New steps to increase the control over Spanish residents owning assets outside Spain.

Spain launches new national office for international taxation

The Spanish Official State Gazette (BOE) published a resolution last Friday creating a new National Office for International Taxation (ONFI), which is expected to enter into force on 1st April.


As announced in November by the State Secretary for the Treasury, Miguel Ferre, this new specialised unit will assume responsibility for producing a centralised plan of action and establishing uniform action criteria for the entire Spanish Tax Office in terms of international taxation.


The ONFI, based in Madrid, will functionally operate under the Department of Inspection, with approximately 50 people, initially, exclusively engaged in activities related to international taxation. It will be responsible for scheduling, promoting and coordinating the inspection activity related to international taxation carried out by the Spanish Tax Office’s specialised, central and regional units.

At the moment, the prevention of international tax fraud is the subject of growing attention, as is evidenced by the establishment of international cooperation standards backed by the G-20, the initiative on taxable base erosion and offshore profiting, and the recent EU Action Plan to strengthen the fight against fraud and tax evasion.

By launching the ONFI, the Spanish Tax Office is strengthening its resources for combating international tax fraud, in line with the priorities being set by the European Union and the OECD.

The activity to be carried out by the new office will be focused on international related-party transactions, or fixed transfer prices between entities belonging to multinational groups, and the correct taxation in Spain of income obtained by non-residents. It will also have a team specialised in economical-financial valuations of tax relevance (intangible assets, company valuations, unlisted securities, etc.).

This new unit will, certainly, have under it´s main duties, to investigate & check the correct use of the new rules for tax reporting for Spanish residents owning assets outside Spain worth over €50,000.



Javier Herrera Llamas