier for taxpayers to register activities and fulfill their other census obligations with assistance.

This year, Bizum payments will also be gradually accepted, including in the context of telephone and in-person assistance, and credit or debit card payment options will be expanded under secure e-commerce conditions, generally allowing payments using these systems.

Correction of errors

Among the planned new developments in fraud prevention are the increase in the number of cases for which personal income tax taxpayers will be able to self-correct potential errors or omissions through a supplementary return pre-calculated by the Agency, and the advance to April of the notifications that have been sent to potential non-filers who are required to file a return.

Progress will also be made in the transparency of tax data, including by making relevant information available to taxpayers for possible corrections to previously filed VAT returns, taking advantage of the Income Tax and Corporate Tax return campaigns, when third-party information that was unavailable when the indirect tax was declared is available.

Collection control

In the area of tax collection, control will be anticipated and preventive monitoring will be carried out on the collection risk associated with tax crimes and smuggling due to concealment of assets or income. The seizure procedures will also be updated to establish rules for frequency and processing that are more streamlined and in line with the immediacy required by these procedures. Furthermore, with the launch of the National Bankruptcy Proceedings Team, debt collection management and the detection of fraudulent bankruptcies will be promoted.

Likewise, a debtor analysis will be conducted, with special attention to asset stripping to feign insolvency, the use of "safe haven companies," the existence of foreign ties, or the construction of corporate networks under a single control for the provision of fictitious services by other entities in the same group.

Organized crime

Regarding the Customs Surveillance Service's activities, in addition to the usual fight against cocaine and hashish trafficking, and tobacco smuggling, AI projects will be developed during 2025 to meet operational and research needs, while also participating in European projects with AI functionalities to support risk detection and analysis.