Minutes of the meeting

MINUTES OF THE MEETING OF THE PLENARY SESSION OF THE FORUM OF ASSOCIATIONS AND
COLLEGES OF TAX PROFESSIONALS
HELD ON JULY 3, 2018

President of the Forum of Associations and Colleges of Tax Professionals

Director General of the State Agency for Tax Administration

Mr. Jesus Gascon Catalan

Members representing the Tax Agency

Director of the Tax Management Department

Mr. Rufino de la Rosa Cordon

Director of the Department of Financial and Tax Inspection

Mr. Luis Mª Sánchez González

Director of the Revenue Department

Mr. Guillermo Barros Gallego

Director of the Tax Information Technology Department

Mr. Manuel Alfonso Castro Martínez

Director of Legal Services

Mr. Diego Loma-Osorio Lerena

Director of the Planning and Institutional Relations Service

Mrs. Rosa Maria Prieto del Rey

Tax Inspector of the General Subdirectorate of Management and Intervention of II. EE. – Customs Department and II. EE.

Mrs. María Sánchez-Cervera Valdés

Members representing Associations and Colleges

Spanish Association of Tax Advisors

Director of the Office of Studies

Ms. Lucia Torrejon Sanz

Member in charge of Studies and Research

Mr. Javier Gomez Taboada

Professional Association of Accounting and Tax Experts of Spain

Delegate of Madrid

Mr. José Antonio Fernández García-Moreno

General Council of Colleges of Customs Agents and Brokers

Secretary of the Board

Mr. Manuel Lopez Frias

General Council of Colleges of Administrative Managers of Spain

Head of the Tax Department of the General Council

Ms. Pilar Otero Moar

General Council of Official Colleges of Social Graduates of Spain

Member of the Fiscal Affairs Committee

Mr. Jose Castaño Semitiel

Member of the Fiscal Affairs Committee

Mr. Jose Ruiz Sanchez

Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors

Chairperson

Mr. Joan Torres Torres

Deputy to the Presidency

Mr. Jose Luis Carreras Torres

Office of Administrative Managers and Tax Advisors

Lawyer

Mrs. Raquel Cobos Casero

General Registry of Tax Advisors / Registry of Tax Advisor Economists

Vice President of the Board of Directors

Mr. Miguel Angel Ruiz Ayuso

Technical Secretariat of the Forum of Associations and Colleges of Tax Professionals

Deputy Director General of External Communication – Planning and Institutional Relations Service

Mrs. Maria Dolores Carreno Beltran

In Madrid, on July 3, 2018, the thirteenth plenary meeting of the Forum of Associations and Colleges of Tax Professionals is held, attended by the persons mentioned above, and in accordance with the following

AGENDA

1. Opening by the Director General of the State Tax Administration Agency.
2. Approval of the minutes of the meeting held on 28 November 2017.
3. Code of Good Practices for Tax Professionals: improvement proposals.
4. Provisional balance of the IRPF 2017 campaign.
5. Other considerations, requests and questions.

1. Opening by the Director General of the State Tax Administration Agency.

The session was opened by Mr. Jesús Gascón Catalán, General Director of the State Tax Administration Agency and President of the Forum of Associations and Colleges of Tax Professionals, who, after welcoming and thanking everyone present for their attendance, apologised for not having been able to contact each of the attendees prior to the plenary session, while expressing his complete willingness to assist the Associations and Colleges represented at the Forum. He then points out that what is important is not the people but the Institutions and, in this sense, he indicates that the Tax Agency committed itself more than a decade ago to cooperative mechanisms, aligning itself with the most advanced countries of the European Union and the OECD , this being the line of work that will continue to be promoted. He goes on to point out that the relationship between the Tax Administration and taxpayers, as well as with the professionals who represent them, must be fluid, bidirectional and with an ever-increasing degree of trust, and that this Forum can serve as a channel for achieving this new model of relationship. Mr. Jesús Gascón adds that change is not optional and that the Administration has to move forward, since continuous transformations occur in society, and must work to face new challenges such as the transposition of the DAC6 or the modifications in VAT . Likewise, progress must be made in developing cooperation mechanisms that reinforce legal certainty, with the role of tax professionals being key in this work. Finally, he proposed opening a round of interventions so that attendees could make their comments.

