The Spanish law establishes the obligation to disclose information to the Spanish Tax Administration regarding:

(a) Cross-border arrangements containing any of the hallmarks listed in Annex IV of Directive 2011/16/EU.
(b) Updates on marketable cross-border arrangements.
(c) The use in Spain of such cross-border arrangements.
(d) CRS avoidance mechanisms and opaque offshore structures covered by the OECD model rules and the Multilateral Competent Authority Agreement.

The provision clarifies that arrangements based on tax regimes expressly approved by the European Commission are excluded. Certain intermediaries may be exempt from reporting if bound by legal professional privilege, although they must notify the relevant taxpayer. The law also establishes a sanctioning regime: failure to report, late reporting, or providing incomplete/false information constitutes a serious tax infringement, punishable with fixed monetary penalties (generally €2,000 per item, with minimums of €4,000 and maximums linked to fees earned or tax benefits obtained).