What will tax inspections be like in 2026?

The Spanish Tax Agency has published the general guidelines of the 2026 Annual Tax and Customs Control Plan, a document that sets out the priorities of the Administration in preventing and combating tax fraud during the current year.

The new plan reflects a clear trend: more information, more technology and greater scrutiny of new business models and complex corporate structures.

Below, we analyse the main areas of action that will shape tax inspections in 2026.

One of the main developments of the plan is the strengthening of the Tax Agency’s access to financial information.

From 2026 onwards, the Spanish Tax Agency will have monthly access to information relating to:

• ownership of bank accounts

• income obtained by entrepreneurs and professionals through POS terminals

• payments linked to mobile phone numbers

This flow of information will allow the Administration to detect discrepancies more quickly between declared income and actual financial flows, facilitating the monitoring of undeclared economic activities or hidden income.

Furthermore, this information will be particularly relevant in the collection phase, as it will improve the effectiveness of measures such as asset investigations or enforcement actions.

Control over crypto-assets will continue to intensify in 2026.

The Spanish Tax Agency is preparing new reporting obligations derived from the future implementation of the European DAC8 Directive, which will expand the automatic exchange of financial information between countries.

The new measures will incorporate:

• information on electronic money

• data relating to central bank digital currencies

• new reporting obligations for crypto-asset service providers

In addition, the Tax Agency will continue to use blockchain traceability tools to identify taxpayers holding undeclared assets or income in cryptocurrencies.

In 2026, an important milestone in international taxation will take place: the first receipt of information related to the global minimum tax of 15% for large corporate groups, known as Pillar 2.

The Spanish Tax Agency will receive information through new reporting obligations that will allow it to:

• analyse the effective taxation of large multinational groups

• detect potential artificial profit shifting

• ensure that large groups pay at least a minimum effective tax rate of 15%

This measure forms part of the international agreement promoted by the OECD to combat base erosion and profit shifting between jurisdictions.

The plan foresees an increase in inspection actions relating to large companies, tax groups and multinational enterprises.

The areas that will receive greater scrutiny include:

• transfer pricing

• corporate restructurings

• transactions involving intangibles

• intra-group financial transactions

• complex tax deductions and tax credits

Structures designed to shift profits abroad or artificially reduce the taxable base in Spain will also be analysed.

These actions will particularly focus on taxpayers with large transaction volumes or complex international corporate structures.

The Spanish Tax Agency will intensify its monitoring of the abusive use of companies to reduce personal taxation.

Among the practices that will be subject to special scrutiny are:

• the use of companies to pay personal expenses

• fictitious loans between companies and shareholders

• the use of high-value credit cards linked to companies

• abnormal capital transactions or concealed dividend distributions

The Tax Agency will also reinforce the analysis of discrepancies between the lifestyle of certain taxpayers and the income they declare, particularly in cases involving individuals with significant wealth.

Likewise, the Tax Agency will continue reviewing the proper application of the special tax regime for inbound workers (commonly known as the Beckham Law).

The digital economy will continue to be one of the main areas of tax control.

The Spanish Tax Agency will intensify supervision of:

• e-commerce activities

• income generated through digital platforms

• economic activities carried out by content creators and influencers

Thanks to the automatic exchange of information between countries and the data provided by digital platforms, the Tax Agency will be able to identify more easily online income that has not been properly declared.

The plan also strengthens control over the real estate sector, particularly following the recent recovery of the property market.

The actions will focus on:

• property development projects

• construction and subcontracting activities

• real estate marketing and brokerage

• the deduction of financial expenses

The Tax Agency will also pay special attention to:

• tourist rentals managed through digital platforms

• property transactions between related parties

• potential undervaluations in property transfers.

In the collection phase, the Spanish Tax Agency will develop new tools to identify debtors based on behavioural patterns and risk typologies.

Among the measures envisaged are:

• new applications for debtor selection and risk analysis

• improvements in the procedure for seizing bank and non-bank accounts

• the reinforcement of POS-based payment seizures

• the possibility of enforcement actions involving crypto-assets

The objective is to anticipate collection risks and improve the recovery of outstanding tax debts.

The 2026 Tax Control Plan confirms a clear trend: the Spanish Tax Agency will increasingly have access to more financial information, greater technological capabilities and advanced data analysis tools to detect inconsistencies between declared income, assets and standard of living.

In this context, having adequate tax advice becomes especially important in order to review the tax situation of companies and individuals, anticipate potential risks and ensure compliance with current regulations.

At ILIA ETL GLOBAL, we advise our clients in all areas of taxation, including tax advisory services and tax planning and tax optimisation, as well as in matters that are becoming increasingly relevant for the Tax Administration, such as cryptocurrency taxation or the correct declaration of assets abroad through Form 720.

We also provide specialised assistance in particularly complex situations, such as the application of the Beckham Law regime for workers relocating to Spain, the review of the Wealth Tax, or the defence of taxpayers in tax procedures and inspections.

In an environment where tax control is becoming increasingly sophisticated, anticipating and properly planning taxation becomes the best tool to avoid future risks.