1 · Official March 2022 observation
The officers recorded that the complex was undergoing works and closed to the public on 22 March 2022. Pages 3 and 4 retain four photographs from that visit.
Direct documentary fact, limited to that date.
ADMINISTRATIVE SOURCE · 22 MAR / 6 APR 2022 · FIVE PAGES
The AEAT diligence fixes a source and a chain; it does not turn recorded statements into proved facts.
Customs Surveillance documented a Sun Park visit, four photographs and a business-channel account concerning ownership, operation, Booking, complaints, judicial award and tourism registration. Its decisive value lies in separating official observation from third-party statements and then testing what AEAT adopted.
Complete source located · neutral public copy
Audit result. The diligence expressly names Laura Acosta Matos, but does not name the male business interlocutor. It proves that statements were recorded; it does not by itself prove their accuracy, falsity, intention or tax effect.
Controlled reading
Four conclusions the document does support
2 · A divided business channel
A person at the site supplied a business telephone number. The diligence then records an account from an unnamed male interlocutor and, separately, statements attributed to Laura Acosta Matos.
The male identity remains open.
3 · Visible person/entity error
Page 1 refers to “a company called GIL MARER”. Gil Marer is a natural person; page 2 itself identifies Luchy Playa Blanca, S.L.U. as owner of the 159 apartments. Every legal person and capacity must therefore be controlled.
Objective internal contradiction.
4 · Registration is not revenue
The diligence recites a 1991–2014 tourism history. That matters, but does not alone establish who invoiced, collected bookings, controlled accounts or received hotel income in 2017–2018.
Important formal evidence, not a complete economic conclusion.
Exact attribution
Who said what—and what is needed to test it
| Source | Recorded content | What it proves | Evidence still required |
|---|---|---|---|
| Customs Surveillance officers | Visit, works, public closure, people supervising and four photographs. | Direct official observation of the visible condition on 22 March 2022. | Does not reconstruct 2017–2018 or itself identify operator, account or income. |
| Unnamed person at the site | Claimed association with the Acosta Matos channel and business contact route. | Recorded statement. | Name, exact company, role, authority and knowledge. |
| Unnamed male corporate interlocutor | 2017 credit purchase; award of 159 units; 49 other purchases; Booking advertising; alleged complaints, threats and blocked access. | That AEAT recorded that account. | Identity; deeds and unit schedule; Booking/PMS; police files; witnesses; dates and outcomes. |
| Laura Acosta Matos | 24 November 2021 Cabildo request; Gil/Monterecco/LPB relationship; challenge and alleged lack of consent to the 2014 change; claimed operation to 2018. | Named source and identifiable propositions. | Complete Cabildo request/certificate; capacity; documentary basis; entity-, period- and account-level comparison. |
| Recited, unappended Cabildo certificate | Sun Park S.A. 1991; Monte Lanza, S.L. 1996; Monterecco Sun Park, S.L. 2012; Owners' Community 2014. | That the diligence transcribes that sequence. | Native certificate, file, applications, 2015 challenge, decision and exact legal effect. |
Criminal and reputational limit. Booking, fraud, assault, threats and blocked access appear as third-party statements. The diligence contains no advertisements, reservations, complaints, police reports, judgments or statements from those said to have experienced the events.
Causation control
The diligence could inform the new assessment; it did not originate the inspection or supplementary action
29 Jul 2020
inspection plan
inspection plan
Nov/Dec 2020
commencement
commencement
7 Oct 2021
provisional zero result
provisional zero result
4/15 Mar 2022
supplementary action
supplementary action
22 Mar 2022
visit
visit
6 Apr 2022
diligence
diligence
Temporal conclusion. The 22 March contact and 6 April diligence could not have caused the 2020 selection. The supplementary action had already been ordered and notified. They could still have influenced the later narrative or evidential assessment; that requires a statement-by-statement reliance matrix.
Pink / AEAT
The issue cannot be answered with one undifferentiated “operator” label
Entity
Pink Canary Services, S.L.U.—formerly Monterecco Sun Park, S.L.U.—LPB, CEXP, the Owners' Community, Matkator, CAM and third-party owners are distinct persons or structures.
Function and period
Tourism registration, maintenance, reception, keys, bookings, marketing, ownership, security, works and preservation are not automatically the same function and cannot be moved between years.
Income
Tax attribution requires a bank or merchant account, PMS/OTA, invoice, contract, staff, customer, booking, beneficiary and period. The diligence does not supply that economic bridge.
Strong judicial-control point. The diligence supplies propositions capable of verification, but also reveals an express person/company confusion and blends owner, operator, creditor and award recipient. Independent verification was therefore required; the document alone establishes neither nullity nor culpability.
Document room
Five pages accounted for, accessible text and integrity chain
Public source
The received copy contained 27 later editorial highlights and 27 associated popup objects. The public version removes them so they are not mistaken for AEAT markings, rasterises all five pages and retains all four photographs.
Technical control
ID: EVID-AEAT-PINK-VA-20220406-001
Received-source SHA-256: b6ffc7cf…117bb16
Public-PDF SHA-256: 1698a080…5dbf2c9
Interconnection
Read the diligence through the correct lanes
Pink / AEAT · source auditPO 496/2026Material control · 7 June 2018Community and minutes2022 award / works
Right of correction. The original Cabildo certificate, police records, Booking data, deeds, banking records or authentic identification of the interlocutor that completes or contradicts this reading will be incorporated with equivalent visibility.