Mr. José Ruiz Sánchez, representative of the General Council of Official Colleges of Social Graduates of Spain, took the floor and, after congratulating the Director General on his appointment, expressed his interest in continuing close collaboration between both parties. He goes on to point out that tax professionals need to be heard, since in their daily work they maintain a very direct relationship with the Administration, being able to provide solutions to problems that they sometimes encounter, which would be to the benefit of their clients and, therefore, of the Administration and of the tax professionals themselves.

Mr. Jesús Gascón intervened to point out that in terms of cooperative relations, progress will continue to be made along the same lines as his predecessors, since this is an institutional objective of the Tax Agency, regardless of the person who heads it.

Mr. José Castaño Semitiel, also a representative of the General Council of Official Colleges of Social Graduates of Spain, took the floor. He indicated that social collaborators want to take advantage of the opportunity offered by the Forum to address issues of interest to them and reiterated the request to have representatives of the General Directorate of Taxes in it.

In relation to this request, the Director General of the Tax Agency points out that, although this Forum is focused on the Tax Administration, there is no problem with the General Directorate of Taxes being able to participate in any working group.

Ms. Raquel Cobos Casero, representative of the Cabinet of Administrative Managers and Tax Advisors (GESAF), took the floor, followed by Ms. Pilar Otero Moar, representative of the General Council of Colleges of Administrative Managers of Spain, who, after congratulating Mr. Jesús Gascón on his recent appointment, joined the requests made by their colleagues, pointing out the need for their proposals to be analyzed and taken into account.

Next, Mr. Miguel Ángel Ruiz Ayuso, representative of the General Registry of Tax Advisors and the Registry of Tax Advisory Economists (REAF – REGAF), spoke. After congratulating the General Director on his appointment, he offered the collaboration of the organization he represents to enhance the activity of the working groups, make progress on the problems that their daily practice presents to them and promote bilateral relations with the Administration.

Mr. Joan Torres Torres, representative of the Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors (FETTAF), took the floor. He joined his colleagues in highlighting the need for a good relationship between tax professionals and the Tax Agency, as well as the possibility of the latter acting as a spokesperson before the Ministry or other administrative bodies, and even before the Cortes, to convey its concerns.

Mr. Jesús Gascón intervened to state that they will certainly find common ground on issues such as legal certainty, simplification of the tax system, etc., as these are common concerns, because what constitutes a burden for the taxpayer and for the professionals who advise him, is often also a burden for the Administration itself.

Next, Mr. José Luis Carreras Torres, also representing FETTAF, spoke, and agreed with what had already been said in previous interventions.

Mr. Manuel López Frías, representative of the General Council of Customs Agents and Brokers, took the floor. After reiterating his congratulations to the new Director, he explained that his association has always considered itself a collaborator of the Administration and considers this Forum to be of the utmost importance, since it includes a list of tax professionals from this country, where they can be heard and their proposals taken into account.

Mr Jesús Gascón intervened to indicate that the customs area is a good example of the need to combine controls with trade facilitation. The Tax Agency must ensure compliance with tax obligations, but without affecting the normal development of its economic activity, and it is in this area that common ground must be sought, extending the customs model to other areas.

Mr. José Antonio Fernández García-Moreno, representative of the Professional Association of Accounting and Tax Experts (AECE), took the floor and added to what was already commented in previous interventions.

Next, Mr. Javier Gómez Taboada, representative of the Spanish Association of Tax Advisors (AEDAF), intervened. He agreed with what his colleagues had said and added that his Association considers it important to take advantage of the Forum to better understand both parties and highlights the firm and proven commitment of all the Associations and Colleges represented to professionalism in the exercise of tax advice. He goes on to point out that, as the first implementers of the tax system, they reject fraud and combat it by carrying out necessary and daily educational work with their clients, and thus support the Tax Agency in this task. On the other hand, Mr. Javier Gómez points out that the desirable cooperation is necessarily built between two parties, the Tax Agency and the advisors, the latter as representatives of the taxpayers, mutual trust being necessary to achieve a fruitful relationship. The AEDAF representative then briefly comments on some relevant cases in the tax field that have occurred in recent times and which he considers paradigmatic:

• The Supreme Court, with the new regime of appeals, has denounced various administrative practices that have ignored judicial interpretations, some of them issued by the Supreme Court itself.
• The members of the Central Economic Administrative Court have been in office for almost a year.
• The Tax Agency loses one in every two lawsuits before the Economic-Administrative Courts or the Courts of Justice, and this in a country where, by legal imperative, administrative activity is endowed with a presumption of legality, certainty and validity.
• Spain has received several blows from the European Union in terms of taxation, but this has not had any particular consequences.
• Last May, thirty-five professors of tax law denounced that the tax situation in Spain has meant the degradation of the citizen to a subject.

