New AEAT Inspection Director 2026: What Changes for Companies and Large Taxpayers

Key data

The Department of Financial and Tax Inspection of the State Tax Administration Agency (AEAT) is the body that directs and coordinates major tax inspections in Spain, including the fight against high-complexity tax fraud. Its director sets the roadmap for inspection activities: which sectors are prioritized, which taxpayer profiles are selected, and with what intensity control campaigns are developed.

The dismissal of Manuel Trillo Álvarez, formalized through a resolution from the Presidency of the AEAT under Article 103.3.2 of Law 31/1990, represents a change in this strategic position. Changes in direction in this department have historically preceded reorientations in inspection priorities.

What does this resolution establish?

The resolution is formally straightforward: the Presidency of the AEAT orders the dismissal of Mr. Manuel Trillo Álvarez as Director of the Department of Financial and Tax Inspection. The legal basis is Article 103.3.2 of Law 31/1990, which regulates the dismissal of senior officials of the Agency.

The Department of Financial and Tax Inspection is one of the central bodies of the AEAT. Its main functions include:

• Planning and coordination of inspection activities at the national level.
• Direction of inspections of large companies and consolidated groups.
• Design of criteria for selecting taxpayers to inspect.
• Coordination of the fight against high-complexity tax fraud.
• Supervision of Large Companies Management Units (UGGE).

The resolution does not appoint a successor in the same text, which is customary in this type of dismissal: the appointment of the new director is made through a separate resolution.

Economic and operational impact

A change in the direction of the Inspection Department does not modify tax law, but it can modify how and to whom it is applied. These are the operational effects that companies should evaluate:

• Change in action priorities: The new director may reorient inspection focus toward sectors, tax figures, or types of fraud different from those prioritized so far.
• Taxpayer selection criteria: The algorithms and risk criteria that determine which companies are selected for inspection may be adjusted with the new management team.
• Intensity of control campaigns: The inspection pressure on certain sectors or tax structures (transfer pricing, related-party transactions, VAT, corporate income tax) may increase or decrease.
• Ongoing procedures: Inspections already initiated continue normally; the director's dismissal does not halt or modify open files.

For companies operating in sectors historically under intense scrutiny (technology, real estate, financial, large distributors), this type of change is a signal to review the soundness of their tax positions before any new campaign materializes.

Who does it affect?

• Large companies and consolidated groups subject to inspection by the AEAT at the central level.
• Taxpayers currently under inspection procedure opened by the Department of Financial and Tax Inspection.
• Tax advisors and tax consulting firms that manage the relationship with inspection on behalf of their clients.
• CFOs and financial directors of companies with exposure to relevant tax risks (transfer pricing, international structures, related-party transactions).
• Law firms specialized in taxation that handle inspection procedures or appeals before the AEAT.

Practical example

A business group with revenue exceeding 100 million euros that has been in an inspection procedure for 18 months initiated under the direction of Manuel Trillo Álvarez wonders if the dismissal affects its file.

Direct answer: the inspection procedure in progress is not interrupted or modified by the director's dismissal. The actuaries assigned to the file and the legal deadlines in force are maintained. However, if the file has not yet concluded and there is a change in the department's direction regarding, for example, the valuation of related-party transactions, that new criterion could be applied in future actions or in the resolution of still-open files.

The practical recommendation for this group would be to review with its tax advisor the status of the file, ensure that all supporting documentation is in order, and be alert to whether the new director issues instructions or interpretive criteria that may affect its situation.

What should companies do now?

1. Review the status of open inspection files: If your company has an inspection in progress, confirm with your tax advisor the deadlines, the status of activities, and whether there is any pending resolution that may be influenced by the change in direction.
2. Audit high-risk tax positions: Take advantage of the transition period to internally review areas with greater exposure: transfer pricing, related-party transactions, deductions in Corporate Income Tax, VAT regularizations.
3. Monitor new department instructions: The new director will likely publish criteria or action plans. Subscribe to BOE and AEAT alerts to detect any change in approach as soon as it occurs.
4. Strengthen supporting documentation: Faced with any change in inspection criteria, the best defense is to have robust and up-to-date documentation that justifies the tax positions adopted.
5. Consult with your tax advisor if operations are planned: If your company plans to execute restructuring operations, mergers, or relevant intragroup transactions, assess the impact of the new inspection approach before closing them.

Official source

Consult complete regulation in official source (BOE-A-2026-20298)

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-20298