2026 Annual Tax and Customs Control Plan: Key Issues and Risk Areas for Taxpayers

On 12 March 2026, the Resolution of the Directorate General of the Spanish State Tax Administration Agency (AEAT) approving the general guidelines of the 2026 Annual Tax and Customs Control Plan was published in the Official State Gazette (Boletín Oficial del Estado).

The Plan sets out the AEAT's priorities in terms of information and assistance, prevention of non-compliance, and control and investigation of tax and customs fraud for the current fiscal year.

The Plan consolidates trends already observed in previous years, but incorporates a significant reinforcement in the use of monthly financial information, intensified sector-specific controls, and actions targeting complex structures, with a direct impact on companies, multinational groups, significant estates, and non-resident taxpayers with interests in Spain.

From a practical standpoint, the Plan anticipates a greater capacity for early risk detection, a tightening of controls over certain tax planning arrangements, and a more intensive use of coordinated actions and precautionary measures, which reinforces the importance of preventive review of tax positions and an appropriate tax dispute management strategy.
Below, we highlight the most relevant aspects and the practical implications arising from the Plan for taxpayers.