Plenary Sessions
The Plenary is composed of all its members, under the direction of the President and assisted by the Technical Secretary
Twentieth session - November 23, 2021
MINUTES OF THE PLENARY MEETING OF THE FORUM OF ASSOCIATIONS AND
COLLEGES OF TAX PROFESSIONALS
HELD ON NOVEMBER 23, 2021
Secretary of State for Finance and President of the State Tax Administration Agency
Mrs. Inés María Bardón Rafael
President of the Forum of Associations and Colleges of Tax Professionals
General Director of the State Tax Administration Agency
Mr. Jesús Gascón Catalán
Members representing the Tax Agency
Director of the Tax Management Department
Mrs. Rosa María Prieto del Rey
Director of the Department of Financial and Tax Inspection
Mr. Javier Hurtado Puerta
Director of the Collection Department
Mr. Guillermo Barros Gallego
Director of the Department of Aduanas and Excise Duties
Mrs. Pilar Jurado Borrego
Director of the Tax IT Department
Mr. José Borja Tomé
Director of the Legal Service
Mr. Diego Loma-Osorio Lerena
Director of the Planning and Institutional Relations Service
Mr. Ignacio Fraisero Aranguren
Special Delegate of Catalonia
Mr. Isidoro García Millán
Deputy Director General of Tax Techniques of the Tax Management Department
Mrs. Mercedes Jordán Valdizán
Deputy Director General of Special Procedures of the Collection Department
Mr. Carlos José Dorrego Anta
Members representing Associations and Colleges
Spanish Association of Tax Advisors
Director of the Studies Office
Mr. Arturo Jiménez Happy
Professional Association of Accounting and Tax Experts of Spain
Secretary of the Board of Directors
Mr. José Antonio Fernández García-Moreno
Member of the Board of Directors
Mr. Antonio Ibarra López
General Council of Spanish Lawyers
Vice Dean of the Balearic Bar Association
Mr. Rafael Gil March
General Council of Colleges of Customs Agents and Commissioners
Secretary of the Board
Mr. Manuel López Frías
General Council of Colleges of Administrative Managers of Spain
Responsible for the Fiscal Area of the General Council
Mrs. Pilar Otero Moar
General Council of Official Colleges of Social Graduates of Spain
Member of the Fiscal Affairs Commission
Mr. José Castaño Semitiel
Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors
Chairperson
Mr. Joan Torres Torres
Cabinet of Administrative Managers and Tax Advisors
Lawyer
Mrs. Raquel Cobos Casero
Registry of Tax Advisory Economists
Vice President of the Board of Directors
Mr. Miguel Ángel Ruiz Ayuso
Member of the Board of Directors
Mr. Jesús Fernández-Bravo Pinto
Technical Secretariat of the Forum of Associations and Colleges of Tax Professionals
Deputy Director General of External Communication of the Planning and Institutional Relations Service
Ms. Mª Dolores Carreño Beltrán
On November 23, 2021, the twentieth plenary meeting of the Forum of Associations and Colleges of Tax Professionals will be held by videoconference, attended by the mentioned people and in accordance with the following
AGENDA
- Opening by the General Director of the State Tax Administration Agency.
- Approval of the minutes of the session held on July 6, 2021.
- Information on the topics discussed in the working groups.
- Other considerations, requests and questions.
1. Opening by the Secretary of State for Finance
The session opens with Ms. Inés María Bardón Rafael, Secretary of State for Finance and President of the State Tax Administration Agency (hereinafter, Tax Agency), who, after welcoming the attendees and thanking them for their presence, comments that If the evolution of the health crisis allows it, the next plenary session will recover the in-person format. Likewise, it points out that for the Ministry of Finance and Public Function and the Tax Agency it is an objective of maximum interest to continue advancing in the cooperative relationship and that this Forum is an excellent communication instrument. On the other hand, Ms. Inés María Bardón communicates that she wishes to welcome to this Forum Mr. Ignacio Fraisero Aranguren, who has been appointed Director of the Planning and Institutional Relations Service, replacing Ms. Rosa María Prieto del Rey, who, in turn, has taken on the position of Director of the Tax Management Department, a position held by Mr. Gonzalo García de Castro, to whom, on the other hand, we would like to express our gratitude for the work carried out during these years.
