The Spanish taxman has stepped up on-site inspections of self-employed workers and businesses as part of its crackdown on undeclared income, illegal accounting software and tax fraud.
According to the Agencia Tributaria’s last published annual enforcement report, in 2024, 2,100 unannounced inspections were carried out, representing a 12.8% year-on-year increase, reports Diairo AyE.
These surprise visits, although still a small proportion of overall inspections, mark a clear upward trend following several years of reduced activity after the pandemic.
While the number of unannounced visits remains below pre-Covid levels, tax officials have confirmed that this type of inspection is once again being used more frequently, particularly in cases where there is a risk of evidence being destroyed.
Focus on hidden income and double-use software
The increase forms part of the government’s Tax Control Plan for 2025–2026, published last September, which sets out priorities for inspections across all sectors and business sizes.
One of the main areas of focus is the use of so-called ‘double-use’ accounting software – systems designed to conceal real turnover or manipulate sales data.
According to the tax authority, surprise inspections are especially effective when combined with on-site digital audits.
In 2024, more than 1,600 inspections were supported by specialist IT audit units, allowing inspectors to analyse accounting software directly on business premises.
‘These inspections are highly efficient in uncovering hidden income and obtaining evidence quickly,’ the agency noted, adding that they also have a strong deterrent effect on future non-compliance.
Three types of tax inspections
Spain’s tax authority generally carries out checks in three ways:
- Document requests, where businesses are asked to provide information remotely. Nearly two million of these checks were carried out in 2024.
- Pre-arranged visits, agreed in advance with the taxpayer or their accountant.
- Surprise inspections, the least common but most intrusive option.
Surprise inspections are typically reserved for cases where inspectors believe there is clear evidence of serious fraud and a real risk that documents or data could be destroyed.
In total, 2,071 entries and on-site searches were authorised in 2024, also up 12.8% year-on-year.
Legal limits and court authorisation
Spanish law places strict limits on unannounced inspections. Following several rulings by the Supreme Court, tax officials must now demonstrate that a surprise visit is necessary, proportionate and the only viable option to obtain evidence.
In most cases, inspectors require judicial authorisation before entering business premises that are considered constitutionally protected spaces. The taxpayer must also be formally notified of the start of the inspection, even if this occurs at the moment inspectors arrive.
Tax law experts stress that these visits are always subject to later judicial review.
Despite the increase, tax technicians insist that surprise inspections remain rare and unnecessary in the vast majority of cases.
For most self-employed workers and small businesses, compliance checks will continue to begin with paperwork requests or scheduled visits – but the message from Spain’s tax authority is clear: unannounced inspections are back on the table where inspectors believe they are justified.
