{"id":19479,"date":"2026-05-05T15:03:11","date_gmt":"2026-05-05T15:03:11","guid":{"rendered":"https:\/\/seegman.com\/tax-control-plan-2026-key-areas-of-inspection-and-practical-insights\/"},"modified":"2026-05-05T15:03:12","modified_gmt":"2026-05-05T15:03:12","slug":"tax-control-plan-2026-key-areas-of-inspection-and-practical-insights","status":"publish","type":"post","link":"https:\/\/seegman.com\/en\/tax-control-plan-2026-key-areas-of-inspection-and-practical-insights\/","title":{"rendered":"Tax Control Plan 2026: key areas of inspection and practical insights"},"content":{"rendered":"\t\t
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Tax Control Plan 2026: key areas of inspection and practical insights<\/h1>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/section>\n\t\t\t\t
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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 tax fraud.<\/p>\n

In this article, we analyse the most relevant inspection focus areas for 2026 and their practical implications for both companies and taxpayers, with a view to anticipating risks and strengthening tax positions.<\/p>\n\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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Tax Control Plan 2026: what the Tax Authorities are focusing on<\/strong><\/h2>\n

The different Spanish tax administrations \u2014state, regional and local\u2014 publish annually their priority areas of action. At the state level, the Spanish Tax Agency approved, by Resolution of 11 March 2026, the general guidelines of the 2026 Annual Tax and Customs Control Plan.<\/p>\n

These guidelines provide a fairly accurate indication of the areas that will be subject to increased scrutiny and audit activity in practice.<\/p>\n

Main areas of inspection for companies<\/strong><\/h2>\n

In the corporate sphere, the Tax Authorities are focusing on several key areas.<\/p>\n

On the one hand, there is increased scrutiny of companies with high turnover, as well as complex structures that may give rise to significant tax risks.<\/p>\n

Particular attention is also paid to the improper application of special tax regimes, especially the regime for mergers, spin-offs, contributions of assets and share exchanges (the FEAC regime or tax neutrality regime), where the Tax Authorities aim to identify transactions lacking valid economic reasons.<\/p>\n

In this context, the analysis of certain corporate restructuring transactions becomes particularly relevant, especially where corporate structures may be used for tax purposes not aligned with the intent of the law.<\/p>\n

The Tax Authorities are also reinforcing the monitoring of the correct application of the participation exemption for dividends and capital gains (Article 21 of the Corporate Income Tax Law), as well as focusing on sectors considered higher risk, such as e-commerce, real estate and construction.<\/p>\n

Areas of control for individuals<\/strong><\/h2>\n

In the case of individuals, the focus is placed on situations where there are indications of aggressive tax planning or inconsistencies in reported taxation.<\/p>\n

Particular attention is paid to the use of shell or instrumental companies to channel income or cover personal expenses, a practice that is increasingly being scrutinised by the Tax Authorities.<\/p>\n

In these cases, it is especially relevant to properly assess the taxpayer\u2019s position from both a legal and social security perspective, as analysed in our article on the classification of shareholders and directors for Social Security purposes.<\/a><\/p>\n

Furthermore, increased scrutiny is being applied to taxpayers where there are discrepancies between their standard of living and the income or assets declared, as well as situations involving hidden income or the diversion of assets for personal use.<\/p>\n

Another particularly sensitive area concerns changes in tax residence, especially where individuals relocate to a different Autonomous Community without a genuine change in their centre of economic interests, while maintaining their corporate environment in the original region.<\/p>\n

Special focus: Beckham regime<\/strong><\/h2>\n

One of the priority areas of the 2026 Plan is the monitoring of the correct application of the special tax regime applicable to inbound workers in Spain (the so-called Beckham Law).<\/p>\n

The Tax Authorities expressly warn of abusive use of this regime in recent years, particularly in cases where essential requirements are not met, such as:<\/p>\n