Minutes of the meeting

MINUTES OF THE PLENARY MEETING OF THE FORUM OF ASSOCIATIONS AND COLLEGES OF TAX PROFESSIONALS

CELEBRATED ON JULY 10, 2024

President of the Forum of Associations and Colleges of Tax Professionals

Director General of the State Agency for Tax Administration

Ms. Soledad Fernandez Doctor

Members representing the Tax Agency

Director of the Tax Management Department

Mrs. Rosa Maria Prieto del Rey

Director of the Collection Department

Mrs. Virginia Muñoz Fernández

Director of the Department of Aduanas and Excise Duties

Ms. Nerea Rodríguez Entremonzaga

Director of Legal Services

Mr. Diego Loma-Osorio Lerena

Director of the Planning and Institutional Relations Service

Mr. Ignacio Fraisero Aranguren

Special Delegate of the Special Delegation of Catalonia

Mr. Isidoro Garcia Millan

Deputy Director General of Legal Management and Legal Assistance of the Department of Financial and Tax Inspection

Mr. Manuel Luis Martínez Cabeza

Deputy Director General of Applications of the Tax Information Technology Department

Mrs. Cristina Alvarez Zazo

Members representing Associations and Colleges

Spanish Association of Tax Advisors

Member in charge of Studies, Research and Institutional Relations

Mr. Juan Manuel Herrero from Egaña Espinosa de los Monteros

Director of the Office of Studies and Research

Mr. Arturo Javier Jimenez Happy

Professional Association of Accounting and Tax Experts of Spain

Secretary of the Board of Directors

Mr. José Antonio Fernández García-Moreno

General Council of the Spanish Bar Association

Deputy Director of Legal Services

Mr. José Ramón Álvarez Cañedo

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 Luis Perea Prieto

Spanish Federation of Professional Associations of Tax Technicians and Tax Advisors

Chairperson

Mr. Joan Torres Torres

Second Vice President

Mr. Adolfo Jimenez Ramirez

Office of Administrative Managers and Tax Advisors

GESAF Coordinator

Mr. Carlos de Nicolas Ortells

Registry of Tax Advisors Economists

Member of the Board of Directors

Mr. Jesus Fernandez-Bravo Pinto

Member of the Board of Directors

Ms. Monica Segura Canton

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

The twenty-fifth plenary meeting of the Forum of Associations and Colleges of Tax Professionals will be held on July 10, 2024, with the attendance of the persons listed and in accordance with the following:

AGENDA

1. Opening of the session.
2. Approval of the minutes of the meeting held on November 30, 2023.
3. Information on the topics discussed in the working groups.
4. 2023 Income Tax Campaign Results.
5. NRCO Utilities.
6. Status of pending proposals.
7. Next call.
8. Other considerations, requests and questions.

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

The session is opened by Ms. Soledad Fernández Doctor, Director General of the State Tax Administration Agency (hereinafter, the Tax Agency) and President of the Forum of Associations and Colleges of Tax Professionals, who, after greeting the attendees and thanking them for their presence, lists the different topics on the agenda and, without further delay, gives way to the first of them.

2. Approval of the minutes of the meeting held on November 30, 2023

Ms. Soledad Fernández Doctor, 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 twenty-fourth plenary session were sent to the associations and colleges prior to this meeting.

Having received an observation from FETTAF, which has been incorporated into the minutes, the Deputy Director adds that, if there were no further observations at this time, it would be definitively approved. Since no objections were raised, the minutes of the 24th plenary session, which took place on 30 November 2023, are hereby declared approved.

3.Information on the topics discussed in the working groups

The Director General of the Tax Agency gives the floor to the Director of the Tax Management Department, Ms. Rosa Mª Prieto, who points out that the working group first discussed the VAT exemption regime.

Ms. Rosa Mª Prieto points out that it was the representative of the General Directorate of Taxes who explained this issue, reporting that article 281 of the VAT Directive includes the possibility of regulating simplified regimes, with the equivalence surcharge regime and the simplified regime existing in Spain. However, these two regimes do not exist in other Member States, which have been approving and applying the franchise regime, with a maximum threshold of 85,000 euros.

The approval of the franchise regime should be viewed from the perspective of tax policy and not just from a technical point of view, and it is unknown whether it will ultimately be approved. A different issue is the cross-border tax-free regime, which will come into force on 1 January 2025 and will allow Spain to establish the possibility for certain taxpayers to apply the tax-free regime in other Member States. To do so, it would be necessary to submit a census declaration, stating that this franchise regime is being chosen and reporting the volume of operations in the previous calendar year or, where applicable, in the two previous years. A quarterly information declaration must also be submitted, reporting the quarterly trading volume and, where applicable, whether the maximum threshold has been exceeded.

