Guidelines of the Annual Tax Control Plan 2026

• Fraud control and prevention will be strengthened in all business areas of the real estate sector.

• To prevent a shift of fraud in the hydrocarbon sector, increased monitoring of the operation of tax warehouses is planned.

• The control of irregular billing schemes will be intensified with advanced computer tools capable of detecting the entire fraud chain.

• Extensive enforcement will intensify the actions of teams specializing in the control of economic activities, while continuing to promote voluntary compliance for less serious issues.

• In terms of assistance, new improvements will be made to 'Web Censuses' and the payment of debts by card will be facilitated also in the offices of the Tax Agency itself.

• Customs reaffirms its commitment to the control and security of the port logistics chain

March 12, 2026. This year, the Spanish Tax Agency will leverage the full potential of the new financial information available to strengthen its control over digital business, hidden income and assets, and the fight against the underground economy. In addition to the information already available from payment service providers on cross-border payments, and that submitted by e-commerce platforms under the DAC7 directive, new information returns for the financial sector will now be added, enriching the data on economic flows available to uncover tax fraud in a wide variety of areas, from e-commerce to the concealment of collections and payments through the 'neobank' circuit.

These priority areas of action are included in the general guidelines of the 2026 Tax Control Plan published today in the Official State Gazette (BOE), which also plans to continue promoting the fight against tax fraud by companies with high turnover figures and individuals with significant assets, while strengthening the control and prevention of fraud in all business areas of the real estate and construction sector.

In turn, in the area of ​​extensive control, actions carried out by teams specializing in the control of economic activities will be intensified, while the milder problems will continue to be addressed from a perspective of prevention and promotion of voluntary compliance.

The role of new financial information

Starting this year, the new financial reporting forms will provide advantages for fraud control, as well as for taxpayer assistance. Regarding the fight against fraud, obtaining monthly information on card payments will improve the control of possible concealment of business or professional activities, and obtaining monthly information on financial ownership will facilitate the early detection of the use of shell companies and other types of instrumental entities used within the framework of VAT schemes.

At the same time, having information on monthly payments and all types of financial accounts and cards will enhance the assessment of collection risk and the investigation of financial flows, as well as the effective adoption of precautionary measures and seizures of accounts and POS terminals. It will also improve the fight against fraud in the enforcement phase, by expanding the capabilities to detect possible asset stripping and facts that lead to raising tax liability issues.

From an assistance standpoint, having up-to-date bank account information will make it easier for taxpayers to process their tax obligations, and prevent the Tax Administration from making payments and refunds to accounts that have been cancelled or whose ownership has changed. It will also allow for increased effectiveness in verifying the identity of taxpayers who do not have other means of authentication, such as Cl@ve, in which the bank account number is used as an additional element of identity verification.

Neobanking and e-commerce

This new financial information, added to the recently incorporated information on cross-border payments, will also boost control over the use of accounts in digital financial entities ('neobanks') to hide income or assets abroad. The checks will be focused on those taxpayers in whom misuse of 'neobank' accounts is detected to hide income or assets abroad.

And the financial information will be added to that submitted by online sales platforms through, among other sources, DAC7, to continue advancing in the control of electronic commerce, which is again this year a priority target of control tasks, both in terms of the sale of goods and the provision of services.

Among other things, verification actions will be carried out on entities formally established in Spain or in another Member State with the aim of appearing to be actually established in the EU in order to modify the form of VAT taxation of e-commerce sales carried out through platforms, thus trying to avoid paying the tax. In turn, one of the profiles that may give rise to coordinated inspection actions will be that of taxpayers who They declare that they are established in the EU to apply the one-stop shop system, and yet they do not have the means to operate in the EU.

We will also continue to delve deeper into the analysis and verification of the correct taxation of content creators on social media, including the analysis of the tax residency of those who participate in these new forms of business.

In the area of ​​Customs and Excise, control over e-commerce operations will be strengthened as a result of the elimination of the €150 customs duty exemption.