2. Approval of the minutes of the session held on July 6, 2021
Ms. Inés María Bardón gives the floor to Ms. Mª Dolores Carreño Beltrán, Deputy Director General of External Communication of the Planning and Institutional Relations Service and Technical Secretary of this Forum, who states that the minutes of the nineteenth session of the plenary session were sent to the associations and colleges prior to this meeting, with no observations having been received; He adds that, if there were not any at this time, it would be definitively approved. Since no objection is raised, the minutes of the 19th plenary session that took place on July 6, 2021 are declared approved.
3. Information on the topics discussed in the working groups
Next, the Secretary of State for Finance gives the floor to Mr. Jesús Gascón Catalán, General Director of the Tax Agency and President of this Forum, so that he can comment on the activity of the working groups of this Forum during the second semester of 2021 and distribute the word among the people responsible for them.
Mr. Jesús Gascón begins his speech by pointing out that the joint virtual meeting of the working groups that took place on November 3 was attended by the General Directorate of the Cadastre, since one of the points on the agenda was reference value. Likewise, of the issues addressed, the following stand out: 2021 informative declaration campaign, improvements in model 303 of VAT , ruling 1130/2021 of the Supreme Court, problems with seizures in credit institution accounts and the treatment of formalized succession agreements before the entry into force of Law 11/2021.
Next, give the floor to Ms. Rosa María Prieto del Rey, Director of the Tax Management Department, so that she can comment on the activity of the News working group on regulations, models and campaigns.
The Director of the Tax Management Department comments that, first of all, she wishes to thank the associations and colleges for the collaboration provided in the work of this Forum during these years, pointing out that, of course, there have been discrepancies, but also many meeting points . He adds that he wishes to make himself available to the Forum to, from his new responsibility, continue advancing in the cooperative relationship model, in favor of a correct application of the tax system. On the other hand, he indicates that, to develop the points concerning his Department discussed in the working group meeting, he gives the floor to Ms. Mercedes Jordán Valdizán, Deputy Director General of Tax Techniques.
Ms. Mercedes Jordán begins her presentation by pointing out that the following issues were addressed at the working group meeting:
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Informative declaration campaign:
Firstly, a review of the models approved in 2021 was carried out:
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Tax on Certain Digital Services (form 490) and Tax on Financial Transactions (form 604): The settlement period is quarterly and monthly, respectively, although this first year of declaration the self-assessment corresponding to the first quarter of 2021 of form 490 is presented in the period corresponding to the second quarter (from July 1 to 31) and that of the The first four months of model 604 are presented within the deadline established for May (June 1 to June 20).
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DAC 6 (models 234, 235 and 236): The informative declaration of cross-border tax planning mechanisms (form 234) and the update information of certain marketable cross-border mechanisms (form 235) have already been submitted. Likewise, Spain has used the power established in the Directive to implement a third declaration of information related to the use of certain cross-border tax planning mechanisms, the model of which has already been approved (236). However, the presentation of the declaration cannot be made until the fourth quarter of 2022, since the deadline established for it is the last quarter of the calendar year following the one in which the mechanisms were used in Spain. cross-border transactions that must have been previously declared.
In relation to the 2021 information declaration campaign which, in terms of its presentation, begins on January 1, 2022, Ms. Mercedes Jordán points out that there are no major new developments and that it is a campaign of continuity, of technical progress , with the aim of improving the tax data provided to groups of Personal Income Tax and Corporate Tax taxpayers. He adds that in the coming days a specific section with all the information on the campaign will be published on the Tax Agency's electronic headquarters, which can be accessed from a link located in the "carousel" on the home screen. Thus, the novelties that were highlighted at the working group meeting were the following:
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Form 179 (quarterly informative declaration of the transfer of use of homes for tourism purposes): A new model has been approved and is back in force. It is a quarterly return and its submission deadline is the calendar month following the end of the quarter. The information will be provided in the personal income tax and corporate income tax data.