The Director of the Management Department indicated that, secondly, the status of corrective self-assessments was discussed, recalling that the implementation of this new system required legal modifications and regulations for the various taxes, specifically VAT, personal income tax, corporate tax, special taxes and taxes on fluorinated gases.

Likewise, for the implementation of the new figure of the corrective self-assessment, it was indicated that the approval of the ministerial orders of the corresponding models was necessary, starting with the VAT model 303 and the expected date for it to come into force being the third quarter, for those who have quarterly settlement, or in the month of September, in the case of monthly settlement. Among the new features that would be introduced in Form 303, it was highlighted that in the form itself boxes were created to indicate the reasons for the rectification, in order to make effective judicial protection effective, an issue that was requested within this forum.

Regarding corporate tax and personal income tax, the Director of the Management Department indicates that the intention is to approve the model in 2024, adding the Director of the Customs Department that in 2025 the tax on fluorinated gases will begin.

Ms Rosa Prieto then recalled that the issue of the certificate of being up to date with tax obligations in the case of temporarily inactive companies was discussed, since professionals were faced with the problem that financial institutions required the certificate.

However, it was clarified in the working group that in order to obtain the certificate it was necessary to be registered in the census of entrepreneurs and professionals and, therefore, the first of the requirements was not met.

The next issue addressed was the problems arising from the rehabilitation of a revoked NIF, distinguishing two problems, on the one hand, justifying the economic activity and, on the other hand, the cases in which a company is going to be dissolved or liquidated. In the latter case, despite the fact that instructions had been sent to registrars and notaries not to hinder the dissolution or liquidation, some registrars and notaries did not allow such operations if the NIF had been revoked. The Director of the Management Department informs the professionals who are studying a way out so that the company can finally be dissolved and liquidated.

Another issue addressed was the notification of the start of a sanctioning procedure, since certain changes had been made in the area of tax management, at the request of the taxpayer, in order to facilitate the processing of sanctioning procedures.

The working group explained that if the taxpayer agreed with the penalty notified at the beginning and there were no objections, he could grant tacit consent electronically, without having to wait for the objections process.

Ms. Rosa Prieto also points out that this tacit consent was distinguished from the consent that must be provided expressly in the inspection procedure, the latter being regulated in article 25 of the regulations governing the sanctioning procedure in the tax field.

Mr. Ignacio Fraisero then referred to the fact that the working group announced that a pilot test would be launched on April 8 to offer the specialized appointment to authenticated social collaborators who were registered as social collaborators or delegated social collaborators and who were adhering to the Code of Good Tax Practices. This pilot test was limited to the provision of some assistance services by some Delegations.

The Director of SEPRI reiterates these services, summarizing what was discussed in the working group and requests that the different incidents or lines of improvement be transferred by the representatives of the professionals.

On the other hand, Mr. Ignacio Fraisero comments that the working group was informed about the status of the pending proposals, suggesting the FETTAF representative to incorporate a new task related to the companies that were in the SII, so that they present models 349 and 303 on the same date.

Since there is an item on the agenda devoted to the analysis of the status of pending proposals, the Director of SEPRI announces that this issue will be developed below, in the sixth section.

The Director of the Tax Agency thanks the working group for its summary and asks if anyone wishes to speak, with the AEDAF representative requesting that part of the content of the explanatory note on Form 303 be incorporated into the legal text of the order. Ms. Rosa Prieto clarifies that incorporation into the text is no longer possible from a temporal point of view. There being no further interventions, Ms. Soledad Fernández gave way to the next point on the agenda.

4. 2023 Income Tax Campaign Results

The Director of the Management Department comments on the main figures of the campaign, pointing out that, with regard to access to personalized income services, there has been an increase of just over 5% and emphasizing the increase in certified services. Access with reference also continues to grow significantly, but access with a password is decreasing. Ms Rosa Mª Prieto also highlights the use of the mobile application, which is improving and increasing its use, with downloads increasing by more than 21%.

The number of tax returns filed has increased from 23 million last year to more than 24 million, with the number of online filings increasing by 4.98%, in-person filings by 6.67% and telephone filings by 5.41%.

The Director of the Management Department places special emphasis on the assistance provided both in person and by telephone, as this year a significant effort has been made to assist all those who needed the assistance of the Tax Agency to file their tax return.

Based on the results, we can distinguish the declarations submitted for payment, which have decreased by 2.95%, the declarations with refund requests, which have increased by 8.04%, and the negative declarations and waivers, which have also increased, although to a lesser extent.

Among the virtual assistance tools, 38,238 queries have been received in the chat, and the Director of the Management Department reported that almost all of them have been attended to, with the deduction for maternity and the deduction for rent for habitual residence being the issues with the greatest demand.

As a summary of this year compared to last year, Ms. Rosa Mª Prieto reports that automatic responses have increased by 48% compared to the previous year and the number of chats attended has increased by 46%, going from 26,500 to 38,600.

