The Spanish Central Tax Appeal Board (TEAC) has confirmed that foreign entities operating in Spain, even without a permanent establishment in Spain, are required to communicate electronically with the Spanish Tax Authorities.
In the matter in question, a Dutch company had transferred a property in Spain and disputed the validity of an electronic notification sent to its representative. The TEAC has confirmed that the notification is fully valid and that the appeal lodged months later was correctly dismissed as time-barred.
Practical conclusion: the Administration may notify foreign entities not established in Spain electronically through their representative in Spain, and these communications have full legal effect.
Recommendation: before starting any activity in Spain, it is essential that foreign entities obtain a tax identification number (NIF) and an e-signature certificate in order to avoid problems in receiving notifications and complying with their tax obligations.