Mr Jesús Gascón took the floor to point out that, indeed, what is involved is highlighting the problems that arise in order to find solutions. He continued his intervention by positively assessing the existence of a new appeal before the Supreme Court that rectifies or ratifies the criteria of the Tax Agency, although it would be desirable for the process to end sooner, with clearer rules and more agile resolution procedures. Mr. Jesús Gascón adds that litigation is a matter of particular concern, since the fact that resolutions contrary to the criteria of the Tax Agency are produced means that the actions of the Administration have not been desirable. As for the figures, Mr. Jesús Gascón indicates that, at this time, one in three files that reach the Courts are annulled. Although it is true that the statistics give a higher figure, this is due to the fact that there are claims that come from other bodies and from other taxes, especially those transferred, which have a very high level of conflict, which distorts the figures. However, and regardless of the statistics, it is a fact that there is a high level of litigation with a significant number of rulings against the Tax Agency that should be avoided, for which a lot of dialogue is necessary. Finally, the General Director expressed his gratitude for the collaboration shown by the professionals in this task.

2. Approval of the minutes of the meeting held on 28 November 2017.

The President of the Forum gives the floor to Ms. Mª Dolores Carreño Beltrán, head of the Technical Secretariat of the Forum, who states that the minutes of the 12th plenary session were sent to the Associations and Colleges so that they could send their comments to it. GESAF sent comments that were incorporated into the text and communicated to the other participants in this Forum. For its part, AEDAF reported that it had objections to the wording of the minutes, although these would be presented at the Plenary Session. He then gives the floor to the representatives of AEDAF.

Mr. Javier Gómez Taboada took the floor and began his presentation by explaining that his Association reserved the right to make its observations public until the holding of this Plenary Session because they go beyond the drafting of the minutes themselves and even affect another point on the agenda. He goes on to comment that, as far as the minutes are concerned, AEDAF's objection is to point IV, which literally says " Next, Mr. Santiago Menéndez submits the Code of Good Practices for Tax Professionals to the vote of the Plenary Session, which was approved by the majority, with the abstention of GESAF and the vote against of AEDAF and REAF-REGAF. Thus, the President of the Forum declares that the Code of Good Practices for Tax Professionals is approved ”. Mr. Javier Gómez Taboada adds that the Forum's operating rules in section III.1.7 provide that “ Agreements will always be adopted by consensus between those attending the Plenary meetings ” and that the RAE dictionary defines consensus as “ agreement produced by consent between all members of a group ”, so AEDAF understands that the Code of Good Practices could not be approved, since there were two associations that voted against it. For all these reasons, AEDAF expresses its opposition to the drafting of the minutes in these terms, refusing to approve them and requesting that these reasons be incorporated into the minutes of the 13th session.

Next, Mr. Miguel Ángel Ruiz Ayuso, representative of REGAF-REAF, intervened to point out that the Registry of Economists shares the opinion of AEDAF, adhering to its proposal.

Mr. Manuel López Frías then took the floor and indicated that the Working Group had been going through numerous versions of the text of the Code, in which the observations proposed by the associations had been collected, arriving at a document with which the majority agreed and, therefore, it was put to a vote, so that it would be recorded.

At this point, several meeting participants gave their opinion on the term “consensus” and the meaning with which it was included in the Forum’s operating rules, in their respective opinions.

The Director of the Planning and Institutional Relations Service then intervenes, indicating that “consensus” is a vague term since it is not a legal concept, but that, since it is stated in the operating rules, it will be necessary to adhere to it. The text of the minutes of the 12th plenary session will therefore be amended.

Mr. Jesús Gascón then took the floor to indicate that, in his opinion, on a topic of this importance, a good image would not be conveyed if the Code were not approved by consensus, understood as unanimity. However, in the future, mechanisms for enhanced cooperation and approval by simple or qualified majority on certain issues could be proposed, as the European Union itself has done, while maintaining, however, the need for consensus on nuclear issues. Mr. Jesús Gascón continued his intervention by stating that it is important that the Associations that do not agree with the Code convey their observations, so that the desirable unanimity can be obtained.

