Fiscal year 2026 is shaping up less as a breaking point than as a stress test for different tax models. In Europe, the combination of moderate growth, high debt, and political constraints is narrowing the room for maneuver. In Latin America, the tension is divided between macroeconomic stability, the need to attract investment, and structural pressures on public spending.

More than major reforms, what defines 2026 is how each jurisdiction manages stability: whether it uses it as leverage to attract capital, as in Paraguay; whether it transforms it into a silent tax burden, as in Spain; or whether it jeopardizes it due to persistent fiscal imbalances, as in Colombia. In the words of Luis Carísimo, head of the Tax Department at Altra Legal, “the tax discussion no longer revolves solely around taxes, but also around predictability, confidence, and institutional quality.”

This common thread allows us to read in parallel very different realities, Spain, Andorra, Paraguay, Colombia and Peru, but connected by the same global context: greater scrutiny, more active tax administrations and a growing demand for sophisticated planning.

Spain: tax revenue on the rise without major reforms

Spain enters 2026 with no political leeway for a profound fiscal overhaul, but with increasing tax pressure from other sources. With estimated growth of 2.9% and public debt nearing 100% of GDP, the fiscal debate is shifting from regulatory reform to administrative management.

Paradoxically, this paralysis doesn’t prevent tax revenue from continuing to grow. “Tariffs aren’t being adjusted for inflation, and the Tax Administration is exceptionally motivated; that explains a good part of the increase in revenue,” notes José María García Guirao, partner at Devesa. The increase in revenue is occurring without major legislative changes, which raises the effective tax burden without sparking an explicit political debate.

Internationally, Spanish fiscal policy is more influenced by Brussels than by Madrid. “Spain largely mirrors EU policy; Trump’s trade war was more of an initial phenomenon than a sustained trend,” notes García Guirao. Sectors most exposed to trade tensions have begun seeking alternative markets, a costly process in the short term, but manageable in the medium term.

From a practical standpoint, Devesa structures its advisory services around comprehensive assessments. Reviewing holding company structures, optimizing assets through SOCIMIs or SCRs, and conducting detailed analyses of the VAT impact in sectors with exempt activities allow for the design of frameworks capable of absorbing future changes. This is compounded by the increasing volume of tax litigation, in a context where the tax authorities adopt aggressive criteria that are not always upheld by the courts.

Andorra: competitive taxation under greater scrutiny

Andorra represents a unique model within the analyzed tax landscape: lower volume, stricter controls, and an explicit commitment to long-term stability. Carlota Pastora, managing partner of Carlota Pastora Business Law Firm, identifies 2026 as a turning point following the approval of the second Omnibus Law, which substantially tightens the passive residency regime and redefines the profile of the international resident.

“It’s no longer enough to just move. Relocation requires real tax planning, analysis of the country of origin, and absolute compliance.”

The requirement for a high minimum investment, along with non-refundable entry fees and the expansion of the automatic exchange of tax information with the European Union, which from 2026 includes crypto assets, electronic money and digital currencies, has raised the level of scrutiny and put an end to any standardized approach.

Far from seeing this tightening as a hindrance, the firm interprets it as a strategic opportunity. “The new requirements are very selective: there will be less volume, but they attract people with substantial wealth who are looking for long-term commitment, exceptional quality of life, and serious estate planning. That’s positive for us, because these are clients with greater commitment and loyalty,” he explains.

In the area of passive residence, Pastora points out that the historical profile was already long-term and that the regulatory changes “further reinforce that trend”.

Regarding growth projections, the firm avoids triumphalist interpretations. “With such recent legislative changes, it’s too early to give an exact numerical forecast. We’ll first see how everything evolves over the next six months, because the client profile will clearly change,” they point out. The focus is not on the volume of cases, but on the quality and depth of the advice.

This same principle applies to the real estate sector. After several years of rising prices due to land scarcity, the recent Omnibus Law should, in Pastora’s opinion, help stabilize the market and benefit local residents. “Our growth doesn’t come from massive real estate transactions. When we work with properties, we provide comprehensive support, from due diligence to complete wealth planning,” she explains.

The firm’s strategic commitment for 2026 also involves the real integration of artificial intelligence in international tax advice and wealth planning.

“AI is becoming a silent partner that eliminates repetitive tasks and frees up time for what’s essential: understanding the customer, negotiating with government agencies, and designing unique solutions.”