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Tax current account (CCT): A new model for requesting inclusion and communication of resignation from the tax current account system is approved. The main novelty is that the presentation is carried out exclusively electronically.
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Project orders in process to introduce technical improvements: In model 189 the nominal value of the securities is incorporated and in model 198 the objective of the modifications is aimed at being able to relate consecutive operations. These changes are essential for the correct functioning of the “Stock Portfolio” tool. For its part, in form 347 the code “XI” is introduced in the VAT NIF codes for people who operate in Ireland.
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Support services: At the meeting, the functionalities of the Pre 303 help service were explained and its vocation for universality for all people with this tax obligation was highlighted, as well as the convenience of using this service at least once a year, in order to keep the information updated. census data. Likewise, the availability of the different virtual assistants was recalled and, in terms of VAT, it was reported that the format of the 2021 VAT Manual was exclusively electronic and that it had been systematically integrated with the virtual VAT assistance tools.
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Rules pending processing: The following were highlighted at the meeting:
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Draft Ministerial Order on the special tax on Listed Joint Stock Companies for Investment in the Real Estate Market (SOCIMI): The changes have their origin in the modification of Law 11/2009 by the Law on measures to prevent and combat tax fraud, establishing a 15% tax on undistributed profits for periods starting on January 1, 2021. The model will be approved in similar terms to the current model 217.
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Virtual currencies: Informative statements on holding and operations with cryptocurrencies will be approved for entities dedicated to the safeguarding and custody of private cryptographic keys. A new obligation to report this type of assets abroad is also created.
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Adaptation of the regulations to DAC 7 and the Directive that regulates the CESOP (central electronic payment information system), establishing, respectively, a new information obligation for people who operate through digital platforms and another for provider entities of payment services.
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Ruling number 1130/2021 of the Supreme Court of September 15, 2021 (R. Cassation no. 5664/2019): At the meeting it was reported that this ruling had established that, for the purposes of calculating the amortization of leased properties acquired for profit, the acquisition value was the result of the application of the Inheritance and Gift Tax rules. For his part, the representative of the Spanish Association of Tax Advisors (AEDAF) asked if it was planned to implement any mechanism so that the group affected by the ruling could regularize the amounts in their favor in a manner similar to that established at the time after the ruling. declaration by the Supreme Court of the exemption from maternity benefit, to which, on the part of the Tax Agency, the response was that it was not planned to prepare an ad hoc form , but rather that was working on the development of a new functionality so that rectifications of self-assessments could be carried out through Renta WEB, without prejudice to the interested person choosing other means to submit their rectification request. In this sense, the Deputy Director General of Tax Techniques reports that on November 12, the associations and schools represented in the Forum were informed that the updated versions of WEB Income for the years 2019 and 2020 were already available and that the rectifications They could be done through the application.
Mr. Jesús Gascón thanks Ms. Rosa María Prieto and Ms. Mercedes Jordán for their interventions and gives the floor to Mr. Javier Hurtado Puerta, Director of the Department of Financial and Tax Inspection, to comment on the matters discussed in the meetings of the working groups corresponding to the scope of their Department.
Mr. Javier Hurtado points out that in the joint virtual meeting of the Forum's working groups, his Department's intervention was limited to the issue raised by an association in relation to the treatment of succession agreements formalized before the entry into force of the Law 11/2021. Thus, the Deputy Director General of Legal Planning and Legal Assistance explained that the modification introduced in article 36 of the Personal Income Tax Law established that in lucrative acquisitions due to death derived from contracts or succession agreements with present effects, the beneficiary of the same ones that transmit, before the passage of five years from the execution of the succession agreement or the death of the deceased person, if earlier, the acquired assets, would be subrogated to the latter's position, with respect to the value and date of acquisition of those , when this value is lower than that resulting from the application of the Inheritance and Donation Tax rules. The representative of the Department of Financial and Tax Inspection added that, however, the first transitional provision had established that the new wording of article 36 would only apply to transfers of assets carried out after the entry into force of Law 11/ 2021. Finally, Mr. Javier Hurtado points out that currently there is a double treatment in this matter depending on whether the transfer of the asset was carried out prior to the entry into force of Law 11/2021, that is, before 11 July 2021, or later.