Mr. Javier Gómez takes the floor and points out that AEDAF's opposition to the Code of Good Practices is an amendment to the whole and its arguments are the following:

1. The rules of operation of this Forum provide that the agreements adopted will not have binding legal effects, and therefore do not consider the Forum to be an appropriate instrument for arbitrating a relationship that will generate rights and obligations.
2. The establishment of a relationship between the Tax Agency and the advisors, of the kind that is intended, should be developed in another area that, among other aspects, could even include the regulation of the exercise of tax advice in Spain.
3. The text reveals a clear inequity between the commitments required of tax advisors and those assumed by the Tax Agency.
4. The so-called collaborative spirit is not implemented with the approval of a Code, but rather, first of all, it is necessary to generate an appropriate environment of mutual trust, which is not precisely the scenario in which they find themselves in the development of their activity.
5. The transposition of DAC6 seems to be the ideal opportunity to arbitrate the scenario in which tax advice can be developed under parameters of trust and security. They consider that doing so now, through the Code, is an unnecessary and hasty anticipation of a debate that will undoubtedly have to be addressed.

Next, Mr. Miguel Ángel Ruiz Ayuso intervenes, pointing out that his entity does not have a position as clear as that expressed by the representative of AEDAF, since, within his organization, a process of reflection on the Code is being carried out, assessing the content with which they agree and with which they could approve the text.

Mr. Manuel López Frías then intervened, addressing the representative of AEDAF, pointing out that the arguments presented were not, however, expressed in the meetings held in recent years in relation to the Code, and adding that, in his opinion, AEDAF's position would imply starting from the beginning again.

Next, Mr. Joan Torres takes the floor and shares what Mr. Manuel López Frías has said. He added that if the operating rules establish consensus, there will have to be one, but, given that the majority is in agreement, he does not consider that there is sufficient reason to paralyse the approval of the Code. On the other hand, Mr. Joan Torres points out that, in the 12th plenary session, the representative of AEDAF voted against the approval of the text due to some definitions included in it that, however, were not presented in today's session.

Mr. Manuel López Frías intervenes again to add that Spain has to make progress in terms of cooperative relations and the Code of Good Practices represents an opportunity for dialogue between social partners and the Administration, since it is a living text that will be perfected by all. It also provides a framework in which tax professionals will be able to present various aspects of their activity, which is why it reiterates its disagreement with the suspension of the Code.

Mr. José Ruiz Sánchez, representative of the General Council of Official Colleges of Social Graduates of Spain, then took the floor to reiterate his organization's agreement with the text of the Code of Good Practices.

Mr. Jesús Gascón takes the floor and briefly reflects on the Code of Good Practices approved by the Forum of Large Companies, pointing out that, in this case, a framework document was approved with a certain level of commitments and from there other mechanisms for developing the cooperative model have been created. He goes on to point out that currently the number of entities that have signed up is around 135, which means that there are many entities that have not signed the Code, but there are also many others that have shown a greater level of commitment by presenting the so-called “Annual Report on Fiscal Transparency”. To conclude, Mr. Jesús Gascón proposes developing a similar model with a modular structure in this Forum. To do this, it would be necessary to identify which part of the current text would be acceptable to all members of the Forum and, from there, move towards a model where each person could place themselves in the module they consider most appropriate.

Mr. Miguel Ángel Ruiz Ayuso takes the floor to state that REAF – REGAF agrees with this proposal.

Next, Mr. Manuel López Frías intervened, expressing his agreement with the current text and clarifying that, as a College of Professionals, they have an individualized Code of Good Practices. He added that it is necessary to move forward and that while it is true that the current text of the Code of Good Practices can be improved, it is necessary to have a starting point.

Next, Mr. Jesús Gascón took the floor and, in relation to what was stated by Mr. Manuel López Frías, added that, precisely, the fact that all organizations have an internal code of conduct is indicative of the fact that it is possible to find a minimum common denominator that can be reflected in a document. On the other hand, it indicates that the Tax Agency is open to receiving proposals in relation to the commitments that each Association or College would assume, in order to achieve a minimum consensus and from there advance through a modular system. In this regard, it requests that the proposals considered appropriate be sent to the Tax Agency and proposes, if necessary, to call an extraordinary plenary session to close this minimum agreement.

Mr. Manuel López Frías takes the floor again to remind us that, previously, it was raised in the Forum that adherence to the Code would mean positive progress for all the groups represented here, highlighting the commitment of the Tax Agency to grant more direct channels in the appointment system for the processing of its administrative procedures.

