Minutes of the meeting

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 Agency for Tax Administration

Mrs. Ines Maria Bardon Rafael

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

Mrs. Rosa Maria Prieto del Rey

Director of the Department of Financial and Tax Inspection

Mr. Javier Hurtado Puerta

Director of the Revenue Department

Mr. Guillermo Barros Gallego

Director of the Department of Aduanas and Excise Duties

Ms. Pilar Jurado Borrego

Director of the Tax Information Technology Department

Mr. Jose Borja Tome

Director of Legal Services

Mr. Diego Loma-Osorio Lerena

Director of the Planning and Institutional Relations Service

Mr. Ignacio Fraisero Aranguren

Special Delegate of Catalonia

Mr. Isidoro Garcia Millan

Deputy Director General of Tax Technology of the Tax Management Department

Mrs. Mercedes Jordán Valdizán

Deputy Director General of Special Procedures of the Tax Collection Department

Mr. Carlos Jose Dorrego Anta

Members representing Associations and Colleges

Spanish Association of Tax Advisors

Director of the Study Office

Mr. Arturo Jimenez Contento

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 Lopez

General Council of the Spanish Bar Association

Vice-Dean of the Balearic Bar Association

Mr. Rafael Gil March

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

Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors

Chairperson

Mr. Joan Torres Torres

Office of Administrative Managers and Tax Advisors

Lawyer

Mrs. Raquel Cobos Casero

Registry of Tax Advisors Economists

Vice President of the Board of Directors

Mr. Miguel Angel Ruiz Ayuso

Member of the Board of Directors

Mr. Jesus Fernandez-Bravo Pinto

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

Deputy Director General of External Communications of the Planning and Institutional Relations Service

Mrs. Maria Dolores Carreno Beltran

On November 23, 2021, the twentieth plenary meeting of the Forum of Associations and Colleges of Tax Professionals is held by videoconference, attended by the people listed 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 July 6, 2021.
3. Information on the topics discussed in the working groups.
4. Other considerations, requests and questions.

1. Opening by the Secretary of State for Finance

The session is opened by Ms. Inés María Bardón Rafael, Secretary of State for Finance and President of the State Tax Administration Agency (hereinafter, the 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 return to the face-to-face format. He also points out that the Ministry of Finance and Public Administration and the Tax Agency are interested in continuing to advance the cooperative relationship and that this Forum is an excellent communication tool. On the other hand, Ms. Inés María Bardón announces 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 up the position of Director of the Tax Management Department, a position previously held by Mr. Gonzalo García de Castro, to whom, on the other hand, she wishes to express her gratitude for the work carried out during these years.

2. Approval of the minutes of the meeting 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 plenary session were sent to the associations and colleges prior to this meeting, and that no comments have been received; He adds that if there were none at this time, it would be definitively approved. Since no objections were raised, the minutes of the 19th plenary session held on 6 July 2021 are hereby approved.

3. Information on the topics discussed in the working groups

The Secretary of State for Finance then gives the floor to Mr. Jesús Gascón Catalán, Director General 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 half of 2021 and distribute the floor 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 Cadastre, since one of the points on the agenda was the reference value. Among 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.

She then gives the floor to Ms. Rosa María Prieto del Rey, Director of the Tax Management Department, to comment on the activity of the working group on New Developments in Regulations, Models and Campaigns.

The Director of the Tax Management Department comments that, first of all, she would like to thank the associations and colleges for their collaboration in the work of this Forum over the years, pointing out that, of course, there have been disagreements, but also many points of agreement. He added that he wishes to make himself available to the Forum in order to continue advancing the cooperative relationship model in his new role, in favour of a correct application of the tax system. On the other hand, she indicates that, in order to develop the points concerning her Department discussed at the working group meeting, she gives the floor to Ms. Mercedes Jordán Valdizán, Deputy Director General of Tax Technology.

Ms. Mercedes Jordán begins her presentation by pointing out that the following issues were addressed at the working group meeting:

• Campaign of information statements:

  First, a review was made of the models approved in 2021:

  • 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 model 490 is presented within the period corresponding to the second quarter (from July 1 to 31) and that of the first four months of model 604 is presented within the period established for May (from June 1 to 20).

