Amsterdam & Partners LLP, the international law and political advocacy firm, today published an open letter addressed to Soledad Fernández Doctor, Director General of Spain's Agencia Estatal de Administración Tributaria (AEAT), accusing the agency of operating a predatory bonus system that incentivises its inspectors to extract ever-greater sums from Spanish taxpayers and foreign residents alike, while publicly misrepresenting the scale and nature of that system.

The letter charges that AEAT inspectors compete internally for a share of an incentive pool that grows in proportion to the revenue they collect. The more a taxpayer loses, the more the inspector gains. In 2024 alone, the AEAT paid out more than €280 million in bonuses and performance-related pay to its staff. In 2025, agency management and trade unions agreed a further extraordinary bonus package of €125 million, tied explicitly to increasing IRPF and VAT collection above the rate of economic growth. Negotiations over yet another incentive agreement are reportedly underway for 2026.

The letter argues that this system is structurally corrupt, compelling taxpayers to pay taxes, interest, and penalties long before they can access a fair and independent review. No comparable tax administration in the OECD operates such a scheme, and Spain's tax revenues have grown at three times the OECD average over the past decade, a consequence, the letter contends, of this incentive-driven culture of aggressive collection.

Robert Amsterdam, Founder and Managing Partner of Amsterdam & Partners LLP, states:

"Spain has built a tax enforcement machine in which the personal financial interests of its inspectors are directly and substantially tied to how much they can extract from the people they are meant to serve. That is not tax administration, it is institutionalised predation. The AEAT has publicly insisted that only 1.4% of inspector compensation is linked to collection. That claim is false, and we are publishing the documentation to prove it.

This matters not only for Spanish citizens but for the many thousands of Americans and other foreign nationals who have made Spain their home, invested in Spanish businesses, or earned income subject to Spanish jurisdiction. They are entitled to know that the agency auditing their affairs has a direct financial incentive to find against them. That is a scandal, and it demands a full public accounting.

We are calling on Director General Fernández Doctor to publish, with complete and unambiguous transparency, the full details of every incentive scheme the AEAT operates at taxpayers' expense. Spain wants to know the truth, and so does the world."

Amsterdam & Partners today published a detailed analysis of the AEAT's incentive structure, based on publicly available documentation, at www.spanishtaxpickpockets.com/primas-aeat/.

The firm's open letter, headlined ¡J'Accuse…! in a deliberate echo of Émile Zola's landmark public indictment, has been submitted directly to the Director General and issued as a full-page advertisement in Spain.

Amsterdam & Partners LLP is an international law firm specialising in political advocacy and human rights, based in London and Washington, DC. For more information, please visit www.amsterdamandpartners.com. Media enquiries may be directed to contact@amsterdamandpartners.com.

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