The 2025 Annual Tax and Customs Control Plan, approved by the Spanish Tax Agency on February 27 and published in the Official State Gazette (BOE) on March 17, reinforces scrutiny over related-party transactions.
This year’s plan prioritizes stricter compliance checks in this area, reflecting the increasing complexity of global economic integration.
Key Focus Areas for 2025
Ensuring compliance with reporting obligations
Authorities will intensify the review of transfer pricing documentation, with particular attention to the accuracy and quality of the information reported in Form 232.
Leveraging advanced risk analysis tools
Tax administration will enhance the use of automated risk assessment systems and international cooperation to detect high-risk tax transactions more effectively.
Main inspection targets
The plan will focus on:
- Business restructurings and the transfer of intangible assets.
- Deductions that artificially lower taxable income.
- Companies with repeated losses.
- Shell companies used for tax avoidance.
- Misuse of special tax regimes.
Recommendation
At addwill, we strongly advise our clients to review and update their transfer pricing policies to ensure full compliance and mitigate the risk of potential audits.
You can download the official 2025 Tax and Customs Control Plan guidelines here.
Our team at addwill can assist your company in assessing its related-party transactions and ensuring all necessary documentation is properly prepared on time. With our extensive tax expertise, we provide tailored analysis suited to your business structure and group operations.
If you have any questions, our tax experts are here to help. Click here to submit your inquiry—we will be happy to assist you.