The Spanish Tax Agency (AEAT) is redefining how tax risk is assessed. The 2026 Tax Control Plan confirms a clear shift. Tax audits are becoming more targeted, more data-driven, and more focused on economic substance.
For multinational groups, this is not just a compliance update. It is a change in expectations. Tax authorities now expect continuous alignment between data, operations, and tax outcomes.
A New Level of Data Transparency
This changes the nature of tax audits. Authorities can now:
- Cross-check reported income with actual cash flows
- Identify inconsistencies in near real time
- Select audit targets with greater precision
Transfer Pricing: Substance Over Structure
Transfer pricing remains a key focus area. However, the approach is evolving.
The emphasis is now on whether:
- Functions are performed where profits are allocated
- Decision-making aligns with the group structure
- Risk allocation reflects actual conduct
Areas such as intangibles, intra-group services, and financial transactions will receive particular attention.
In practice, this means that documentation alone is no longer sufficient. Authorities expect a consistent and defensible narrative supported by real business activity.
Economic Substance as a Core Audit Tool
Economic substance is becoming central to tax audits in Spain.
The AEAT will assess whether entities have:
Structures that lack substance will face increased scrutiny. This is especially relevant for centralized IP models and cross-border arrangements.
- Genuine operational presence
- Real decision-making capacity
- Alignment between profit allocation and value creation
Increasing Compliance Complexity
New reporting obligations and digital requirements are adding pressure on internal systems.
Companies must now manage:
- More frequent and detailed data reporting
- VAT and cross-border transaction scrutiny
- Digital invoicing and real-time reporting frameworks
This increases both compliance workload and audit exposure.
From Reactive Compliance to Proactive Control
The key takeaway is clear. Traditional, reactive compliance is no longer sufficient.
Multinational groups should focus on:
- Data consistency across finance, tax, and operational systems
- Alignment between legal structures and actual conduct
- Regular reviews of transfer pricing models and DEMPE frameworks
Without this, even technically correct structures may not withstand scrutiny.
How TPA Global Can Support
At TPA Global, we support clients in navigating this shift toward precision auditing.
Our approach combines:
- Transfer pricing expertise with technology-driven solutions
- Real-time data alignment and risk monitoring
- Practical implementation of DEMPE and substance requirements
- Audit readiness and dispute support
We work with multinational groups to ensure that their tax structures are not only compliant, but also operationally aligned and defensible.
If you are reviewing your transfer pricing model, preparing for increased scrutiny, or facing challenges with data consistency and substance, this is the right moment to act.
Get in touch with our team to discuss how we can support your organization in strengthening its tax position and reducing audit risk.
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