In his opinion, the use of these tools allows for the simulation of succession scenarios, the modeling of cross-border tax impacts, and the anticipation of risks, always with full human supervision.

Pastora’s leadership and her more than 15 years of experience in international taxation have been key to consolidating the firm’s position in the Iberian market. “With tenacity and passion. We are not just another law firm; we are the ideal partner for the Iberian market,” she summarizes. This strategy has resulted in a strong connection between Andorra, Spain, and Portugal, supported by stable alliances with firms in both countries.

“My approach has always been to stay one step ahead: anticipating regulatory changes, training the team in preventative measures, and building lasting relationships of trust. The result is clients who don’t come for the price, they come for peace of mind and real results,” he adds.

The firm’s growth rests on two pillars that Pastora considers essential: absolute personalization and a trusted international network. “Each HNWI client is a unique case; there’s no one-size-fits-all approach,” she states. The firm’s activity is primarily cross-border and relies on collaborations with firms in Spain, France, Portugal, Luxembourg, the Netherlands, Germany, Switzerland, and the United Kingdom, allowing for seamless management of tax, inheritance, and international contracts.

This approach translates into a comprehensive response to clients’ needs, both in direct and indirect taxation as well as in business operations. “We work with a 360° and preventative approach. Clients don’t want surprises; they want to sleep soundly knowing that their business and assets are protected and growing,” he says.

For 2026, Pastora clearly identifies the area with the greatest growth. “Without a doubt, cross-border estate planning will continue to be the fastest growing. Families choose Andorra to properly organize their succession, minimize their tax burden, and take advantage of structural benefits such as the absence of wealth and inheritance taxes.”

Growth and discipline: the Paraguayan case

Paraguay enters 2026 as one of the few cases in the region where fiscal stability is not just rhetoric, but a verifiable reality. With projected growth of 4.2%, the country has consolidated a track record of macroeconomic discipline that culminated last December with Standard & Poor’s awarding it an investment grade rating (BBB-), following the Baa3 rating with a stable outlook granted by Moody’s in 2024.

For Luis Carísimo, head of the Tax Department at Altra Legal Paraguay, the impact of these ratings goes far beyond reputation. “Investment grade is a concrete signal for investors: it reduces the cost of capital, allows for long-term planning, and strengthens the credibility of the tax framework,” he explains. Unlike other economies in the region, Paraguay does not face the need for abrupt fiscal adjustments or emergency tax reforms in 2026.

This positioning is supported by regulatory modernization geared towards productive investment. The comprehensive update of the Maquila regime, the reform of the incentive regime for productive investment (formerly Law 60/90), and the enactment of a specific law for the production and assembly of electrical, electronic, electromechanical, and digital goods constitute a coherent regulatory package.

“It’s not just about attracting capital, but about doing so under international standards, with job creation and technology transfer,” Carísimo points out.

From a fiscal perspective, the logic is clear: broaden the economic base rather than increase the tax burden. “The combination of tax stability, clear rules, and an improved country risk rating allows for increased revenue without raising taxes,” he summarizes. This approach is especially relevant in a regional context where many countries face persistent deficits and pressure to increase the tax burden.

Externally, Paraguay maintains relatively limited exposure to financial volatility and global trade shocks. Its export profile, concentrated in commodities and food, and the absence of trade retaliation policies provide it with room to maneuver. “We don’t foresee an emotional fiscal reaction to potential tariffs or international tensions; the strategy remains to preserve confidence and predictability,” Carísimo emphasizes.

From a professional standpoint, Altra Legal has aligned its strategy with this period of stability. The firm actively participates in the structuring and execution of projects under the new regulations, provides technical training for investors and institutional stakeholders, and supports its clients in their dialogue with the authorities. According to Carísimo, the focus is on “combining legal certainty, tax efficiency, and long-term sustainability” in an environment where Paraguay seeks to consolidate its position as a regional investment platform.

Colombia: Fiscal Uncertainty and Structural Pressure

Colombia enters 2026 facing a particularly delicate combination of circumstances: political uncertainty, accumulated fiscal deterioration, and an increasingly demanding regulatory environment. Unlike Paraguay, where stability is an asset, fiscal stability in Colombia is under discussion. The electoral calendar, with legislative elections in March and presidential elections in May, directly influences the tax debate.

