2025 Tax Control Plan

The Spanish Tax Agency has published its 2025 Tax and Customs Control Plan, marking a shift in its approach to combating tax fraud. This year, the agency places special emphasis on two strategic areas: the control of personal wealth of individuals with signs of external wealth and the monitoring of complex business operations.

Monitoring Individuals with Signs of External Wealth

One of the main focuses of the Plan is targeting taxpayers whose lifestyle and signs of external wealth do not align with their declared income and/or assets. This strategy aims to tackle sophisticated forms of tax evasion that have gone largely unnoticed due to the opacity of certain mechanisms.

Who is the target of this oversight?

High-net-worth individuals who use legal structures—typically companies—to manage their resources and finance their lifestyle without proper tax reflection.

Key areas of scrutiny:

• Deducting personal expenses as if they were business-related.

• Simulating leases or services between the individual and their company.

• Free use of company-owned assets (cars, homes, boats, etc.).

• Fake loans that conceal real money flows.

• Global taxation of non-Spanish nationals who are tax residents in Spain—not just income generated within the country.

• Verification of income earned by non-residents in Spain.

The Agency will focus its efforts on analyzing these corporate structures and attributing personal-use expenses and investments—currently claimed as business-related—to the individual. The goal is to ensure that individuals pay taxes on their actual personal income. The Plan also specifies that investigations into high-net-worth individuals (HNWIs) will continue as described.

Intensified Control Over Corporate Structures and Complex Operations

Alongside individual wealth control, the Plan also seeks to delve into companies controlled by a single individual or family group to assess operations as a whole. Special attention will be paid to mergers, spin-offs, asset contributions, and share exchanges.

Key areas of scrutiny:

• Non-cash contributions to companies that lack valid economic reasons.

• Transactions masking substantial asset alterations.

• Application of the dividend and capital gains exemption in Article 21 of the Corporate Income Tax Law.

• Simulated company structures and economic activities.

• Concealment of the real beneficiary in significant transactions, hindering income traceability and auditability.

These legally covered practices will be examined in detail to detect cases with solely tax-driven purposes—i.e., lacking any valid economic rationale—which may lead to their reclassification as tax avoidance or even fraudulent operations.

The Tax Agency will use advanced technology and international information exchange to unravel opaque structures and corporate networks designed solely to dilute tax liability or shift income to more favorable jurisdictions.

Other Key Areas of Focus

Although personal wealth and complex structures are the primary targets, the 2025 Control Plan also includes:

• Reinforced oversight of the underground economy, foreign payment methods, and point-of-sale (POS) systems.

• Audits in sectors with high instances of false or simulated invoicing.

• Increased monitoring of cryptocurrencies, e-commerce, and neobanks.

• Use of artificial intelligence to improve taxpayer assistance.

• Encouragement of voluntary compliance through new tools such as “Renta Directa” or using Bizum for tax payments.

• Strengthened collection efforts and control over outstanding debts during the enforcement period.

The 2025 Tax and Customs Control Plan of the Spanish Tax Agency focuses on strengthening oversight of personal wealth and complex corporate structures. The plan aims to identify sophisticated tax planning mechanisms and ensure that income and assets are properly declared. The use of advanced technologies and international cooperation will be key to improving the efficiency of the tax system.

At Gentile Law, we offer expert legal advice to ensure your wealth and corporate structures comply with current tax regulations. If you need support in reviewing your tax situation legally and efficiently, our team is here to guide you toward the right decisions.