2026 Tax Control Plan: the 8 key points you need to know
Last Thursday, the Tax Control Plan for 2026 was published. From its extensive content, I would like to highlight the following:
1. Business visits and POS terminal control
The business visit programme continues, especially to monitor POS (Point of Sale) terminals for any simulation of economic activities, and to detect undeclared tourist rentals and leases.
2. Cash-only payment activities
Focus will be placed on reviewing activities where only cash payments are used, along with anomalous or sector-inconsistent variations in inventory levels.
3. Plastic Tax
The review of the Plastic Tax continues, with particular attention to census registration status. This is a tax that requires careful attention.
4. Wealth Tax and tax residency
The review of the Wealth Tax is included, along with the ongoing monitoring of external signs of economic capacity and fictitious changes of tax residency.
5. E-commerce and cryptocurrencies
Controls on e-commerce through digital platforms and cryptocurrency reporting obligations remain in place.
6. Non-residents and withholding taxes
Regarding non-residents, the correct application of withholding taxes will be reviewed by verifying who the beneficial owner is (in line with recent court rulings on the matter), which will undoubtedly generate significant controversy and litigation.
7. Real estate transactions
In the real estate sector, authorities will review transactions where a VAT refund has been requested in cases involving the regularisation of investment goods, the application of reduced rates, and property transfers between related parties.
8. Restructuring and international operations
Restructuring transactions, intra-group international movements, and situations of ongoing losses will all be subject to review.
If you are unfortunately going through a tax inspection process and need technical assistance, do not hesitate to contact me.