COURT RECORD · PROCEDURAL STATUS · NO MERITS OVERSTATEMENT

Pink Canary / AEAT: Audiencia Nacional PO 496/2026.

This is a distinct tax-administrative judicial proceeding involving Pink Canary Services, S.L.U. It is not conflated with the general 2021 tax notice, other AEAT registrations or any separate criminal provenance route.

Controlled status: the primary court record reviewed establishes the ordinary proceeding and a linked interim-measures incident. The 6 July 2026 order refused the requested suspension. It did not decide the merits of the ordinary proceeding.

What the primary court record establishes

Date / referenceProcedural factLimit
8 Aug 2024The later court order records a nullity request addressed to the AEAT Regional Inspection Office in Tenerife concerning files CO000952499 and A5179591986.Filing alone does not establish the merits of that request.
2026 · PO 0000496/2026Audiencia Nacional · Contentious-Administrative Chamber · Section 7. NIG 28079 23 3 2026 0002648. Claimant: Pink Canary Services, S.L.U.; defendant: State Administration / Ministry of Finance. Subject identified in the order: collection.The existence of judicial review establishes a live procedural route, not that either side is correct.
6 Jul 2026 · Order 00426/2026 · PSS 0000496/2026 0001The Chamber declined to suspend the challenged presumed dismissal by negative administrative silence. No costs were imposed.The order concerns interim relief only. It does not resolve the legality of the underlying tax acts or the merits of PO 496/2026.

Source control: the 6 July 2026 order was reviewed from the native court-notification attachment carrying the 496/2026 reference. Counsel emails, drafts and predictions are not reproduced.

What this record does not establish

The reviewed order does not establish a tax offence, fraud, validity or invalidity of the underlying assessments, entitlement to repayment, final liability or the outcome of PO 496/2026. It also does not convert the separate Sun Park / RICPE / AEAT notice history into this litigation.

The correct distinction is between the AEAT notice and registration history, the Pink / AEAT contentious proceeding, and separate provenance questions about third-party statements. Evidence may overlap, but the lanes, objects and standards do not become identical.

Connected new primary source

The Customs Surveillance diligence formalised on 6 April 2022 records a 22 March visit, four photographs, and statements attributed to an unidentified male interlocutor and, separately, Laura Acosta Matos. It proves that those observations and statements were recorded; it does not itself prove every account, the male identity, or who comprehensively operated or earned Sun Park income during 2017–2018.

The diligence post-dates the commencement of the 2020 inspection and the March 2022 decision to extend the investigation. It could not have originated those steps; any influence on the later assessment requires the complete file and a statement-by-statement reliance matrix.