Mr. Jesús Gascón thanks Mr. Javier Hurtado for his intervention and gives the floor to Mr. Guillermo Barros Gallego, Director of the Collection Department, so that he can comment on the matters discussed at the meeting corresponding to the area of his Department.
The Director of the Collection Department comments that the Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors (FETTAF) proposed that an incident related to an excessive embargo be included in the agenda of the meeting on November 3, which, in addition , took a while to get up. For her part, the Deputy Director General of Coordination and Management reported that excessive seizure proceedings were usually lifted ex officio, but that in the case mentioned a computer problem had occurred. The representative of the Collection Department pointed out that, for greater agility in the resolution of incidents, these would be communicated to the Tax Agency through the Collection telephone service (REC@T). On the other hand, Mr. Guillermo Barros indicates that some of the difficulties that arise in seizure actions are related to the late transfer of information associated with collection fortnights, an issue that has already been commented on in previous meetings of this Forum. Thus, it informs that the Tax Agency, together with collaborating entities, is working on the development of the NRC on line, so that, after the complete implementation of this project, the Tax Agency can instantly have the information at the moment the payment is made, without having to wait for the biweekly period in which it is currently obtained. Mr. Guillermo Barros indicates that, through the Technical Secretariat, the associations and schools will be informed of the start-up of the new system, scheduled for the end of January 2022. Finally, the Director of the Collection Department reiterates that, for greater speed in the resolution of any incident, this should be communicated through the telephone number 915536801.
Next, Mr. Jesús Gascón, after thanking Mr. Guillermo Barros for his presentation, gives the floor to Mr. Ignacio Fraisero, so that he can comment on what was discussed in the joint meeting of the working groups in relation to the Code of Goodwill. Practices and reference value.
The Director of the Planning and Institutional Relations Service, after commenting that he is available to the members of the Forum to, in the exercise of his new responsibilities, continue the development of the work undertaken by his predecessors, begins his presentation on the issues discussed in the joint virtual meeting of the working groups, highlighting the following:
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Reference value: The representatives of the General Directorate of the Cadastre explained that the General State Budget Law for 2018 had introduced the market reference value because the use of the cadastral value presented certain difficulties in terms of updating it, since it was carried out through complex long-term processes and, furthermore, did not allow the annual updating of the economic value. For this reason, initially, it was decided to store, internally, the market information provided by public notaries. Likewise, they explained the particularities of the procedure for determining the new reference value, pointing out that it was carried out in two phases:
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Firstly, the average modules assigned to each homogeneous area into which the territory is divided are calculated, based on the information on all sales provided by public notaries.
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Subsequently, the individualized value of the property is determined, based on technical cadastral valuation standards, which add a certain complexity to the process.
The representatives of the General Directorate of the Cadastre indicated that in the self-assessments of taxes on Inheritance and Donations, Asset Transfers and Documented Legal Acts and Assets, the market value would be the reference value, unless the value declared by the taxpayer was higher.
Likewise, the General Directorate of the Cadastre responded to the queries made by the associations and schools, of which the following can be highlighted:
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Regarding constructions on rural land, it was explained that as long as the regulatory development was not carried out, they would not have a reference value.
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In relation to the reduction factor, it was commented that it is not part of the procedure for determining the reference value, since the standard did not require it nor did it limit its approval; Therefore, in order to mitigate fluctuations in market value, any reduction factors considered appropriate could be approved.