  • DAC 6 (models 234, 235 and 236): The information declaration on cross-border tax planning mechanisms (form 234) and the information declaration on updating certain marketable cross-border mechanisms (form 235) have now been submitted. Spain has also used the power established in the Directive to implement a third declaration of information regarding the use of certain cross-border tax planning mechanisms, the model for which has already been approved (236). However, the declaration cannot be submitted 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 use in Spain of the cross-border mechanisms that should have been previously declared took place.

  Regarding the 2021 informative 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 the groups of taxpayers of IRPF and Corporate Tax. He added that in the coming days a specific section with all the information on the campaign will be published on the Tax Agency's website, which can be accessed from a link located in the "carousel" on the home screen. The following new developments were highlighted at the working group meeting:

  • Form 179 (quarterly information declaration on the transfer of use of housing for tourist purposes): A new model has been approved and is back in force. It is a quarterly declaration and its submission deadline is the calendar month following the end of the quarter. The information will be provided in the tax data of IRPF and Corporate Tax.

  • Tax current account (CCT): A new model for requesting inclusion and communicating resignation from the tax current account system is approved. The main novelty is that the submission is done exclusively electronically.

  • Draft 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 “Securities Portfolio” tool. For its part, in form 347 the code “XI” is introduced in the VAT NIF codes for people who operate in Ireland.

• Support Services: The meeting explained the features of the Pre 303 help service and highlighted its universality for all persons with this tax obligation, as well as the convenience of using this service at least once a year, in order to keep the census data up to date. Likewise, the availability of the different virtual assistants was recalled and, regarding VAT , it was reported that the format of the VAT 2021 Manual was exclusively electronic and that had been systematically integrated with the virtual assistance tools in VAT .

• Pending regulations: The following were highlighted at the meeting:

  • Draft Ministerial Order on the special tax on Listed Real Estate Investment Companies (SOCIMI): The changes are based on the amendment of Law 11/2009 to the Law on measures to prevent and combat tax fraud, establishing a 15% tax on undistributed profits for periods beginning on or after 1 January 2021. The model will be approved in similar terms to the current model 217.

  • Virtual currencies: Informative declarations on the holding and operations with cryptocurrencies will be approved for entities dedicated to the safeguarding and custody of private cryptographic keys. A new obligation is also created to report this type of assets abroad.

  • Adaptation of the regulations to DAC 7 and the Directive that regulates the CESOP (central electronic payment information system), establishing, respectively, a new reporting obligation for persons operating through digital platforms and another for entities providing payment services.

• Judgment number 1130/2021 of the Supreme Court of September 15, 2021 (R. Cassation No. 5664/2019): At the meeting it was announced that this ruling had established that, for the purposes of calculating the depreciation of leased properties acquired for profit, the acquisition value was the result of applying the rules of the Inheritance and Gift Tax. For its part, the representative of the Spanish Association of Tax Advisors (AEDAF) asked whether it was planned to implement any mechanism so that the group affected by the ruling could regularize the amounts in its favor in a similar way to that established at the time after the Supreme Court declared the exemption from maternity benefits, to which the Tax Agency replied that it was not planned to prepare a form. ad hoc, but work was being done on developing a new feature so that corrections to self-assessments could be made through Renta WEB, without prejudice to the interested party choosing other means to submit their correction request. In this regard, the Deputy Director General of Tax Technology reports that on November 12, the associations and colleges represented at the Forum were informed that the updated versions of Renta WEB for the 2019 and 2020 financial years were now available and that corrections could be made through the application.

Mr. Jesús Gascón thanks Ms. Rosa María Prieto and Ms. Mercedes Jordán for their contributions 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 his Department.

Mr. Javier Hurtado points out that at the joint virtual meeting of the Forum's working groups, his Department's intervention was limited to the question raised by an association in relation to the treatment of inheritance agreements formalized before the entry into force of Law 11/2021. Thus, the Deputy Director General of Legal Organization and Legal Assistance explained that the amendment introduced in article 36 of the Income Tax established that in the case of lucrative acquisitions due to death arising from contracts or succession agreements with present effects, the beneficiary of the same who transfers, before the passage of five years from the celebration of the succession agreement or the death of the deceased, if earlier, the acquired assets, would be subrogated in the position of the latter, with respect to the value and date of acquisition of those assets, when this value was lower than that resulting from the application of the rules of the Inheritance and Gift Tax. 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 there is currently a double treatment in this matter depending on whether the transfer of the asset has been carried out prior to the entry into force of Law 11/2021, that is, before July 11, 2021, or after.

