AEAT 2026 Tax Control Plan: Risk Areas and What Companies Should Review

Key data

The AEAT has already marked its objectives for 2026. The Resolution of 11 March 2026 approved the guidelines of the Annual Tax and Customs Control Plan, and the correction of errors published on 24 April 2026 (reference BOE-A-2026-9016) adjusts formal aspects without modifying the substance. What matters in practical terms is what was already approved: four lines of inspection action that define where the Tax Agency will focus this year.

For a CFO, tax advisor or executive, knowing these guidelines is not an academic matter. It is a risk management tool: knowing where the Tax Authority will look allows you to anticipate, review documentation and correct possible exposures before the request arrives.

What does this regulation establish?

The Annual Tax and Customs Control Plan is the document that the AEAT publishes each year to set its priority lines of inspection action. It is not a regulation that creates new obligations: it is the Agency's internal roadmap that indicates where it will concentrate its control resources during the year.

The four priority lines approved for 2026 are:

The correction of errors published on 24 April 2026 adjusts formal or material aspects of the original text, but does not modify any of these lines of action. The guidelines approved on 11 March 2026 remain intact in their substantive content.

Economic and operational impact

The Control Plan does not generate a direct cost in itself, but defines the actual tax risk perimeter for companies during 2026. An inspection action derived from these guidelines can result in regularizations, surcharges and late payment interest that in many cases far exceed the amount of the fee initially not paid.

The most relevant operational effects by area are:

• Large taxpayers: Higher probability of systematic checks. Requires robust and up-to-date tax documentation, especially in related party operations and restructurings.
• International operations: Focus on transfer pricing, permanent establishments and international tax planning structures. Companies with foreign subsidiaries or suppliers must review their related party transaction documentation.
• Underground economy: Sectors with high cash turnover, hospitality, construction or retail are historically the most exposed. The AEAT uses data crosses and sectoral profitability analysis to detect anomalies.
• Tax fraud: Actions on VAT schemes, use of false invoices and artificial structures. It especially affects companies that participate in supply chains with high-risk suppliers.

Who does it affect?

The regulation affects all taxpayers subject to tax control in Spain, but the level of exposure varies depending on the profile:

• Large companies and business groups: Maximum exposure. They are the explicit target of one of the four priority lines.
• Companies with cross-border activity: High exposure. International operations, transfer pricing and structures with a foreign component are in direct focus.
• Customs operators: Affected by the customs component of the plan, which complements tax control.
• Self-employed workers and SMEs in risk sectors: Especially those operating with cash or in sectors historically associated with underground economy (hospitality, construction, retail).
• Tax advisors and consultants: Must know these guidelines to anticipate risks in their client portfolios and review supporting documentation.
• CFOs and financial directors: Responsible for ensuring that the company has sufficient documentation to support its tax position in priority areas.

Practical example

A Spanish industrial company with turnover exceeding 50 million euros that has a subsidiary in Germany and makes intra-group purchases falls directly into two of the four priority lines of the plan: control of large taxpayers and international operations.

In practice, this means that the probability of receiving a request for information or a check on its transfer pricing is significantly higher in 2026 than in years when these areas were not explicitly prioritized. If the company does not have its related party transaction documentation file (master file and local file) updated, it is exposed to sanctions for lack of documentation, regardless of whether the prices are correct.

The concrete action: review before summer that transfer pricing documentation is updated for the 2025 fiscal year and that it reflects the economic reality of the operations.

What should companies do now?

1. Identify which priority lines your company fits into: Check if you are a large taxpayer, have international operations, operate in sectors with underground economy risk or have had complex tax structures. The more lines that affect you, the greater your exposure.
2. Audit related party transaction documentation: If you have transactions with group companies, especially abroad, verify that the transfer pricing file is updated and is consistent with the economic reality of the business.
3. Review compliance with international reporting obligations: Check that you have correctly filed models 232 (related party operations), 720 (assets abroad) and any other reporting obligation with a cross-border component.
4. Evaluate risk in underground economy sectors: If you operate in hospitality, construction, retail or any sector with high cash turnover, review that your declared income is consistent with sectoral ratios and that you have documentary justification for your operations.
5. Inform senior management and the board: The Control Plan is relevant information for corporate tax risk management. CFOs and financial directors should communicate these priorities to the audit committee if one exists.
6. Consult with your tax advisor: Request a specific review of your company's risk profile against the four priority lines of the plan, with special attention to areas where there is less supporting documentation.