In a decision dated 22 February 2024, the Central Tax Court (TEAC) has stated that the Spanish Tax Authorities lack the authority to make an individualised request for information to an entity that, not being established in Spain and not having any link or connection criterion with the Spanish territory that would determine the existence of a legal-tax relationship, is not subject to the Spanish domestic legal system.
In these circumstances, obtaining information from those entities must be channelled through mutual assistance instruments related to the exchange of information.
Access the full decision HERE