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 in the meeting corresponding to the area of his Department.

The Director of the Tax Collection Department comments that the Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors (FETTAF) proposed that an incident relating to an excessive embargo, which also took a long time to be lifted, be included in the agenda of the meeting on 3 November. The Deputy Director General for Coordination and Management reported that excessive seizure orders were usually lifted ex officio, but that in the case in question there had been a computer problem. The representative of the Tax Collection Department indicated that, in order to speed up the resolution of incidents, these should be communicated to the Tax Agency through the Tax Collection telephone service (REC@T). On the other hand, Mr. Guillermo Barros indicates that some of the difficulties that arise in seizure proceedings are related to the late transfer of information associated with the fortnightly collection periods, an issue that has already been discussed in previous meetings of this Forum. Thus, it reports that the Tax Agency, together with the 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 time the payment is made, without having to wait for the fortnightly period in which it is currently obtained. Mr. Guillermo Barros indicates that, through the Technical Secretariat, associations and schools will be informed of the implementation of the new system, scheduled for the end of January 2022. Finally, the Director of the Collection Department reiterates that, in order to resolve any incident more quickly, it should be reported via 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 at the joint meeting of the working groups in relation to the Code of Good Practice and the 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 with 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:

• Reference value: Representatives of the General Directorate of 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 its update, since it was carried out through complex, long-term processes and, in addition, did not allow for the annual update of the economic value. For this reason, it was initially decided to store, internally, the market information provided by public notaries. They also explained the particularities of the procedure for determining the new reference value, pointing out that it was carried out in two phases:

  • First, the average modules assigned to each homogeneous zone into which the territory is divided are calculated, based on the information on all sales provided by public notaries.

  • The individual value of the property is then determined based on technical standards for cadastral valuation, which adds a certain complexity to the process.

  Representatives of the General Directorate of Cadastre indicated that in the self-assessments of the taxes on Successions and Donations, Patrimonial Transfers and Documented Legal Acts and Patrimony the market value would be the reference value, unless the value declared by the taxpayer was higher.

  The General Directorate of Cadastre also responded to queries made by associations and schools, of which the following can be highlighted:

  • As regards constructions on rustic land, it was explained that as long as the regulatory development was not carried out, they would not have a reference value.

  • Regarding 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 and did not limit its approval; Therefore, in order to mitigate fluctuations in market value, any mitigating factors deemed appropriate could be approved.

  • 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 are derived from the consolidated sales prices, and the residual method is applied, the construction costs are discounted and the difference would correspond to the value of the land.

  To conclude this point, it was reported that, as of January 1, 2022, citizens would be able to find out the reference values and obtain a certificate of them for a certain date.

• Commitments made 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 joined the Code. He also noted that, in relation to the commitments contained in the Codes, the status of the situation was as follows:

  • Establishment of a communication channel in the electronic headquarters: It has been operational since January 12 and associations and schools have submitted 6 queries to date.

  • Organization of outreach and communication campaigns: In 2021, an information session was held on the content of the Codes of Good Practice aimed at the associations and schools that have signed the Code. In addition, two webinars have been held for the group of professionals who have joined, the first on ADI (Comprehensive Digital Assistance Administrations) and the IRPF 2020 campaign and the second on electronic commerce.

  • Recognition of associations and colleges that voluntarily adhere to the Code: The registration of a logo in the trademark registry that recognizes associations, colleges and professionals that have joined is currently being processed.

  • Specialized appointment: Its articulation is being analyzed by the Management, Inspection, Collection and Information Technology Departments, both in person and remotely.

Next, Mr. Jesús Gascón thanks Mr. Ignacio Fraisero Aranguren for his presentation and offers the floor to those present in case they wish to make any comments. Since no intervention was made, the Secretary of State for Finance moved on to the next item on the agenda.

