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AEAT Tax Requirement: What to Do (and What Not to Do) in the First 10 Days

Zythos Business

An envelope in the mail — or, more commonly today, a notice in the Tax Agency’s online portal (Sede Electrónica) — bearing a formal request addressed to your business almost always produces the same reaction: a knot in your stomach. The good news is that a requerimiento is not a penalty or a formal accusation; it’s a request for information or justification about something the AEAT has spotted (or wants to verify) in your tax returns. How you respond in the first ten days largely determines the final outcome.

What Types of Requests Can the AEAT Send You?

Not all requests are the same, and it’s worth identifying exactly which one you’ve received before you move a single piece of paper. The most common ones for freelancers and small businesses are:

Information request: you’re asked to provide invoices, contracts, bank statements, or supporting documents for a specific item (a VAT deduction or a declared expense, for example). This doesn’t yet imply an adjustment — it’s simply verification.

Request ahead of a proposed assessment (within a limited verification procedure): the AEAT has already flagged a possible discrepancy and is giving you the chance to explain it or provide evidence before issuing a provisional assessment.

Request to clarify discrepancies between filings: for example, when the output VAT declared on your quarterly VAT return (Modelo 303) doesn’t match what a client reported on their annual transactions return (Modelo 347), or when withholdings on Modelo 111 don’t line up with what your payers declared.

Request as part of a formal inspection: this is the most serious kind, usually signed by an inspector, and signals the start of broader audit and investigation proceedings — not limited to a single item.

The First Ten Days: What to Do and What to Avoid

The standard deadline the tax authority gives you to respond to a request tends to be around ten business days from notification, though each communication states the exact deadline and it can vary depending on the procedure. So the first step is to read the entire notice: what’s being requested, which tax year and tax it concerns, and the actual deadline stated in the document — not whatever deadline you remember from a previous notice.

What you should do: confirm the exact notification date (not the date you opened the email, but the one recorded in the Sede Electrónica, since that’s when the clock starts); gather only the documentation that’s been requested — no more, no less; and, if it’s a straightforward information request, assess whether you can respond clearly and with proper supporting documents within the deadline.

What you shouldn’t do: never ignore it, even if you assume it’s a mistake or that “it’ll sort itself out” — failing to respond can trigger a penalty for not attending to a formal request, on top of leaving the underlying issue unresolved in your favor. Nor is it a good idea to respond verbally by phone, or to submit incomplete documentation just to meet the deadline: it’s better to request a justified extension than to hand in something disorganized that raises new questions. And, of course, don’t provide more information than what was asked for “just in case” — the more you show, the more questions can come up.

Filing a Response and When to Call Your Advisor

If the request already includes a proposed assessment or adjustment you disagree with, you have the right to file a formal response (alegaciones) within the stated deadline, backed by evidence — invoices, contracts, proof of payment — that supports your version of events. A well-argued response with specific references to the supporting documentation carries far more weight than simply stating you disagree.

As a general rule, call your advisor as soon as the request arrives — not when only two days are left on the clock. This is especially important if the request mentions a limited verification procedure or a formal inspection, if it covers several tax years or taxes at once, if the amount at stake matters to your business, or if you simply don’t understand what’s being asked or why. An advisor can check whether the deadline is being calculated correctly, whether it’s worth requesting an extension, and whether you should stick strictly to what’s asked or add an explanation that heads off a second request.

At Zythos Business, we support freelancers and small businesses from the moment the first notice arrives: we review the request, identify what kind of procedure is involved, prepare the documentation with the tax authority’s criteria in mind, and, when needed, draft the formal response within the deadline. Knowing that someone with experience is reading the notice alongside you, instead of facing the Sede Electrónica alone, is often the difference between a matter resolved in a few weeks and a problem that drags on for months.

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