When a Spanish Tax Agency inspection reaches its final stage, the company needs to understand what is recorded in the inspection report, how it is formalised and what consequences may arise from signing it.
Since 29 October 2026, the Spanish Tax Agency has applied new rules governing the preparation, signature and processing of tax inspection reports. The measure removes the requirement to use predetermined official templates and updates the procedures for their electronic formalisation.
The changes affect companies subject to inspection proceedings by the Spanish Tax Agency (AEAT). At LEIALTA, we explain what has changed and what companies should review.
What is changing in Spanish Tax Agency inspection reports?
The new resolution replaces the rules introduced in 2007 and establishes general guidelines for documenting the outcome of tax inspections.
The main changes are:
- Mandatory official templates are removed. Inspection reports no longer need to follow the predetermined forms previously in use. Their content must, however, continue to meet the requirements established under Spanish tax legislation.
- Electronic preparation and signature procedures are updated. Inspection reports will be prepared using the AEAT’s IT systems and may be signed electronically, both during in-person meetings and remotely.
- Delivery of the documents is regulated. The company or its representative will receive a copy of the inspection report electronically or in physical form, as appropriate. Where no meeting takes place, the Tax Administration must send the document using a method that ensures the effectiveness of the procedure.
Handwritten signatures will remain possible where the electronic systems provided for cannot be used.
It is important to clarify that electronic signatures were already provided for under the previous rules. The 2026 resolution updates and specifies how they are to be used, rather than introducing electronic signatures for the first time.
Can tax inspection reports be signed remotely?
Yes. The resolution expressly allows tax inspection reports to be signed electronically during remote meetings through the AEAT’s Electronic Office.
These proceedings may be conducted by videoconference or other similar systems that enable simultaneous communication and ensure the security of the documents exchanged.
However, remote attendance is neither automatic nor something that can be imposed without consent. This format must be approved by the Tax Administration and accepted by the person attending the proceedings.
This may make it easier for company representatives who are not physically present at Spanish Tax Agency offices to participate, including representatives of foreign companies operating in Spain.
Reports in agreement, in disagreement and with agreement: what is the difference?
Although the way inspection reports are prepared and signed is changing, the three types of inspection report provided for under Spain’s General Tax Law remain in place:
- Reports in agreement: used when the company accepts the facts and the proposed tax assessment issued by the Tax Inspectorate.
- Reports in disagreement: formalised when the company does not accept the proposal, refuses to sign or fails to attend on the scheduled date. The rules allow the company to submit representations within 15 days from the date the report is issued or notified, as applicable.
- Reports with agreement: used in certain cases where valuations, estimates or other relevant aspects of the tax adjustment need to be determined. Their formalisation is subject to specific requirements.
This distinction is important because signing an inspection report does not always mean accepting the Spanish Tax Agency’s position. A company may sign a report in disagreement without accepting the proposed tax adjustment.
Each type of report also has different consequences in terms of the final assessment, potential penalties and available appeal procedures.
What happens if a company refuses to sign the inspection report?
Refusing to sign does not prevent the Tax Inspectorate from continuing the procedure.
- If the company representative attends but refuses to sign, this will be recorded in the document. In this case, the report will be deemed to have been notified in accordance with the applicable legal rules.
- If the representative does not attend, the Tax Administration will send a copy using the appropriate method.
A refusal to sign should therefore not be viewed as a way of stopping the procedure or avoiding its effects. What matters is understanding the options available for submitting representations or challenging the decision in each case.
What should companies review during a tax inspection?
The resolution does not introduce new general tax obligations or require all companies to adapt their internal procedures.
However, when a company is undergoing a tax inspection in Spain, several areas deserve particular attention:
- Check the contents of the inspection report: the facts recorded, tax periods reviewed, amounts involved and grounds for the proposed adjustment.
- Correctly identify the type of report: particularly before indicating agreement with a proposal made by the Spanish Tax Agency.
- Verify representation: ensure that the individual acting on behalf of the company has the appropriate authority to do so.
- Monitor notifications and deadlines: whether the document is signed electronically or delivered by other means.
- Assess the consequences before signing review the effects of accepting an adjustment and the options available for submitting representations.
These precautions are relevant both for Spanish companies and for foreign companies subject to AEAT inspection proceedings in Spain.
It should also be noted that the resolution governs proceedings carried out by the Spanish State Tax Agency. It should therefore not automatically be applied to procedures conducted by other tax administrations, such as Spain’s regional chartered tax authorities.
Why reviewing the inspection report before deciding matter
The update to tax inspection reports is primarily part of the modernisation of the Spanish Tax Agency’s procedures. It does not change companies’ tax obligations or the statutory deadlines applicable to the different types of inspection report.
However, the publication of the new rules highlights an important point: the outcome of a tax inspection does not depend solely on the documentation submitted, but also on how the company formally responds to the Spanish Tax Agency’s proposal.
At LEIALTA, our Accounting and Tax Department supports companies in reviewing their tax obligations and dealing with proceedings involving the Tax Administration.
Correctly analysing the contents of an inspection report, its consequences and the available alternatives allows companies to approach these procedures with greater certainty and avoid rushed decisions.