4. Other considerations, requests and questions

Firstly, the Director General of the Tax Agency intervenes, who, in relation to the planning of the Forum's activities for the coming year, reports on the following issues:

• Planning and accountability tools: Mr. Jesús Gascón points out that, as has been done this year, the Tax Agency's planning for 2022, as well as the results obtained in 2021, are expected to be shared at the next plenary session. He added that a specific addendum to the Strategic Plan 2020-2023 for the 2022 financial year is being considered. The report also indicates that the general guidelines of the Annual Tax and Customs Control Plan for 2022, which must be approved by legal mandate, will also be discussed, as well as the organization's Plan of Objectives for the coming year. Finally, it indicates that the reports prepared by the Internal Audit Service on the evolution of the multiannual indicators and on the degree of compliance with the objectives in 2021 will also be shared.
• White Paper on Tax Reform: He points out that when the Committee of Experts presents its report, it will be proposed that a specific event be held in which they will report on the most relevant issues it contains, especially if they concern practical issues in the application of the tax system.
• Spain's upcoming presidency of the Council of the European Union in the second half of 2023: Mr. Jesús Gascón reports that there are a significant number of Community legislative initiatives in the pipeline and points out that it would be advisable to hold a meeting to include this matter, since knowing the opinions and interests of the groups represented in this Forum would be very useful when setting Spanish priorities.
• First results of the presentations derived from DAC 6: He points out that the Tax Agency is analysing the data and that, at the moment, they are very provisional. Indicates that when the final information is available it will also be shared with this Forum. He adds that, however, the number of submissions has not been very high.
• Component 27 of the Recovery, Transformation and Resilience Plan, regarding the prevention and fight against tax fraud: communicates that, in compliance with the commitments made 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 of 2023, in which, in view of the results, improvements and modifications will be proposed. He adds that in the European Union it is common practice to evaluate the application of regulations, although Spain has not considered it a priority until fairly recently. Thus, Mr. Jesús Gascón points out that it would be advisable to know the opinions and reflections of the associations and colleges 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 speech, the Director General of the Tax Agency said that the Forum already has a number of tasks in store for the following year, apart from, of course, its usual work on the most immediate regulatory developments, formal obligations or the evolution of the cooperative model. He then opens a round of interventions.

Mr. Joan Torres Torres, representative of the Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors (FETTAF), took the floor. After congratulating Ms. Rosa María Prieto and Mr. Ignacio Fraisero on their recent appointments, he commented that he would like to thank the Inspection and Collection departments for their responses to the questions raised in the working groups and which they ratified at this plenary session.

Next, Mr. Arturo Jiménez Contento, representative of the Spanish Association of Tax Advisors (AEDAF), spoke and joined in congratulating the new positions at the Tax Agency. It then points out that the AEDAF wishes to express its deep disappointment at the lukewarm reaction of the AEAT to the Supreme Court ruling of September 15, 2021 regarding the amortization in the IRPF of rented real estate acquired free of charge, since the former has limited itself to introducing changes in the Renta Web computer tool so that it is the taxpayers, and not the Tax Agency itself ex officio, who promote the rectification procedure in order to adapt their declarations to the 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 Tax Management Department (Mr. Gonzalo García de Castro) in the plenary session of 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 processed diligently and quickly, as the AEDAF had expressly requested. For the AEDAF, this episode represents a great missed opportunity for the Tax Agency to present itself to society as a collaborative and agile entity when it comes to implementing practices that are favourable to taxpayers; He considers it a pity and, in any case, an aspect in which a substantial improvement in the response capacity of the Tax Agency should be requested in the event of possible similar future scenarios.

Ms. Rosa María Prieto del Rey replies 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 that the most appropriate and viable option was to do so through Renta WEB. She then gives the floor to the Deputy Director General of Tax Technology to provide further details on the analysis process that was carried out.

Ms. Mercedes Jordán begins her speech by pointing out that the statements made by the then Director of the Tax Management Department at the previous plenary session to the effect that refunds would be expedited and processed diligently remain valid since said refunds are identified and the origin of the correction is known. He added that an ad hoc form was not prepared because it was considered that the most effective option 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. He also points out that it was already mentioned at some meeting of the working groups that the acquisition values were not well reported in the case of properties acquired for profit, since the Tax Agency had followed the criteria of the General Directorate of Taxes in this matter, of which the AEDAF was fully informed, since it had requested the reports through the Transparency Portal. Finally, Ms. Mercedes Jordán reiterates that requests for rectification will be processed with diligence, agility and due priority, since the traceability between the request for rectification and the reason for it is perfectly identified.

