2024 Balance of Tax Control Results

• The reduction of 5.3 billion euros in undue negative tax bases, deductions and offsets will increase future revenue collection.

• Debt amounting to 524 million euros has been settled in 1,264 audits carried out on large estates.

• €800 million in tax bases secured through Advance Valuation Agreements on the international taxation of multinationals, a 6.1% increase.

• The Inspection Department has liquidated 315 million euros, 25.5% more, to taxpayers from whom it has obtained information about their foreign accounts.

• International collection requests from foreign authorities have increased by 50%.

September 18, 2025.- Last year, the Tax Agency reduced tax losses, outstanding deductions, and incorrect tax offsets by €5.305 billion, 58% more than the previous year. Of all these actions, which are highly significant for broadening future tax bases and increasing revenue collection, two-thirds were carried out by the Central Delegation for Large Taxpayers.

This work is part of the overall control activity carried out by the Tax Agency last year in the Management, Inspection, Collection and Customs Areas, which concluded with €18.928 billion in revenue linked to the prevention and fight against fraud (13% more than the previous year); 4.3% more discounted extraordinary files of fractional payments).

Among the control results, the 9.4% growth recorded in direct revenue from control actions stands out, which totaled 10.318 billion euros, in addition to 7.554 billion euros from refund reductions and 1.056 billion euros in revenue from late declarations.

These results follow more than 1,981,000 internal tax audits, a 4.4% increase over the previous year. Within this overall range of actions, the Tax Agency carried out 46,407 audits related to large companies, assets, abuse of corporate forms, and the fight against the underground economy, a 6.3% increase over the previous year.

Among these notable actions, which consume a large amount of highly qualified resources, 36,918 actions were carried out on multinationals, corporate groups and companies with an annual turnover exceeding six million euros (+7%), 3,101 related to asset and corporate analysis (-4.8%), 4,402 related to abuse of corporate forms and concealment of activity (+5.9%) and 1,986 related to hidden sales discovered in economic activities (+15.7%).

Great estates

Last year, the Agency, through its various branches, carried out 1,264 audits on large-net-worth individuals, resulting in debt settlements totaling €524 million.

In addition to supporting these settlements, the Central Coordination Unit for the Control of Relevant Assets is promoting projects to further strengthen and update control in this area, including the tool to assist in the detection of false non-residents with significant assets, which in 2024 facilitated the settlement of €51 million, 84% more than the previous year, for 127 taxpayers artificially located in other countries, and for whom it has been determined that they were actually effective residents in Spain.

Control of multinationals

In turn, last year the National Office of International Taxation (ONFI) participated in the management of 48 Advance Valuation Agreements (APAs) with an estimated result in international taxation of multinationals, guaranteeing future tax bases estimated at €3.797 billion, 6.1% more than the previous year and 40% more than in 2022.

Also in the area of international taxation of large multinational companies, the Tax Agency regularized tax bases in 2024 amounting to €2.712 billion in a total of 88 inspections carried out by the Central Delegation for Large Taxpayers and the Agency's other Delegations, with the support, where appropriate, of the National Taxpayer Institute (ONFI).

Information from abroad and research

Regarding the inspection control of taxpayers from whom information on financial accounts abroad has been received through the European DAC2 directive, the OECD CRS standard and the Fatca agreement with the United States, last year 315 million euros (25.5% more) were settled from 727 taxpayers. Since 2017, the year in which this information began to be received, the Agency's Inspection area has already settled more than 1.5 billion euros from more than 4,000 taxpayers.

Furthermore, within the annual activity of the National Fraud Investigation Office (ONIF) of the Inspection Department, the preparation of FITT (Tax Information Sheets) stands out, which the Office forwards to the various Tax Agency branches for the possible regularization of tax contingencies.

Last year, the ONIF submitted 411 FITT forms for analysis on more than 1,200 taxpayers. Those submitted in recent years enabled the Agency's offices to settle a total of €315 million for 346 taxpayers in 2024. In addition, 57 taxpayers filed 103 induced returns for a total of €13 million.

Emergence of the underground economy

Within the control section dedicated to uncovering hidden economic activity, the Agency carried out 2,581 inspections last year under various verification programs (the aforementioned 1,986 in the control of economic activities, and the rest in other programs) in which it discovered hidden sales, 11% more than the previous year, regularizing quotas totaling €431 million.

Fees and penalties totaling €140 million were also settled against 1,488 taxpayers (a 20.7% increase) who had previously been subject to inspection and registration procedures with the support of the Computer Audit Units (UAIs). Last year, these units participated in more than 1,600 operations with computer dumps, which facilitate the discovery of hidden income, improve the collection of evidence, and reduce the duration of investigations.

Inspections in the field of combating the black economy are complemented by the plan of visits. In 2024, the Agency carried out more than 31,500 in-person inspections (a 6.5% increase) for on-site monitoring in sectors and areas of tax risk.

These actions include more than 2,500 carried out within the framework of monitoring irregular invoicing to verify the existence or not of an economic activity likely to generate a VAT refund request. In addition to suspending refunds in these cases, the case of more than 300 taxpayers with particularly complex profiles due to their involvement in VAT schemes is being analyzed.

Induced effect in extensive control

From the perspective of extensive control, on the other hand, the Agency's Tax Management Area has begun to analyze the induced effects of certain actions, specifically on the deduction for investment in primary residence, imputation of real estate income, reductions in net income from real estate capital, expenses from economic activities and VAT deductible expenses. According to the analysis, after being subjected to extensive audits in these matters, more than 144,000 taxpayers increased the amounts reported in subsequent tax returns, increasing their tax liability by €457 million as a result of the initial audit.

Collection control

And, regarding control during the collection phase, this year again, international requests to third countries have significantly increased, both for information and for the seizure of assets and the adoption of precautionary measures. With the support of the National International Collection Team, 4,250 requests of this nature have been made, 50.2% more than in 2023 and 135% more than in 2022.

Also noteworthy is the new growth (+9.3% year-on-year) in the number of in-person visits by the Collection Department last year. 17,815 appearances have been made to carry out enforcement actions and obtain information on debtors. In addition, 1,507 civil and criminal legal actions have been taken to secure debt collection, and more than 65,300 investigations into financial transactions have been conducted.

This complements the usual measures to secure collection, which represent the derivations of liability (40,580 in 2024) and the precautionary measures (4,014), two tools, derivations and precautionary measures, which have allowed the collection of debt amounting to 550 million euros.

Fight against drug trafficking and smuggling

During the past year, the usual tasks of controlling special and environmental taxes, customs control and in the area of smuggling, drug trafficking, money laundering and other economic crimes were also carried out. The seizure of 79 tons of cocaine stands out, with 522 arrests; 84 tons of hashish, with 523 arrests; 2.6 million packs and 46 tons of cut tobacco and other tobacco products; and the seizure of 1.3 million counterfeit products.

Throughout 2024, the Tax Agency has maintained its usual collaboration with the justice system and other national and international administrations, and has promoted fraud prevention through information and assistance tools and cooperative forums in which the Agency participates.