During the first months of 2026, regulatory activity in Spain has been marked by multiple tax changes. Some entered into force and, however, ceased to apply just weeks later. Others, on the contrary, have been consolidated and have started to generate real effects on business operations.
For this reason, at LEIALTA we review the most relevant tax developments for companies and how to respond to them at this particularly demanding start to 2026.
Rules that come and go: the main source of uncertainty
In the first quarter of 2026, several tax measures have had a very limited period of validity.
For example, Royal Decree-Law 16/2025 introduced, among other measures, the extension of certain thresholds under the modules system (PIT and VAT), as well as adjustments to special regimes. However, it ceased to have effect after not being ratified by Parliament.
Subsequently, Royal Decree-Law 2/2026 attempted to recover part of that content, including the continuation of those thresholds and certain technical adjustments. However, it was also repealed after not being validated.
In practice, this has created uncertainty for companies and self-employed individuals, particularly in key areas such as:
- The application of the modules system.
- Eligibility to remain within certain tax regimes.
- Proper planning of tax obligations.
The risk in this context is significant: applying a measure that is no longer in force may lead to tax errors and potential liabilities.
Measures that remain in force: real impact on specific sectors
The rules that have been ratified during this period and remain in force are the following:
Firstly, Royal Decree-Law 7/2026 includes tax measures aimed at mitigating the effects of the energy crisis, affecting different taxes and potentially impacting business costs, especially in energy-intensive sectors.
Royal Decree-Law 6/2026 introduces changes in Personal Income Tax (PIT), specifically affecting the treatment of certain compensation payments.
In addition, Royal Decree-Law 5/2026 introduces tax relief measures related to damage caused by extreme weather events in certain areas of Andalusia and Extremadura. Its impact is significant, although mainly for companies and taxpayers affected in those regions.
Operational changes: the real impact on businesses
Beyond legislative changes, the first months of 2026 have brought operational updates that directly affect day-to-day business activity in Spain.
VAT self-assessment forms
On the one hand, there have been changes to VAT self-assessment forms (303, 322, 353 and 390) and to the technical specifications of VAT record-keeping, requiring companies to review how tax information is reported.
B2B electronic invoicing systems
On the other hand, the mandatory B2B electronic invoicing system continues to develop, representing a structural shift in invoicing processes, control mechanisms and relationships with clients and suppliers.
This development also takes place in a broader context of increased tax control, with initiatives such as Verifactu aimed at enhancing traceability and supervision of transactions.
2026 Tax Control Plan
In addition, the 2026 Tax Control Plan has been approved, strengthening audit and inspection activities by the Spanish Tax Authorities.
This plan does not introduce new obligations, but it does indicate where control will be intensified, which has a direct impact on businesses.
Key focus areas include:
- Reviewing the correct application of tax regimes.
- Ensuring consistency between declared data and actual activity.
- Monitoring transactions with tax risk or accounting inconsistencies.
In practice, this means an increase in audit activity and requires companies to strengthen the traceability of their accounting and tax information.
What companies should review in this context
This quarter sends a clear message: tax compliance requires continuous monitoring and regular review. In this environment, it is essential to:
- Verify which measures are in force at any given time.
- Review the correct application of tax regimes.
- Adapt accounting and invoicing systems to new requirements.
- Assess the impact of changes on costs and tax planning.
An environment that requires anticipation
The combination of regulatory instability and new operational obligations requires companies to adopt a more proactive approach. The risk is no longer only missing a regulatory update, but also incorrectly applying rules whose validity has changed within very short timeframes.
Given the speed of regulatory changes, it is advisable to verify the applicability of each measure at the time it is implemented.
From LEIALTA’s accounting and tax area, we support companies in interpreting and applying these changes, helping them adapt with confidence to an increasingly demanding tax environment in Spain.
