Spanish Valuation Checks: No Prior Reasoning and No Site Visit Means the Assessment Falls (TEAC decision of 28 April 2026, case 00/08883/2024)

Spain's Central Tax Tribunal, in its decision of 28 April 2026 (case 00/08883/2024), annuls an inheritance tax assessment because the authority failed to justify the need for the valuation check before starting it, and because the expert reports repeated the same boilerplate excuse for not visiting the properties. It applies the Supreme Court judgment of 19 November 2025 (appeal 113/2024) and, a previous assessment having already been annulled, bars a third assessment and rules out a fresh remittal.

1. A decision that changes the starting point of every valuation check

Spain's Central Economic-Administrative Tribunal (TEAC), in its decision of 28 April 2026 (case 00/08883/2024), upheld an appeal and annulled an Inheritance and Gift Tax (ISD) assessment on two grounds worth remembering:

  1. The tax authority's expert valuation reports failed to justify, on a property-by-property basis, why the personal site visit had been skipped.
  2. Above all, the authority did not give reasons for starting the valuation check before carrying it out, merely stating in the adjustment proposal that the check had already been performed.

The TEAC also closes the file: it orders no further remittal of proceedings and allows no third assessment, because a first assessment on the same tax obligation had already been annulled.

For any taxpayer — and especially for foreign residents on the Costa Blanca facing valuation checks on inheritances, gifts or property purchases — this decision is a first-rank defence tool. At [Bufete Padilla](https://bufetepadillatorrevieja.com/en/contact), with offices in Torrevieja, Elche and Moraira, we routinely defend these files before the Inspectorate, the regional and central tax tribunals and the administrative courts.

2. What a valuation check is, and why it hurts

A valuation check (*comprobación de valores*) is the procedure by which the Spanish tax authority reviews the value a taxpayer declared for a tax on wealth or on a transfer — mainly inheritance and gift tax and transfer tax — and replaces it with a higher one.

The regime is set out in Articles 57, 134 and 135 of the General Tax Act (Law 58/2003), developed by Articles 157 to 162 of the General Tax Management and Inspection Regulation (Royal Decree 1065/2007).

The practical effect is immediate: if you inherited a property declared at €180,000 and the authority values it at €260,000, the difference becomes additional taxable base, with tax due, late-payment interest and, frequently, a proposed penalty.

| Element | Consequence for the taxpayer |
|---|---|
| Declared value replaced | Higher taxable base and higher tax |
| Tax difference | Claimed with late-payment interest |
| Possible penalty | Up to 150% in the most serious cases |
| Burden of proof | Falls on the authority: it must give reasons |

3. The facts: inheritance tax, company shares and a wasted second chance

The file decided by the TEAC concerned an inheritance in which the authority checked the value of several urban properties held by a company, QR TX, S.L., whose shares formed part of the estate.