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Regarding the breakdown of the value for determining the value of the land and the value of the construction, it was explained that the modules derive from the consolidated sales prices, and the residual method is applied, the construction costs and the difference would correspond to the value of the land.
To conclude with this point, it was reported that, as of January 1, 2022, citizens could know the reference values and obtain a certificate of them referring to a certain date.
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Commitments assumed by the Tax Agency within the framework of the Code of Good Tax Practices: The representative of the Planning and Institutional Relations Service reported that as of November 2, 45 associations and colleges and 781 tax professionals had adhered to the Code. Likewise, he pointed out that, in relation to the commitments contained in the Codes, the status of the situation was as follows:
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Establishment of a communication channel in the electronic headquarters: It has been operational since January 12 and associations and schools have submitted 6 consultations to date.
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Organization of outreach and communication campaigns: In 2021, an information session was held on the content of the Codes of Good Practices aimed at associations and schools that have signed the Code. Likewise, two webinars have been held aimed at the group of professionals who have joined, the first on the ADI (Comprehensive Digital Assistance Administrations) and the Personal Income Tax 2020 campaign and the second on electronic commerce.
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Recognition of associations and schools that voluntarily adhere to the Code: The registration in the trademark registry of a logo that recognizes associations, colleges and professionals that have joined is in process.
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Specialized appointment: Its articulation is being analyzed by the Departments of Management, Inspection, Collection and IT, both in person and remotely.
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Next, Mr. Jesús Gascón thanks Mr. Ignacio Fraisero Aranguren for his presentation and offers the floor to the attendees in case they wish to make any comments. Since there is no intervention, the Secretary of State for the Treasury gives way to the next item on the agenda.
4. Other considerations, requests and questions
First of all, the Director General of the Tax Agency intervenes, who, in relation to the planning of the Forum's activities for next year, reports on the following issues:
- Planning and accountability instruments: Mr. Jesús Gascón points out that, as has been done this year, it is planned that in the next plenary session the planning of the Tax Agency for 2022 will be shared, as well as the results obtained in 2021. He adds that the preparation of a specific addendum to the 2020-2023 Strategic Plan for the 2022 financial year is being studied. Likewise, it indicates that the general guidelines of the 2022 Annual Tax and Customs Control Plan will also be discussed, which, by legal mandate, will have to be approved, as well as the organization's Objective Plan for next year. Finally, it indicates that the reports prepared by the Internal Audit Service on the evolution of multi-year indicators and on the degree of compliance with the objectives in 2021 will also be shared.
- White Paper on Tax Reform: points out that at the time the Committee of experts presents its report, it will be proposed to carry out a specific act in which they report on the most relevant issues it contains, especially if they concern issues of a practical nature in the application of the tax system.
- Spain's next presidency of the Council of the European Union in the second half of 2023: Mr. Jesús Gascón reports that there is a significant number of community legislative initiatives in the pipeline and points out that it would be advisable to hold a meeting that includes this matter, since knowing the opinions and interests of the groups represented in this Forum would be of great benefit. useful when setting Spanish priorities.
- First results of the presentations derived from DAC 6: points out that the Tax Agency is analyzing the data and that, at the moment, they are very provisional. It indicates that when the definitive information is available it will also be shared with this Forum. He adds that, however, the number of presentations has not been very high.
- Component 27 of the Recovery, Transformation and Resilience Plan, related to the prevention and fight against tax fraud: communicates that, in compliance with the commitments assumed by the Government in said Component, the Tax Administration plans to carry out a provisional evaluation of the application of Law 11/2021 in the fourth quarter of 2022 and another, in greater depth, in the fourth quarter. quarter of 2023, in which, in view of the results, improvements and modifications are proposed. He adds that in the European Union it is common practice to evaluate regulatory application, although Spain has not considered it a priority until quite recently. Thus, Mr. Jesús Gascón, points out that it would be convenient to know the opinions and reflections of the associations and schools on the application of this Law and comments that in the second half of next year the collaboration of those present will be requested in order to prepare said reports. .