Furthermore, in 2026, efforts will be made to carry out control measures on taxpayers who, having operated with virtual currencies, have not declared income or capital gains derived from their possession and transfer. In this context, the exploitation of available information will be intensified, as well as the analysis of risk profiles, through the use of traceability tools in blockchain, in order to detect taxpayers with indications of unjustified assets or undeclared income.

A comprehensive strengthening of control in the real estate business

In 2026, the Tax Agency will strengthen its actions to control and prevent fraud in the various business areas of the real estate sector, in a context of takeoff in this market after years of slowdown, and of new manifestations in the business model in which it develops, encompassing the phases of promotion, construction, marketing and intermediation.

Potential risks characteristic of the sector will be subject to detailed control, such as the improper deduction of financial expenses or the abusive use of subcontracts, while relevant attention will also be paid to the marketing and intermediation in the sale and rental of real estate.

The Agency will also pay attention to the correct valuation of properties in transfers, especially when related entities or corporate structures are involved. Furthermore, controls on compliance with the requirements of the regulations will be strengthened, especially in complex operations involving the promotion, rehabilitation and successive transfer of real estate.

On the other hand, specific monitoring will be carried out on business, corporate and asset structures that may be used in the real estate sector, in order to identify schemes designed to reduce the tax burden.

Furthermore, in the area of ​​rentals, actions will be intensified to verify the correct declaration of income obtained, with special attention to rentals managed through digital platforms, and special emphasis will continue to be placed on the various operators in the tourist rental market through platforms. Special attention will also be paid to the intermediation sector to ensure that the commission system on which it is based is properly reflected in tax returns.

At the same time, one objective of the formal verification visit plans will be to identify undeclared residential property leases for uses other than housing, or leases declared as housing leases. The aim is to detect irregularities in the rental of tourist apartments and seasonal leases.

Similarly, controls on publicly traded real estate investment trusts (Real Estate Investment Trusts) will continue to be intensified, given their special tax regime and their relevance in the real estate market, and the correct taxation of capital gains derived from real estate obtained by non-residents will be monitored.

On the other hand, non-resident individuals who own assets in Spain, directly or indirectly through shares in entities, represent an increasingly large group. Consequently, control actions will be carried out regarding the Wealth Tax due to the real obligation to contribute and the Non-Resident Income Tax.

Hydrocarbons sector

Furthermore, formal checks will be intensified in order to verify that all taxpayers who have accessed the Register of Tax Deposit Extractors in VAT continue to meet the requirements to remain in the Redef.

In parallel, and following the administrative actions and regulatory measures implemented in the hydrocarbon sector, which have led to a considerable reduction in VAT fraud in this area, it is planned to increase the monitoring of the operation of tax warehouses and tighten the conditions for being the owner of a tax warehouse in order to prevent fraud from shifting towards this figure.

Underground economy and irregular invoicing

In turn, the Agency will maintain its presence in sectors and business models where there is a high risk of the existence of an underground economy. In this area, coordinated actions have been and will continue to be an important tool in the fight against tax fraud.

Sectoral visit plans will continue, targeting business and professional activities, with a strong focus on census and formal review, which will again emphasize the control of POS terminals and the non-acceptance of card payments. Similarly, in 2026, formal checks will be intensified to identify taxpayers who may be pretending to carry out an economic activity.

Efforts will also be focused on all operators who receive irregular billing with the aim of significantly reducing their tax burden. With the support of advanced computer tools capable of detecting the entire chain of fraud involving irregular invoices, efforts will continue to focus on detecting companies lacking structure and real economic activity, as well as those that are practically inactive, which issue irregular invoices that do not correspond to the reality of a delivery of goods or a service provided with the sole purpose of simulating an apparent activity in order to obtain a refund, allow undue deductions of fees or record fictitious expenses.

Similarly, actions will be intensified to prevent VAT refunds to taxpayers who feign carrying out an economic activity, and to prevent abuses in the recovery of fictitious or non-deductible input VAT, declarations with requests for small amount refunds made by companies with a common link will be monitored.

Multinationals, corporate groups and large fortunes

In the area of ​​multinational control, controls will be intensified in areas where risks of applying tax regulations beyond a reasonable interpretation are concentrated.

