The Central Economic-Administrative Court (TEAC, its Spanish acronym) endorses the Tax Authorities’ (AEAT, its Spanish acronym) right to request due diligence

In its ruling of 15 October 2025, the TEAC confirmed that the AEAT may request taxpayers to provide reports prepared as part of a due diligence.

The controversy arose regarding whether a request for these documents to be provided, which contain the results of a thorough examination of business operations and structures, exceeds the powers of the issuing body or violates the principles of motivation and tax significance.

The TEAC considers and emphasises in its ruling that, in the case analysed, the request was fully valid, as it was issued by a competent body, was sufficiently reasoned and there was a direct connection with the management and control of the tax obligations of the taxpayer concerned.

The court recalls in its ruling that tax significance is measured by the potential fiscal relevance of the information requested. In this case, the documentation requested — the reports of a complete due diligence — was valuable for assessing the tax risks associated with certain financially significant transactions. Furthermore, the court adds, the requested data was not confidential under Article 93.5 of the General Tax Law, thus reinforcing the legitimacy of the request.

This ruling reinforces the scope of the Tax Authorities’ powers of verification and investigation and consolidates the obligation of companies to cooperate with requests that are justified and linked to legitimate tax purposes.