Javier Blel, a partner in Tax Controversy at Deloitte Colombia, is emphatic: “Dismissing the need for tax reform would have immediate effects. Without adjustment measures, the fiscal deficit could exceed 8% of GDP, surpassing the limits of the fiscal rule.” This scenario would not only strain public finances but also send a negative signal to investors and rating agencies.

The problem, however, goes beyond a single reform. “Colombia must discuss not only how much to collect, but how and on what it is spent. The size of the state, the efficiency of spending, and investment priorities can no longer be postponed,” Blel adds. Even with a reform approved in the second half of 2026, fiscal sustainability will continue to depend on structural decisions regarding public spending.

In this context, the pressure on taxpayers is intensifying. Tax authorities have increased audits, massive data cross-checks, and penalty procedures. “We are seeing more in-depth inspections, stricter technical criteria, and enforced collections with increasingly stringent deadlines,” explains Blel. The consequence is a significant increase in tax litigation, especially regarding transfer pricing, customs audits, and official assessments.

The trade dimension adds another layer of risk. Claudia Garzón, partner in Indirect Taxes and Foreign Trade at Deloitte Colombia, warns that “Colombia starts from a more vulnerable position vis-à-vis the United States due to its trade deficit. Any slowdown in exports is felt more quickly.” This is compounded by regional tensions, such as the reciprocal tariffs between Colombia and Ecuador, which could immediately affect bilateral trade flows.

From a regulatory perspective, the compliance environment is also becoming more stringent. Esteban Jiménez, partner at Deloitte Legal, anticipates a significant transformation:

“The regulator is moving towards an integrated risk management model. Companies will need to redesign their compliance systems to avoid falling behind in an environment of greater scrutiny.”

The integration of risks of money laundering, corruption, terrorist financing and environmental and social factors points to a more cross-cutting supervision model that is aligned with international standards.

Given this scenario, Deloitte has reinforced a comprehensive approach that combines tax strategy, risk management, regulatory compliance, and advocacy. According to Blel, the priority is clear:

“Helping companies anticipate, not just react, in an increasingly complex and demanding tax environment.”

Peru: regulatory stability, increased litigation

Peru faces 2026 from a formally stable position, but with tax pressure that manifests itself administratively. No significant tax reforms are expected in the short term, largely due to the political situation and the upcoming presidential elections.

Arturo Tuesta, Tax Partner at Deloitte Peru, summarizes it like this:

“We do not anticipate any significant changes in tax legislation by 2026.

If they were to occur, they would be promoted by the next government and would have effects mainly from 2027 onwards.” This regulatory stability, however, does not translate into less conflict.

On the contrary, the National Superintendency of Customs and Tax Administration (SUNAT) has intensified its auditing activity.

“The tax authorities are increasingly prioritizing formal aspects over the economic substance of transactions, which is increasing tax disputes,” Tuesta points out. The main areas of focus are transfer pricing, the veracity of transactions, the application of the general anti-avoidance rule, and the intensive use of information from international exchange mechanisms.

This increased scrutiny is forcing companies to strengthen their internal processes and their responsiveness to government regulations. At Deloitte, the strategy involves anticipating risks and leveraging technological tools. “New technologies, including artificial intelligence, will play a key role in managing tax information, responding to requests, and assessing contingencies more accurately,” explains Tuesta.

The result is a scenario in which Peru combines regulatory predictability with a clear increase in litigation and compliance costs. A less turbulent environment than Colombia’s, but not without risks for businesses and investors.

Una lectura transversal

More than a year of reforms, 2026 will be a year of testing for existing tax models. A look at these jurisdictions reveals a common pattern: less room for improvised reforms and more pressure to manage what has already been built. Spain faces the year with rising tax revenues but no political capacity for major reforms, relying on the tax administration as its main lever. Andorra, at the opposite extreme, is tightening access to taxation to preserve a competitive tax model based on selectivity, planning, and a long-term perspective.

Paraguay stands out as a regional exception, capitalizing on macroeconomic stability, investment grade status, and clear rules to attract productive investment without increasing the tax burden. Colombia, on the other hand, reaches 2026 with very tight fiscal space and the unavoidable need to redefine its balance between revenue, spending, and state sustainability. Peru maintains a stable regulatory framework but shifts the pressure to the administrative arena, with more intense oversight and increased litigation.

Beyond the differences, the common thread is clear. 2026 will not be a year of major tax revolutions, but rather one of adjustments, compliance, and strategy. For companies and investors, the key is no longer just where to pay less, but which jurisdictions offer predictable, consistent, and sustainable rules.