Next, Ms. Lucía Torrejón Sanz spoke and said that she had just joined AEDAF as Director of the Studies Office, and this was the first time she had attended a session of this Forum. She is surprised that such different groups are represented, such as Customs Agents and Brokers and tax advisors, and adds that, as a former employee of the Tax Administration, it is very difficult to understand the work carried out by tax advisors, since the Administration has a very compartmentalized activity in different bodies, while the tax advisor is responsible for all the action. On the other hand, Ms. Lucía Torrejón Sanz expresses her agreement with the General Director's proposal to establish a modular system.

At this point, Mr. Jesús Gascón takes the floor to state that, precisely, plurality is what enriches the Forum and that is why different professional fields are represented in it, all of them legitimate and recognized by the Tax Agency. He adds that this is one of the reasons why he is in favour of a Code with a modular system, since the priorities of different groups may not coincide. On the other hand, the President of the Forum points out that any cooperative mechanism adopted must entail some advantage for those who adopt it and that the Tax Agency is also willing to assume specific commitments that facilitate the activity of social collaborators, such as the more direct route mentioned in the appointment service.

Mr. Manuel López Frías then intervenes to clarify that Customs Agents are also tax professionals and adds that the customs declaration is, in fact, one of the most complicated tax declarations.

Mr. Jesús Gascón takes the floor again to clarify that when Article 103 of Law 31/1990 states that the Tax Agency is responsible for the effective application of the state tax and customs system, this does not mean that the customs system is not a tax system, but rather that it is not state-based, since it is European.

The Director of the Planning and Institutional Relations Service then intervenes and, in relation to the Code of Good Practices, proposes that, in order to specify and organize the next work, the Technical Secretariat send an email to all organizations so that they can inform them within a certain period of time of the minimum content that they would be willing to assume.

3. Code of Good Practices for Tax Professionals: improvement proposals.

At this point on the agenda, Mr. Jesús Gascón gives the floor again to Ms. Rosa María Prieto to comment on the main topics discussed at the meeting of the Working Group held on May 17.

The Director of the Planning and Institutional Relations Service began her presentation by pointing out that the Working Group discussed two main issues: the Code of Good Practices and certain technical modifications and improvements on which the Tax Agency is working. As regards the Code of Good Practices, an improved version was analysed that included the contributions made by some associations, mainly AEDAF and REAF, considering that, with these improvements, there was practically already a consensus; however, as has been made clear in this session, this is not the case. It also indicates that this improved text of the Code will be the one that the Technical Secretariat will send to the associations so that they can express their opinion on the minimum content that they would be willing to accept. Regarding the second question, Ms. Rosa María Prieto summarizes the main modifications and functional improvements that were presented by the Deputy Director General of Tax Technology, highlighting the following:

• As regards Corporate Tax, the Ministerial Order and the manual were published earlier than in previous years on the Tax Agency's website, and information was provided on the improvements that the Tax Agency is working on to adapt the tax return model to the format that is becoming more widespread, i.e., filing using a form.
• Regarding the filing of information returns, the improvements in the taxpayer identification system were discussed, raising the level of requirements regarding the correctness of the data provided for next year.

Ms. Rosa María Prieto also explains the general complaint of associations regarding the advance of the presentation of information declarations, making it coincide with that of other declarations, especially that of form 347.

In relation to this last section, the Director of the Planning and Institutional Relations Service reports that it is planned to bring forward the start date of the 2019 IRPF campaign, this being the main reason why reliable and correct data is needed with greater notice. He goes on to invite those present to use the help tool available on the Tax Agency's website in order to carry out tests and adapt to the new level of requirements for identification data. Finally, in relation to form 347, Ms. Rosa María Prieto comments that, although it is expected to be submitted in January next year, the Tax Agency will study whether there is any possibility of improvement.

4. Provisional balance of the IRPF 2017 campaign.

Mr. Jesús Gascón Catalán gives the floor to Mr. Rufino de la Rosa Cordón, Director of the Tax Management Department, who begins his presentation by clarifying that the data shown are provisional since information may still be sent by financial institutions.

Mr. Rufino de la Rosa goes on to indicate the main new features of this IRPF campaign:

• Temporary advance of some support services (tax data, new mobile portal, etc.).
• Consolidation of Renta Web as the sole tax return preparation service of the Tax Agency.
• Improvements in the display, data download and use of the application, as well as in the presentation with an improved interface.
• New app from the Tax Agency for Income services 2017.
• Extension of telephone service through “outgoing calls” from the start of the campaign.