Regarding corporate groups, special attention will be given to tax groups in which the entities that make them up have a strikingly low net turnover, especially when it is observed that there is no commercial logic for the formation of these groups, or there are no transactions between the entities that make them up. Similarly, artificial structures designed to achieve undue tax relief through the exemption for dividends and capital gains in Corporate Income Tax will be monitored.

For its part, a key focus in 2026 will continue to be the control of large fortunes, especially the monitoring of external signs of wealth and standard of living that are inconsistent with declared income and assets, as well as the use of shell companies to avoid or minimize personal taxation. Also noteworthy are the actions concerning false non-residents and those related to the regime for expatriates, and changes of tax domicile of individuals whose corporate environment remains in the autonomous community of origin will also be monitored with special intensity.

Information, assistance and prevention

The Control Plan guidelines also dedicate a significant portion of their content to highlighting the progress in information, assistance and fraud prevention planned for this year. In 2026, the conversion of Information Officers into Virtual Assistants will continue to be promoted to facilitate taxpayers obtaining quick answers to their questions. Specifically, the conversion of the Non-Resident Income Tax Reporter will be carried out. The Export Information Tool will also be launched, a new virtual tool designed to offer comprehensive information support regarding export operations and the exit of goods from the EU customs territory.

In the census field, improvements to 'Web Censuses' will continue to be made to expand its use to a greater number of procedures. Following the launch last year of this tool that assists entrepreneurs in registering activities and census obligations, this year the service will be extended to certain census modifications. In turn, taxpayers who, according to the information contained in the Agency's database, have not communicated their current tax address, will be sent a communication informing them of the discrepancy detected and the possibility of correcting it through 'Web Censuses'.

Furthermore, the information and assistance model will be strengthened to ensure omnichannel access by interconnecting the different channels into a single tool that allows obtaining the history of taxpayer services. Staff will also be added to provide services exclusively in the information and assistance model, both in person at the offices and through telephone service, and same-day appointments will be implemented, allowing taxpayers to obtain an appointment on the same day of the request, provided there is availability in the requested service.

Regarding the available payment methods for settling debts, this year taxpayers will have the option of paying by card at the Tax Agency offices and by phone, thus completing a wide range of payment possibilities, since currently it is already possible to pay by direct debit, Bizum or card through the electronic office and the app, and by direct debit and Bizum at the offices and by phone.

Fraud in the collection phase

In the section on fraud control in the collection phase, and as a result of the improvements developed in the selection of debtors, in 2026 specific investigation programs will be developed based on the concurrence of certain fraudulent behaviors of concealing assets, especially the use of safe haven companies, placement of wealth in new financial instruments and networks of companies under the same control in order to carry out asset stripping through the provision of fictitious services by other entities of the group.

The system for the seizure of commercial and lease credits will also be improved to achieve greater efficiency in collection actions, reduce the administrative burdens that responding to and complying with seizure proceedings entail for paying entities, and avoid a possible excess in obstacles that harms debtors.

Customs control and the fight against organized crime

In the area of ​​customs control, the commitment to the development of the European Ports Alliance initiative of the European Commission continues, a major cooperation platform between EU customs authorities that focuses on the control and security of the port logistics chain, the security of containers and protection against risks associated with the digitalization of customs processes.

In the maritime field, and in coordination with other European agencies, the action will be geared towards the detection of new threats such as the use of naval drones, 'narco-submarines' and unmanned vessels, the concealment of drugs and tobacco in refrigerated containers, the digital manipulation of port documentation and the use of mother ships on the high seas. This collaborative framework will allow for anticipating risks, improving target selection, and strengthening joint operations in a key area for customs security and the fight against organized crime.

In turn, the Tax Agency will continue to apply specific measures in the Campo de Gibraltar, in close coordination with the new Special Security Plan against drug trafficking in the area, also considering the growing violence of the organizations, the use of high-speed inflatable and semi-rigid boats and drones.

In the Customs Area, surveillance will also be extended to products such as electronic cigarettes, refill liquids and heated tobacco, which already have regulations that are equivalent to those of traditional tobacco, with a ban on flavors other than tobacco, special tax and the relevant health warnings.