Spain's 2026 Tax Surveillance Net: Why More Business Owners Are Moving to Andorra

If you’re a foreign business owner in Spain, a Beckham Law beneficiary, a retiree with overseas assets, or anyone with significant wealth and Spanish residence, the regulatory landscape changed materially on January 1, 2026 — and again last week.

Two documents tell the story: the AEAT 2026 Annual Tax and Customs Control Plan (published in the BOE on February 21, 2026) and Royal Decree 253/2025 (BOE, April 2, 2025), which entered force on January 1, 2026. Together, they redefine what the Spanish Tax Agency knows about you and how often.

What Royal Decree 253/2025 changes: monthly financial reporting

Before 2026, Spanish financial institutions reported account data to AEAT annually, often subject to minimum thresholds. From January 1, 2026:

• All accounts — bank and non-bank alike — are reported monthly to the Financial Ownership File (Fichero de Titularidades Financieras). Current accounts, savings, term deposits, credit accounts, payment accounts. No minimum threshold.
• Payment institutions and electronic money institutions (Revolut, N26, PayPal, business Bizum) are now obligated to report on the same terms as traditional banks.
• Foreign institutions providing services to Spanish residents under EU freedom of services rules must report monthly.
• Business Bizum: the previous €3,000 annual threshold is eliminated. AEAT now receives information on every business payment, no minimum.
• Card transactions (Modelo 174): a new annual reporting form covering charges, credits, top-ups, and cash withdrawals on any card with annual volume above €25,000.
• Beneficial owners: institutions must now report not just nominal account holders but the ultimate beneficial owner under the anti-money-laundering definition (Law 10/2010).

In practice: AEAT’s database moves from an annual snapshot of your financial life to something close to a real-time feed.

What the 2026 Control Plan signals

The Plan published in February confirms where AEAT will direct its inspection resources:

• High-net-worth individuals — systematic cross-checks between income tax, wealth tax, the solidarity tax on large fortunes, and reported income.
• Impatriate regime (Beckham Law) audits — AEAT is no longer just verifying the math. It’s auditing the substance of structures: are employment contracts genuine? Is reported salary actually disguised dividend income?
• Transfer pricing and related-party transactions — restructurings, intangibles, intra-group services, intra-group financing.
• Personal holding companies — patrimonial vehicles used to defer taxation.
• Crypto assets — DAC8 (automatic exchange of crypto exchange data) operational; second year of Modelo 721.
• Foreign-source income — DAC2/CRS, FATCA, automatic exchange with 100+ jurisdictions.
• Real estate — short-term rental platforms, DAC7 reporting (Airbnb, Booking, Wallapop, Vinted, Uber, etc.).

The full surveillance stack in 2026

Framework	What it covers	Status
DAC2 / CRS	Financial accounts in cooperating jurisdictions	Annual, fully operational
DAC6	Cross-border tax planning arrangements	Continuous
DAC7	Digital platform earnings (Airbnb, Booking, Wallapop, Uber)	Annual, second year
DAC8	Crypto exchange operations	Operational in 2026
CESOP	Cross-border payments via PSPs	Quarterly
CbCR / Pillar 2	Country-by-country MNE reporting	Annual
FATCA	US persons’ accounts	Annual
Modelo 720	Foreign assets above €50K	Annual
Modelo 721	Foreign crypto holdings above €50K	Annual
Financial Ownership File	All Spanish accounts, no threshold	Monthly from 2026

The message is unambiguous: meaningful wealth, anywhere in the world, is visible to AEAT — or will be soon.

The pressure on Beckham Law beneficiaries

Until two years ago, the Beckham Law was a clean impatriate regime: 24% on the first €600,000 of Spanish income, foreign-source income exempt, six-year duration. The 2023 Startups Law expanded eligibility to remote workers and digital nomads — and AEAT has responded with aggressive substance audits using three articles of the General Tax Law:

• Article 13 LGT — recharacterization: if you label payments as dividends but AEAT views them as salary, they reclassify.
• Article 15 LGT — conflict in the application of the rule: if a structure is “artificial” but not fictitious, AEAT can assess tax (without sanctions, subject to the Consultative Commission procedure).
• Article 16 LGT — simulation: if AEAT proves the contract isn’t what it appears to be, sanctions apply.

For current beneficiaries, the question has shifted from “do I qualify?” to “does the economic substance of my structure survive an audit?” And at the end of year 6, the cliff: 47% on worldwide income, no transition.

For the Beckham vs Andorra long-term math, see our Beckham Law analysis.

Where Andorra fits — and where it doesn’t

It’s not a hiding place. Andorra has a Double Taxation Treaty and tax information exchange agreement with Spain since 2017. It reports automatically under CRS to 100+ jurisdictions including Spain. Relocating to Andorra is a legal tax decision, not concealment. The advantage is low rates within a transparent framework, not opacity.

It’s outside the DAC perimeter. As a non-EU country, Andorra is not within the scope of DAC6, DAC7, or DAC8 for purely internal transactions between Andorran residents and Andorran institutions. Reporting obligations remain in respect of EU-linked accounts and assets, but the systematic DAC-driven information pressure does not apply to Andorran-to-Andorran activity.

The rates. Maximum personal income tax in Andorra is 10%, vs Spain’s 47% top marginal (50% in Catalonia). For investors and business owners drawing dividends, see our analysis of Spain’s new 30% savings tax bracket. Andorra has no wealth tax, no inheritance tax, no solidarity tax.

Predictability. Spain has enacted approximately 94 tax increases since 2018. The “solidarity tax on large fortunes” has been extended indefinitely. Andorra’s framework has been stable since 2014 with targeted changes — the Òmnibus 2 Law of 2026 adjusted passive residency, not rates.

Making the move legally

Breaking Spanish tax residence requires that none of the following apply:

1. Presence in Spain for more than 183 days in the calendar year.
2. Center of economic interests located in Spain.
3. Resident spouse and minor children habitually resident in Spain (presumption).

Andorra requires effective residence: 183 days/year for active residency, 90 days/year for passive (with €1,000,000 minimum investment under the Òmnibus 2 Law). In both cases, you must obtain an Andorran fiscal residency certificate and file Modelo 030 with AEAT to formalize the move.

The Spanish exit tax (Article 95 bis LIRPF) applies if you hold corporate participations valued above €4M or above 25% of a company valued above €1M — latent capital gains are taxed at the moment of departure. Deferral options exist for moves to countries with both a DTT and an information exchange agreement, which Andorra satisfies. See our Spain exit tax guide.

The bottom line

Spain is building, with published and effective regulations, a system in which every account, every business Bizum, every crypto exchange, every digital platform, and every corporate structure feeds AEAT automatically and monthly. That is the 2026 reality.

For many high-income professionals, business owners, and current or future Beckham Law beneficiaries, the question is no longer “could I pay less elsewhere?” — it’s “how long can I remain here, profitably, without inspection risk?”

Andorra isn’t the only answer. But it’s the closest, with the same language for Catalan speakers, in the same time zone, two hours by road from Barcelona, with a stable fiscal framework and a social security system (CASS) more efficient than Spain’s.

Calculate your exact tax saving with our free calculator.

This article is informational and does not constitute tax advice. Every situation is individual — consult a qualified advisor before relocation decisions. Andorra meets international standards on tax transparency and automatic information exchange (CRS) — its appeal lies in legal low rates, not opacity.