Based on a presentation, Mr. Rufino de la Rosa shows the attendees the results related to the filing of tax returns for IRPF , concluding that, until the end of May, there is a considerable increase in the filing of returns compared to previous years. He also highlights that the great challenge from a media and technological point of view of this campaign has been the launch of the app of the Tax Agency which, in his opinion, has had very good results.

As for the main results of the filing of declarations, the following stand out:

• Support and assistance services: More than sixteen million users have been served, with the reference number being the most commonly used form of access, with more than thirteen and a half million taxpayers, followed by the electronic certificate (around one million seven hundred thousand).
• REINDEER: There have been more than 22 million applications, of which around 20 and a half million have been made through box 450 of the IRPF declaration for the 2016 financial year.
• Statements submitted: 19,732,699 returns have been submitted, which represents an increase of 1.73% compared to the previous year.
• Declarations submitted for entry: There has been an increase of 9.04%, in line with forecasts, although the amount received has been higher than expected, increasing by around 15% compared to the previous year.
• Declarations submitted for return: There was a slight decrease compared to the previous year (0.48%), although the expected decrease was greater, around 2%. The amount requested was also higher than expected, with an increase of 0.15%.
• Net results of the campaign: This is the section where there has been the least variation compared to forecasts, with a positive result of 116 million euros being produced for the first time.
• Refunds paid at the end of the campaign: This year there has been greater agility in the execution of refund requests with an increase of 0.29%, with an amount that has also increased by 1.59%.

Regarding the methods of filing returns, Mr. Rufino de la Rosa points out that the Internet has been the predominant method with almost 87% and more than 17 million returns. Those submitted via the Intranet have suffered a 9.45% decrease, while those submitted via telephone, due above all to the extension of the “LE LLAMAMOS Plan”, have increased by almost 83%. However, he clarifies that in approximately 60% of the telephone calls, the taxpayer was helped to prepare the declaration, although in the end they decided to submit it by another means.

Mr. Rufino de la Rosa continued his intervention by highlighting that the number of tax returns submitted in paper form to the offices of the Tax Agency was 29,481, with a decrease of 36.77%, and to financial institutions, 140,862, with a decrease of more than 50% compared to the previous year. He added that these figures reflect the tendency of taxpayers to use electronic means to a greater extent, due to both the personal development of citizens and the improvement of the Tax Agency's telematic services.

As for the tax information telephone service for the income tax campaign, he comments that the figures have remained at similar levels to those of the previous year in terms of calls answered, although it should be noted that the month in which this service was most in demand was April due to the advance provision of tax data.

Mr. Rufino de la Rosa goes on to reiterate that the most notable new feature has been the ability to file the IRPF declaration via mobile phone, using the app of the Tax Agency. Almost 200,000 declarations have been submitted via this channel, which, in his opinion, is a very positive result.

Finally, Mr. Rufino de la Rosa highlights the fact that taxpayers are bringing forward the date of filing their IRPF declaration year after year. Thus, this year as of May 31, there had been an increase of 51.52% compared to the same period of the previous year.

Mr. Jesús Gascón then took the floor to highlight that, thanks to everyone's collaboration, almost twenty million declarations have been processed, and he pointed out that the income tax campaign is an example of prevention and control a priori, through the strengthening of assistance and help services, this being the model to follow in the rest of the taxes.

5. Other considerations, requests and questions.

Mr. Jesús Gascón Catalán addresses those present and opens the floor.

Mr. Joan Torres Torres intervened to comment that, at the last meeting of the Working Group, in relation to model 347, it was agreed to propose to the Ministry the possibility of extending the submission period until February 20 or 28, and asked if there was any news in this regard.

Mr. Jesús Gascón Catalán points out that this is an issue that has not yet been assessed, however, he reiterates that the advance in the presentation of form 347 is in response to the Tax Agency's objective of also advancing the start of the 2018 income tax campaign.

Next, Mr. José Castaño Semitiel spoke. In relation to the early start of the income tax campaign, he requested, as he did in the previous plenary sessions, that the end date of the campaign not be brought forward either, since, given that April 20 is the last day for filing many returns, tax professionals do not begin working on IRPF returns until May. Finally, he agrees with the comments made by Mr. Joan Torres Torres in relation to model 347.

Since there are no new interventions in this final point of the agenda, the director of the Tax Agency thanks everyone again for their attendance and participation, and closes the thirteenth session of the plenary session of the Forum of Associations and Colleges of Tax Professionals.