To conclude his intervention, the Director General of the Tax Agency comments that, therefore, the Forum already has a few works for the following year, apart from, of course, its usual work on the most immediate regulatory developments, the obligations formalities or the evolution of the cooperative model. Next, a turn for interventions opens.
Mr. Joan Torres Torres, representative of the Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors (FETTAF), takes the floor and, after congratulating Ms. Rosa María Prieto and Mr. Ignacio Fraisero on their recent appointments, comments that he wishes thank you for the answers provided by the Inspection and Collection departments to the questions raised in the working groups and which they have ratified in this plenary session.
Next, Mr. Arturo Jiménez Contento, representative of the Spanish Association of Tax Advisors (AEDAF), intervenes, who joins in congratulating the new positions of the Tax Agency. Next, it points out that the AEDAF wishes to express its deep disappointment at the lukewarm reaction of the AEAT to the ruling of the Supreme Court of September 15, 2021 regarding the amortization in personal income tax of rented real estate acquired free of charge, since that has limited itself to introducing changes in the Renta Web computer tool so that it is the taxpayers, and not the Tax Agency itself, who promote the rectification procedure in order to adapt their declarations to legality in the sense finally endorsed by the Supreme Court. This scenario, in the opinion of the AEDAF, does not correspond to the statements made by the then Director of the Department of Tax Management (D. Gonzalo García de Castro) in the plenary session on July 6, when he pointed out that, in the event that the Supreme Court rectified the interpretation of the DGT / Tax Agency in this regard, the refunds would be managed diligently and quickly, just as the AEDAF had expressly requested. For the AEDAF, this episode constitutes a great missed opportunity for the Tax Agency to show itself to society as a collaborative and agile entity when it comes to carrying out practices favorable to taxpayers; considers it a shame and, in any case, an aspect on which to demand a substantial improvement in the response capacity of the Tax Agency in the face of future analogous scenarios.
Ms. Rosa María Prieto del Rey answers that the Tax Agency analyzed at the time different possibilities to implement this rectification procedure and that, in view of the information available to the Tax Agency, it was considered the most appropriate option. and it was more viable to do it through Renta WEB. Next, give the floor to the Deputy Director General of Tax Techniques to report in more detail on the analysis process that was carried out.
Ms. Mercedes Jordán begins her intervention by pointing out that the statements that the then Director of the Tax Management Department made in the previous plenary session in the sense that the returns would be expedited and processed diligently, remain valid since said returns are identified and the origin of the rectification is known. He adds that an ad hoc form has not been prepared because it was considered that the most effective thing was to use the functionalities offered by Renta WEB, given that, in addition, the information available was not optimal and it was necessary for taxpayers to provide it. Likewise, it points out that it was already commented in a meeting of the working groups that the acquisition values were not well informed in the case of properties acquired for profit, since the Tax Agency had followed the criteria of the General Directorate of Taxes in This issue, of which the AEDAF was fully informed, since it had requested the reports through the Transparency Portal. Finally, Ms. Mercedes Jordán reiterates that rectification requests will be processed with diligence, agility and due priority, since the traceability between the rectification request and the reason for it is perfectly identified.
Next, Mr. Rafael Gil March, representative of the General Council of Spanish Lawyers (CGAE), takes the floor, who after thanking Ms. Rosa María Prieto for the excellent treatment provided and wishing that his successor in office, Mr. Ignacio Fraisero, Continue on the same page, I wish you both the best of success. Next, in relation to the declarations derived from DAC 6, ask if the volume of presentations is known and if useful information had been obtained with them, that is, given that they include potentially aggressive, but not illicit, tax planning operations, if they had served for the Administration to detect situations that really had no planned regulation.
Mr. Jesús Gascón responds that a systematic analysis of the information is currently being carried out and that at a future meeting it will be shared with those present. For his part, Mr. Javier Hurtado adds that, from first impressions, whether a mechanism is legal or not, it can only be determined by studying case by case.
