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HolderTax / Spain / Decisions / Regularisation
Decision · Spain · prior-year exposure

Voluntary regularisation: a price list

The deciding mechanicsBefore a requerimiento: surcharges, no penalty. After: 50–150%. The calendar is the price.
Working draft · the highest-stakes Spanish page on this site · pending licensed review · not a recommendation to file

Spain offers no immunity door like Austria and no once-in-a-lifetime pardon like Switzerland. It offers something more prosaic and, in practice, more predictable: a price list. Correct before any requerimiento and you file a supplementary self-assessment paying the surcharges of Article 27 of the tax code — 1% plus another 1% for each full month of delay, and from twelve months a flat 15% plus late interest. No penalty, no proceeding, no judgment of conduct. Correct after and you enter the penalty regime: fines of 50 to 150% of the unpaid amount, gradable — reducible on agreement and prompt payment, but a different league.

The price, itemised

A spontaneous supplementary return one year late costs the tax plus a surcharge of roughly 13%; beyond a year, tax plus 15% plus interest from month twelve. Surcharges shrink a further 25% on timely payment. Against that, the penalty route starts at 50% — and climbs with concealment or fraudulent means. The gap between the two columns of the list is routinely a multiple of three or four; and the only thing that moves a taxpayer from one column to the other is the date of the first requerimiento. Which is why the Renta aviso is valuable information: it documents that the cheap window is still open — and that someone is already looking.

Austria forgives exact sequence, Switzerland forgives once, Germany demands the whole decade. Spain does not forgive: it charges by tariff. Predictability is its form of mercy.

The criminal threshold: €120,000

Above €120,000 of tax defrauded per year and per tax, the matter jumps to the Criminal Code. Even there an exit exists: complete and truthful regularisation before proceedings begin — acknowledging and paying the debt in full — excludes criminal liability. It is Spain's version of the emergency door, and it shares the logic of everything else here: it arrives early or not at all. At amounts of that scale, nothing on this page substitutes for a criminal tax lawyer from day one.

What a crypto regularisation corrects

The usual pieces: undeclared swaps from rotation-heavy years, airdrops classified into the wrong base, omitted staking income, unfiled Forms 721 and wealth-tax mismatches. They should travel together: a supplementary return that fixes the Renta but stays silent on the 721 exposes exactly the inconsistency data matching detects best.

The sequence

  1. Reconstruct before deciding. All open years, full FIFO, bases correctly labelled, year-end valuations — the real number surprises in both directions.
  2. Compute both columns. Surcharges today against probable penalties tomorrow: the decision is made with numbers, not anxiety.
  3. File complete, once. Renta, 721 and wealth tax coherent with each other. Piecemeal corrections invite review of the whole.
  4. Near or above €120,000 per year: criminal counsel first. The exemption demands truth and completeness — and admits no second attempt.
  5. If a requerimiento arrived: change playbooks. Spontaneity is over; now you manage a proceeding, reductions and agreement — with representation.