Amsterdam & Partners Exposes Tax Agency's Millions in Performance Bonuses

The letter accusing the Tax Agency of paying bonuses for higher collections

What is the cost of disputing a tax assessment with the Spanish Tax Agency (AEAT)? It costs more than money: it costs time, health, and, in too many cases, the business itself. The legal offensive led by the firm Amsterdam & Partners against the AEAT has brought to light a rarely discussed figure: in 2024, the agency paid over €280 million in bonuses and incentives to its staff. In 2025, management and unions agreed to an extraordinary €125 million bonus to incentivize income tax (IRPF) and VAT collections to exceed economic growth. Paying for higher revenue, in raw terms.

The figure appears in a letter signed by lawyer Robert Amsterdam and addressed to the AEAT’s Director General, Soledad Fernández Doctor, as part of a major lawsuit accumulating testimonies from foreign and domestic taxpayers. The document argues that these incentives turn the inspection function into a race for targets, with the taxpayer as the opposing party. This is the central accusation. And, for now, just an accusation.

Incentives that turn inspectors into revenue collectors

The criticism is not that bonuses exist, but what they are linked to. The most repeated argument: if the bonus depends on revenue collected, the incentive shifts from fighting fraud to finding taxable income wherever possible, regardless of whether a court ultimately rules in the taxpayer’s favor. Some add a second layer to the problem: when the taxpayer wins, the agency itself (i.e., all taxpayers) pays the indemnity, not the official who handled the case. The asymmetry, they argue, is the system’s engine.

And here lies the core of this issue: the tax itself is not disputed; the procedure is. That is why the case has moved from the fiscal sphere to discussions on legal insecurity.

Beckham Law: Those who came to work ended up in court

The special regime for displaced workers, known as the Beckham Law, has generated a string of cases resulting in public testimonies. Under pseudonyms, stories like those of “Anna,” who broke her silence, “Michael,” and “Lars,” a Swedish professional who summarizes his experience in a self-explanatory phrase: “We wanted to work and contribute, but we were paid with threats and humiliation.” These are partial accounts, covered by economic press and awaiting judicial resolution.

The pattern they describe is common: successive requirements for documentation already submitted in the initial process, shifts in criteria regarding tax residency, and defense costs that, in practice, turn legal rights into a luxury few can afford.

Shifting criteria and the Supreme Court

The most cited case is that of Xabi Alonso, acquitted by the Supreme Court after years of litigation regarding the transfer of his image rights to a company in Madeira. The high court concluded, according to the widely circulated account, that without proof of intent to defraud or simulation, there was no infringement. The question hovering over the case is uncomfortable: if what was legal yesterday becomes illegal due to a change in administrative criteria, what exactly are we discussing when we talk about legal security?

There is another contrast repeated in the debate: inspections peine and immediately suspended in the case of a former prime minister, according to La Razón citing data from the GESTHA technicians’ union. The comparison proves nothing on its own. But it fuels the perception of two different standards.

Paying to get refunds: the advice born of antiestéticar

Among the numerous accounts, one paints a clearer picture than any statistic of the described climate. The advice of a tax advisor to a self-employed worker, repeated for 25 years: never file a return that results in a refund. Better to pay something, even if small, than to become a target. Another case: a bank account with about €500 in Spain, blocked after failing to provide data on residence and foreign income. No phone calls, no formal notices recalled.

And in the background, an administrative detail already a recurring joke. The “wonderful tool” the agency provides taxpayers is a search engine that understands no questions not pre-designed. The system it uses to cross-check data, however, is top-tier. A curious distribution of resources.

Denmark is not the paradise sold

The international counterpoint is also on the table. Those defending the Nordic model recall that taxes are higher, but administration is predictable and services work. Those attacking it respond with figures: 25% VAT, 180% registration tax, and family holding structures where, as long as money does not leave, no tax is paid. The result, they argue, is always the same: the bill is ultimately paid by the average salary, not well-structured wealth.

And Spain? With these premises, the average taxpayer’s reaction is not to protest. It is to watch the door. Or to pay and stay silent, even if legally right. The latter is cheaper.

---

And so we have gone for years: rewarding those who collect more and calling exemplary citizens those who do not ask questions.