Inspections, requests and tax controversy

Advanced tax strategy is not just about structuring things correctly. It is also about being prepared when the tax authorities question, review, or challenge your position.

This is where many companies arrive too late. First they file, then they accumulate poorly documented positions, and only when a request or inspection arrives do they seek advice. The problem is that at that stage it is no longer about “optimising”, but about defending properly and limiting the damage.

The best tax defence does not start when the inspection arrives

Leading tax firms place strong emphasis on tax proceedings, tax litigation, and tax controversy. Pérez-Llorca highlights specialised teams in tax procedures and disputes; Cuatrecasas structures part of its practice around tax proceedings; and at a local level, several firms publish dedicated pages on tax inspections and defence against tax authority requests, reinforcing that this is a high-intent, high-demand area.

The practical conclusion is clear:
if the company is well structured beforehand, the defence is usually stronger afterwards.

What types of procedures we handle

The Spanish Tax Agency (AEAT) sets out specific procedures such as:

• tax inspection procedure for verification and investigation;
• responses to formal requests for information;
• submission of allegations and supporting documentation;
• and procedural steps linked to tax investigations or audits.

This means that we are not only talking about “tax inspections”. We also deal with:

• preliminary information requests;
• tax management reviews;
• formal inspections;
• penalty proceedings;
• and appeals or subsequent defence actions.

What we do when AEAT or ATC arrives

First, we identify exactly what type of procedure you are facing and what deadline is running.
Second, we review whether the tax position is properly supported, what documentation backs it up, and where the weak points are.
Third, we decide whether the appropriate step is:

• to respond and justify the position;
• to correct it;
• to negotiate criteria;
• to prepare an administrative defence;
• or to design a full litigation strategy from the outset.

The AEAT itself provides formal channels to respond to requests, submit documentation, and file allegations within inspection or tax management procedures.

Why this area is so valuable for a business

Because what is at stake here is not just a tax assessment.
It involves:

• penalties,
• future tax positions and criteria,
• group documentation,
• exposure of directors or administrators,
• and even the overall consistency of the existing tax structure.

That is why the most highly regarded tax teams do not separate “planning” from “controversy”: they treat them as two sides of the same coin.

How we handle tax defence

First, we review the procedure, deadlines, and scope.
Then we reconstruct the accounting, tax, and documentary basis.
Finally, we define a defence strategy that is genuinely effective:

• formal submissions and objections;
• documentary responses;
• appeals;
• and preparation for subsequent stages if necessary.

Here, we do not believe in “responding quickly and that’s it”. We believe in responding properly.

What documentation we need

If you already have it, it is useful to gather:

• the tax request, audit notice, or formal resolution received;
• affected tax returns;
• accounting records or supporting documentation;
• relevant contracts and annexes;
• corporate structure information, if relevant;
• previous communications with AEAT or ATC;
• and any document that supports the tax position taken.

If you want to grow with confidence, don’t wait for an inspection to start organising your defence

Advanced tax strategy also means ensuring that, if the AEAT or ATC comes knocking, your company is not improvising.

Request an initial tax assessment