María Antonia Azpeitia

María Antonia focuses on the full spectrum of tax controversy and indirect tax advisory work, assisting clients throughout every phase of national and international tax proceedings. Her litigation practice covers tax audits, voluntary disclosure procedures, administrative appeals, contentious administrative proceedings and landmark cases before Spain’s highest courts. She also represents clients in procedures before the European Court of Justice, formal complaints before the European Commission and Mutual Agreement Procedures arising under international tax treaties.

She also collaborates regularly with white collar crime specialists in risk assessment, prevention or defence matters related to tax criminal offences.

In the VAT and indirect tax sphere, María Antonia advises Spanish and multinational companies on day to day VAT matters, complex structuring issues, reorganizations, acquisitions, and the design and implementation of compliant tax models across multiple jurisdictions. Her work routinely involves navigating exemption regimes, cross border supply chains, EU harmonization rules and high value transactional VAT planning. Clients rely on her for clear strategic guidance in resolving disputes, mitigating risk and anticipating the tax implications of evolving EU jurisprudence and administrative practice.

She has also developed a particular specialization advising tech companies and digital taxation, including matters like digital services tax, TVE levy, deemed reseller regimes, etc.

• Advised several multinational groups in the tech, healthcare, tourism and manufacturing industries in their audits in Spain, having being able to secure positive settlements and, in some cases, leveraging in those settlements to obtain certainty for future years through Advance Price Agreements.
• Advised several financial institutions in a VAT dispute arising from a novel interpretation of EU case law, under which the Spanish Tax Authorities consider that head offices must charge VAT to their Spanish branches for intra group services, departing from traditional VAT treatment in the financial sector.
• Advised several multinational groups in the tech space on a comprehensive and highly technical permanent establishment (PE) analysis in Spain, assessing corporate income tax and VAT exposures across multiple business units and operational lines.
• Advised a multinational group in a tax audit covering VAT and transfer pricing matters, including the VAT implications of transactions reported for digital services tax (DST) purposes and the application of the use and enjoyment rule.
• Advised a global group in the insurance industry in a major corporate income transfer pricing dispute, including assistance during audits, local litigation and Mutual Assistance Procedures under the relevant Tax Treaty.
• Advised an international mobility services company in a Supreme Court cassation case concerning whether damage charges billed to customers constitute VAT taxable consideration or non taxable compensation, a matter with significant implications across multiple industries.
• Assisted several high net worth individuals in tax residency audits.
• Assisted several group entities in the accommodation industry in ongoing tax audit proceedings in Spain, covering both Transfer Pricing and VAT matters, while simultaneously advising on the design and coordination of the group’s VAT strategy at EU level to ensure consistency, risk mitigation and alignment with evolving regulatory trends.
• Assisted Spanish multinational groups in initiating withholding tax refund proceedings before the Portuguese tax authorities, achieving substantial refund claims coordinated from Madrid and executed locally by Portuguese counsel.
• Advised an aerospace company on the Spanish tax implications of a complex cross border restructuring aimed at establishing a joint venture with multiple international partners to create an independent European aerospace platform.
• Advised a global defence group in a major corporate income transfer pricing dispute, including assistance during audit and litigation.
• Advised a multinational digital technology group in a VAT audit concerning the application of the Spanish use and enjoyment rule, where the tax authorities relied on information sourced from new digital taxes to assess VAT on foreign generated revenues.

• Leading Partner, Tax, Legal 500, 2026
• Band 1, Tax: Litigation, Chambers and Partners Europe, 2026
• Band 1, Tax: Indirect Tax, Chambers and Partners Europe, 2026

• Madrid Bar Association