
Tax Control Plan 2026: key areas of inspection and practical insights
The Annual Tax Control Plan sets out each year the main lines of action of the Spanish Tax Authorities in the prevention and fight against
In a Resolution dated May 12th, 2023, the TEAR upheld the claim filed against the provisional ISD liquidation of the Community of Madrid, determined by the DGT of the Community of Madrid, which denied the application of the 99% tax credit, based on the fact that the donation documented before a French Notary Public and duly apostilled, would not be considered as a public document, a requirement established by article 3.five.2 of Law 4/2006, of December 22nd, 2006, on Tax and Administrative Measures.
On the contrary, the TEAR appreciates that those formalized before a foreign Notary cannot be excluded from the consideration of public documents, as long as they comply with the notarial legislation of the corresponding State, together with the fact that the apostille of the document has recognized the condition of “public document”, thus confirming its documentary cate gory.
The TEAR also ratifies that the only requirement demanded by Article 25.2 of Legislative Decree 1/2010, of October 21st, consists of the mere formalization of the donation by means of a public document, so that the granting of a notarial deed of donation itself cannot be considered essential.

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This article analyses the evolution of restructuring plans in Spain since their introduction by Law 16/2022 through to their practical consolidation in 2026, with particular

Executive summary Supreme Court ruling STS 440/2026 (20 March 2026) establishes, for the first time, a clear criterion for a very common issue in private
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