The Spanish Tax Agency (AEAT) has recently published in the Official State Gazette (BOE) the main guidelines it plans to promote throughout 2025 regarding tax oversight, identifying sectors, transactions, and activities that will be prioritized for audit and investigation.
Among the most significant aspects is the intensified focus on Transfer Pricing, which continues to be a key area of enforcement. With a global approach based on cross-analysis of all available information sources (the so-called 360º strategy in transfer pricing), the Plan strengthens and expands the supervisory actions implemented in previous years.
The main lines of action for 2025 in this area are:
- Verification of Information and Documentation Obligations
There will be increased scrutiny of compliance with information obligations (Form 232) and Transfer Pricing documentation, with particular attention to substantive aspects:- Analysis of functions, assets, and risks.
- Appropriate selection of valuation methods.
- Account segmentation as an audit tool.
Strict compliance with deadlines will be enforced, reminding taxpayers that documentation must be available after the deadline for the voluntary filing of the Corporate Income Tax return. In this regard, the AEAT foresees faster and more targeted verifications, as well as review campaigns for information returns. - Automated Risk Analysis System
The AEAT will continue applying automated risk analysis systems, interrelating all available information on related-party transactions. The goal is greater effectiveness through sector-specific knowledge and multinational context in risk detection. - Enhanced Administrative Cooperation
International cooperation mechanisms will be reinforced:- Automatic exchange of information.
- Tax agreements between administrations and other economic actors.
- Simultaneous multilateral audits and joint inspections under the European frameworks in force since 2024.
- Audit of Specific Intragroup Transactions
There will be a continued focus on the following areas:- Business restructurings: Particular attention to asset transfers, especially intangibles, and internal restructurings that may erode the tax base.
- Intragroup payments and recurring losses: Reviews of deductions for royalties, services, financial transactions, and situations of repeated losses.
- Financial operations and foreign structures: Strengthened actions to prevent structures that inappropriately shift profits out of Spain.
Special attention will be paid to activities carried out by entities with declared low-risk functional structures but significant presence, as well as to valuation methods and indicators used. - Mutual Agreement Procedures and Advance Pricing Agreements
The AEAT reaffirms its commitment to:- Promoting Mutual Agreement Procedures (MAPs) to avoid double taxation and expedite resolution timelines.
- Encouraging Advance Pricing Agreements (APAs) as tools for preventing tax risks and ensuring legal certainty for taxpayers.
- Other Areas of Interest for Large Companies and Multinationals
- Refunds of withholding taxes to non-residents (FASTER): Implementation of the EU’s FASTER system begins, aiming to streamline and secure refunds of excess withholding, especially on dividends.
- Application of the BEPS Multilateral Convention: Audits will ensure effective application of international anti-avoidance measures, such as tax transparency and limits on interest deductibility.
- Global Minimum Tax and New Taxes: Although the first filings for the Top-Up Tax will occur in 2026, 2025 will be a key preparatory year for its implementation.
- Control over Tax Groups: There will be increased review of deductions generated by economic interest groupings and compliance with requirements for inclusion in tax groups, as well as verification of internal consolidation transactions.
- Limited Audit Procedures: The Large Taxpayers Units will increase actions through streamlined procedures, especially focusing on VAT and Corporate Income Tax control.
The 2025 Tax and Customs Control Plan consolidates a clear trend: intensified tax oversight in an increasingly globalized and complex environment. The prevention of tax risks, the strengthening of international cooperation, and the incorporation of new analytical technologies will be fundamental pillars in the Tax Agency’s control strategy this year.
In this context, it is essential for companies to review their transfer pricing policies, optimize their documentation compliance, and anticipate potential tax risks.
At ALS, we are ready to help you face these new challenges, offering you specialized advice, preventive strategies, and comprehensive support to ensure legal certainty and proper adaptation to the Tax Agency’s requirements.
