The 2026 Tax Control Plan has just been published and, among its extensive content, there are eight priority areas affecting both individuals and businesses. From reviewing point-of-sale terminals to monitoring cryptocurrencies, the Tax Agency is focusing on very specific sectors. Here are the most relevant points.
The 8 priority inspection areas for 2026
Business visits and POS terminal checks
The programme of in-person business visits continues, particularly to check point-of-sale (POS) terminals and detect possible simulated economic activity. This also covers tourist rentals and undeclared leases.
Cash-only businesses
Special attention will be paid to businesses that operate exclusively in cash and that show unusual variations in stock levels or figures that don’t match the sector average.
Plastic Tax, special attention to the census register
Review of this tax continues, with specific reference to the census status of affected businesses. This is an area where extra care is advisable to avoid issues.
Wealth Tax and changes of tax residence
This includes review of the Wealth Tax on large fortunes, along with continued checks on external signs of financial capacity and fictitious changes of tax residence.
E-commerce and cryptocurrencies
Monitoring continues of e-commerce carried out through digital platforms and of the correct reporting of cryptocurrency transactions.
Non-residents: withholdings and beneficial ownership, a highly litigious area
Regarding non-residents, the correct application of withholding tax will be reviewed by checking who the beneficial owner actually is, in line with recent court rulings. This point is expected to generate considerable controversy and litigation.
Real estate transactions: VAT and transfers between related parties
In the real estate sector, the review will cover VAT refund transactions involving adjustment of capital goods, the application of reduced rates, and transfers between related parties.
Restructurings, intra-group transactions and ongoing losses
Corporate restructuring transactions, international movements between companies in the same group, and situations of ongoing tax losses will be reviewed.
What does this mean for your business or activity?
The 2026 Tax Control Plan makes clear that the Tax Agency is maintaining and stepping up its presence in sectors with a high likelihood of undeclared activity (cash, POS terminals, rentals), while also broadening its focus to high-net-worth taxpayers, international operators, and businesses with related-party transactions. If your business fits any of these profiles, now is the time to check that all your documentation and filed returns are correct and consistent.
ⓘ Are you currently facing a tax inspection?
If you unfortunately find yourself in the middle of a tax inspection and need specialist technical advice, don’t hesitate to get in touch with us. We can help you defend your interests.