Practice area

Tax Litigation

When a tax matter becomes contentious, technical analysis and procedural strategy must move as one.

Engagement with the Spanish Tax Authorities is rarely straightforward when a matter becomes contentious. Effective defence requires a detailed command of tax law and procedure, together with practical insight into how the authorities investigate, assess and litigate cases.

Our tax litigation team combines substantive tax expertise with in-depth knowledge of administrative and procedural law. We advise private clients, businesses and international groups throughout audits, investigations, claims, appeals and court proceedings.

We act before national, regional and local tax authorities, the economic-administrative tribunals and every Spanish court competent to hear tax matters. We also advise on the financial management of a dispute, including payment, suspension, guarantees and the recovery of sums paid.

The strongest defence is usually built early. We establish the relevant facts, preserve the evidence and develop the narrative and procedural strategy before positions become fixed or deadlines reduce the available options.

Where a matter spans jurisdictions or practice areas, we coordinate the required specialists as one team. The client receives a consistent strategy from the first information request through to final resolution.

Work highlights include advising:

  • Internationally mobile taxpayers in investigations concerning Spanish residence and the source of overseas income.
  • Private clients in audits involving foreign assets, trusts, foundations and holding companies.
  • Companies in VAT, corporation tax and withholding-tax disputes with the Spanish Tax Agency.
  • Directors and successors challenging derivative liability and collection proceedings.
  • Taxpayers seeking suspension of contested debts while administrative and judicial appeals are pending.
  • International groups coordinating evidence and legal positions across several jurisdictions during a Spanish audit.
  • Family businesses responding to valuation challenges and the denial of Wealth Tax and inheritance-tax exemptions.
  • Clients reviewing sensitive tax positions before filing, restructuring or entering into discussions with the authorities.

How we can help

Tax audits and investigations

Strategic support from the first information request, including management of evidence, meetings with inspectors and the technical and procedural response to proposed adjustments.

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Contributions & recognition

CONTRIBUTION

Tax Disputes Chapter: Spain 2026

We are proud to contribute specialist perspective to the Spain chapter, bringing together the legal, procedural and practical considerations that shape complex tax disputes.

Directory recognition

Independent recognition matters when it reflects the quality, judgment and clarity clients experience in demanding tax matters.

In a tax dispute, technical merit and procedural strategy cannot be separated. The evidence, chronology and legal argument must reinforce one another from the first response to the final appeal.

The Lullius approach

Key contacts

Find an expert
Portrait of Xavier Rubert

Xavier Rubert

Partner

Tax, Tax Litigation, Private Wealth
Portrait of Marta Aparicio

Marta Aparicio

Senior Associate

Tax, Private Wealth
Portrait of Carmen Salom

Carmen Salom

Senior Associate

Tax, Tax Litigation
Portrait of Fernando Flores

Fernando Flores

Senior Associate

Tax, Private Wealth

Talk to us about Tax Litigation.

Speak directly with a member of our team for clear, coordinated advice shaped around your circumstances.

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