Mr. Rafael Gil March comments that, in his opinion, a meeting on this issue is indeed necessary since there is a lot of confusion and lack of knowledge about where this type of mechanism fits, which, being legal, can reveal some deficiencies in its regulation.
Next, Mr. José Castaño Semitiel, representative of the General Council of Official Colleges of Social Graduates of Spain, intervenes, who, first of all, thanks Ms. Inés María Bardón Rafael for her presence at the twentieth plenary session. He adds that he also wishes to thank Mr. Gonzalo García de Castro for his work and the good relationship he has always maintained with the participants in this Forum. Likewise, he congratulates Ms. Rosa María Prieto and Mr. Ignacio Fraisero for their new appointments. On the other hand, it communicates that it is receiving many calls regarding direct debits in BANKIA of form 583 that were not being attended to. Ask if the Tax Agency has any information in this regard and, above all, that it takes it into account in the event of incidents that are detected. He adds that he also wants to propose that a future meeting of the working groups include the problem that the group of social collaborators has in relation to the telephone number of the Collection Department, since, for security reasons, a is sent SMS ##1##to the taxpayer who, at those times, is most likely not in the presence of the tax professional. He adds that a way should be found so that it is the social collaborator himself who, on behalf of his clients, can access the service and manage the appropriate procedures. Finally, in relation to the Code of Good Practices, it points out that the General Council had informed the previous Director of the Planning and Institutional Relations Service of its interest in carrying out an outreach campaign among its group. He requests confirmation whether this matter should now be discussed with the new Director of the Service.
Mr. Ignacio Fraisero Aranguren answers that, of course, the Service he directs will continue to provide collaboration and support to the General Council of Official Colleges of Social Graduates of Spain in the organization of the informative campaign on the Codes of Good Practices. On the other hand, without prejudice to what the Director of Collection wishes to add, he comments that the Tax Agency is aware of the difficulties with the assistance service and that, indeed, it is studying how to articulate a joint solution for all Departments.
Mr. Guillermo Barros Gallego, Director of the Collection Department, then takes the floor to point out that it is not the intention of the Tax Agency to hinder the work of social collaborators and reiterates what was commented by Mr. Ignacio Fraisero in that the problematic, in order to establish a system that, complying with all security conditions, allows guaranteeing optimal service. On the other hand, he points out that, in relation to direct debits at BANKIA that are not being attended to, his Department will review whether there is any type of specific incident and will communicate it to the attendees.
Next, Ms. Pilar Jurado Borrego, Director of the Department of Customs and Special Taxes, asks Mr. José Castaño Semitiel if the incident mentioned regarding model 583 is also occurring with the direct debit of other self-assessments.
Mr. José Castaño responds that he assumes that it is happening with more models, but that the calls he has received were referring to model 583, whose last day of presentation ended on November 22.
Ms. Pilar Jurado comments that, possibly, the incidents are due to internal adjustments derived from the merger.
Next, Mr. Rafael Gil indicates that he wishes to reiterate an issue already discussed at the working group meeting in relation to attendance at the Delegations and that is that there are still many restrictions on access to the offices and that, in addition, the Appointments, at least in the Balearic Islands, do not work well and there are cases in which the submission period is short and it takes days to obtain assistance or an appointment. He adds that this situation is occurring in general throughout the Administration and not only in the Tax Agency. He reiterates that it is very necessary to improve personalized attention both by telephone and in person, as well as the appointment service.
Mr. Guillermo Barros and Mr. Ignacio Fraisero reiterate that the Tax Agency is analyzing different ways to improve the efficiency of care and assistance services and that there is no problem in including this topic in the next meetings of the working groups.
Given that no new interventions are made, the President of the State Tax Administration Agency thanks the attendees for their presence and participation and concludes the twentieth session of the plenary session of the Forum of Associations and Colleges of Tax Professionals.
The Technical Secretary of the Forum
Ms. Dolores Carreño Beltrán
The President of the Forum
D. Jesús Gascón Catalán