Next, Mr. Rafael Gil March, representative of the General Council of Spanish Lawyers (CGAE), took the floor. After thanking Ms. Rosa María Prieto for the excellent treatment provided and hoping that her successor in the position, Mr. Ignacio Fraisero, will continue in the same vein, he wished them both the best of success. Next, in relation to the statements derived from DAC 6, he asked whether the volume of submissions was known and whether they had provided useful information, that is, given that they included potentially aggressive but not illicit tax planning operations, whether they had served to enable the Administration to detect situations that did not really have a planned regulation.

Mr. Jesús Gascón replied that a systematic analysis of the information is currently being carried out and that it will be shared with those present at a future meeting. For his part, Mr Javier Hurtado adds that, based on first impressions, whether a mechanism is lawful or not can only be determined by studying each case.

Mr Rafael Gil March comments that, in his opinion, a meeting on this issue is indeed necessary since there is a great deal of confusion and lack of knowledge about where these types of mechanisms fit in, which, while legal, may reveal some deficiencies in their regulation.

Next, Mr. José Castaño Semitiel, representative of the General Council of Official Colleges of Social Graduates of Spain, spoke. He first of all thanked Ms. Inés María Bardón Rafael for her presence at the twentieth plenary session. He added that he would also like to thank Mr. Gonzalo García de Castro for his work and the good relationship he has always maintained with the participants in this Forum. He also congratulated Ms. Rosa María Prieto and Mr. Ignacio Fraisero on their new appointments. On the other hand, he reports that he is receiving many calls regarding direct debits in BANKIA for form 583 that were not being attended to. Ask whether the Tax Agency has any information on this matter and, above all, to take it into account when any incidents are detected. He adds that he also wants to propose that the next meeting of the working groups include the problem that the group of social collaborators has in relation to the telephone number of the Tax Collection Department, since, for security reasons, a SMS is sent to the taxpayer who, at that time, is most likely not in the presence of the tax professional. He adds that a way should be found so that the social collaborator himself, representing his clients, can access the service and manage the relevant procedures. Finally, in relation to the Code of Good Practice, he points out that the General Council had informed the former Director of the Planning and Institutional Relations Service of its interest in carrying out an awareness campaign among its group. He asked for confirmation as to whether this matter should now be discussed with the new Director of the Service.

Mr. Ignacio Fraisero Aranguren replied that, of course, the Service he heads 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 Practice. On the other hand, without prejudice to what the Director of Revenue may wish 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 Tax Collection Department, then takes the floor to point out that it is not the intention of the Tax Agency to make the work of social collaborators difficult and reiterates what Mr. Ignacio Fraisero had said regarding the fact that the problem is being analyzed in order to establish a system that, while meeting all security conditions, will guarantee an optimal service. On the other hand, he points out that, in relation to the direct debits in BANKIA that are not being attended to, his Department will review whether there is any type of specific incident and will communicate it to those attending.

Next, Ms. Pilar Jurado Borrego, Director of the Customs and Excise Department, asks Mr. José Castaño Semitiel whether the incident mentioned regarding form 583 is also occurring with the direct debit of other self-assessments.

Mr. José Castaño replied that he assumed that this was happening with more models, but that the calls he had received were referring to model 583, the last day for which to file was November 22.

Ms. Pilar Jurado comments that the incidents are possibly due to internal adjustments arising from the merger.

Mr Rafael Gil then indicated that he wished to reiterate an issue already discussed at the working group meeting in relation to assistance at the Delegations, which is that there are still many restrictions on access to the offices and that, in addition, the appointment system, at least in the Balearic Islands, does not work well at all and there are cases in which the deadline for submission is short and it takes days to obtain assistance or an appointment. He added that this situation is occurring in general throughout the Administration and not only in the Tax Agency. He reiterated 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 the care and assistance services and that there is no problem in including this topic in the next meetings of the working groups.

Since there are no new interventions, the President of the State Tax Administration Agency thanks those present for their presence and participation and closes the twentieth plenary session of the Forum of Associations and Colleges of Tax Professionals.