Evaluation of Law 11/2021, of July 9, on prevention measures and the fight against tax fraud

"We present the conclusions of the Working Group: Evaluation of Law 11/2021, of July 9, on prevention measures and the fight against tax fraud"

We present the conclusions of the Working Group: Evaluation of Law 11/2021, of July 9, on prevention measures and the fight against tax fraud, which were presented to the Ministry of Finance and Public Function in October 2022, and has contributed to the «Intermediate evaluation report of the effects of the Law against Fiscal Fraud» December 2022.

During the sessions of the Group the following issues have been addressed:

  • Assessment of the changes introduced in the LPF to "facilitate actions aimed at preventing and fighting fraud by reinforcing tax control".
  • Analyze what changes should be introduced in the legal-tax system, other than those already produced, to improve tax compliance.

Matters addressed by the working group:

  1. Measures related to the general tax system
    • Information obligations on virtual currencies
    • Surcharges for untimely declaration and reductions in sanctions
    • Prohibition and penalties for dual-use software. Obligation to use standardized billing software
    • Precautionary measures in suspension procedures.
    • Modifications in the list of defaulters.
    • Regulation of home entrances.
    • Modifications in the collection procedure: joint and several liability
    • Possibility of inadmitting requests for suspension through economic-administrative channels
    • Limitations on cash payments
  2. Measures relating to taxes in particular
    • Departure tax
    • The new regulation of SICAVs
    • The new regulation of tax havens.
    • The regulation of succession agreements in personal income tax
    • The reference value in property taxes
  3. New proposals aimed at improving tax compliance

Have participated in this working group: 

  1. Paula Caro, Partner of the Andersen Tax Department
  2. Carlos Dieguez Nieto, Managing Partner Tax Area, Broseta Abogados.
  3. Antonio Duran Sincreu, Managing Partner of Durán-Sindreu, Legal and Tax Advisors
  4. Xavier Estella, Partner-Director, Avantia Asesor. Fiscal and Legal.
  5. Cristina Garcia-Herrera, Director of Studies of the IEF.
  6. Cesar Garcia Novoa, Professor of Financial and Tax Law at the University of Santiago
  7. Eduardo Grace , Partner, Ashurst
  8. Clara Jimenez, Partner, Pérez-Llorca
  9. Luis Lopez-Tello, Corporate, Economic and Tax Director of Repsol, Repsol
  10. Maximino linares, Partner, EY Lawyers
  11. Gloria Marin Benitez, Partner, Uría
  12. Charity Mourelo, Team Leader at the Central Delegation of Large Taxpayers, State Tax Administration Agency (AEAT)
  13. Miguel Muñoz, Partner responsible for tax procedures, PwC Spain
  14. Anthony Montero, State Treasury Inspector. State Tax Administration Agency.
  15. Anthony Bridges, Partner of the contentious-tax department of BDO Spain
  16. Jesus Rodriguez Marquez, Managing Partner of the Tax Practice, ideo Legal
  17. Salvador Ruiz Gallud, Partner, Economic Team
  18. Jose Ignacio Ruiz Toledano, President of the Regional Economic-Administrative Court of Madrid.


These proposals of the Working Group on FIDE, have been elaborated from the contributions and interventions of all the participants in said group. Although logically they do not represent the unanimous opinion of all, they do reflect the issues on which the debate has focused.


All the people who have participated in this working group of Fide, have done so in a personal capacity and not on behalf of the entities, offices, Universities or companies, where they carry out their professional work, so these conclusions do not reflect and do not include institutional positions but rather particular ones of each one of the members of the group.

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