Other assistance services were the 112 telephone service for income information and those provided by the Comprehensive Digital Administrations, with 38,000 calls with immediate appointments.

Ms Rosa Mª Prieto highlights the launch of the Informa+ income tax system, available at the headquarters since 17 May to answer the most complex questions, and points out that a total of 4,029 queries were answered.

Once the presentation by Ms. Rosa Mª Prieto had concluded, the Director General of the Tax Agency asked if there were any questions related to the subject, asking Mr. José Castaño what the status of the resolutions on the mutual members' refund requests is. Regarding mutual societies, Mr José Castaño also asked how data from previous years could be obtained in order to correctly apply reductions and deductions.

The Director of the Management Department replies that requests for rectification of self-assessment are being resolved gradually and that it is hoped that non-declarants will be able to start being paid before the end of July. However, a communication will be sent to all those who have submitted the form, whether or not they are entitled to a refund, indicating the status of their form.

Regarding the 2023 adjustment, Ms. Rosa Mª Prieto believes that it is difficult to have information incorporated for previous years as well and that one thing is the adjustment, which will be applied to the person who is retired, and another thing is who will be able to apply the minimum, which is the descendant.

On the other hand, Mr. José Castaño explains, regarding the deduction for daycare, the problem that has arisen after the modification of the model, since it is no longer an essential requirement that the center be authorized. However, in some regional deductions, such as in Murcia, the legislation does require authorization from the Department of Education. The problem arises because the professional does not know whether the center is authorized or not, so Mr. José Castaño asks if the data on whether it is authorized or not could somehow be required in the model.

The Director of Management acknowledges that it can be complicated since, if each community sets a requirement, it is difficult to include them all in the model. Ms Rosa Mª Prieto requests that the problem be forwarded through the Technical Secretariat and it will be studied and analysed.

Mr. Joan Torres asks whether the Autonomous Communities communicate all the data on disability, rents, etc.

The Director of Management answers that the Autonomous Communities transfer information and that what is included in the tax data is the information they provide, but that not all of the information is transferred by them.

The Director of the Tax Agency agrees that it is necessary for the Autonomous Communities to facilitate this task in a simpler way, and the request will therefore be forwarded.

Ms. Cristina Álvarez adds that there is a model, 993, through which the Autonomous Communities send the information, however, sometimes their regulations are very complex and not even the community itself has all the information.

5. NRCO Utilities

The Director General of the Tax Agency gives the floor to the Director of the Revenue Department, who clarifies that the initials NRCO refer to the complete online reference number. The NRCO is basically the ID of each payment or income that occurs in relation to all debts managed by the Tax Agency.

Ms. Virginia Muñoz points out that the system is innovative, has a fairly advanced implementation and has greatly improved the previous system from 1998. In the previous system, income was known through the so-called fortnightly reports, information that was given by the collaborating entities every 15 or 30 days. Under that system, citizens were required to provide proof of payment, which led to numerous actions and delays in actions. Until 15, 30 or sometimes 40 days had passed, no action could be taken, which led to a lack of public understanding and an increase in conflict, with some of the actions being carried out with outdated information. There were also reversals in the entities without the Agency's knowledge and control could only be carried out a posteriori.

With the new system, information will be available online more quickly, allowing the Tax Agency and all citizens to use this information, with total security and greater control, eliminating manual validations and counter stamps and allowing control to be carried out at any time.

In addition, the Director of the Tax Collection Department indicates that with the new system a paid settlement can no longer be reversed, unless there is an exceptional problem. All of this will allow the information to be used both in processes initiated by a party (issuing certificates of compliance with tax obligations, granting guarantees, resolving appeals, etc.) and in procedures initiated ex officio.

Likewise, in the Pay, defer and consult APP, not only any citizen with Cl@ve can consult, but also companies with an electronic certificate. In the “Check debts or my payments” section, when you enter “My payments”, which is a feature of the NRC, you will be able to check when the payment was made and download a receipt.

The Director of Collection indicates that 70% of the accesses made to “My payments” are done from the APP. Thus, since July 2022, there have been more than 1,500,000 accesses, of which more than 1,000,000 have already occurred through the APP.

Ms. Virginia Muñoz adds that among the advantages of the system, when a person requests a certificate of being up to date and has just paid a debt, the system recognizes it and issues the certificate with a positive result. On May 3, 2023, a system was also established for all those who were not technologically adapted, who do not have Cl@ve or who cannot access the APP or the Headquarters, allowing them to call by phone after payment and change the meaning of the certificate to positive.

The Director of the Collection Department also points out the importance of the NRC in seizure proceedings, as all the information related to seizures of credits, POS terminals and others is used, which allows knowing that the seized person is paying at that time, unlike the previous system, in which there was a difference of approximately one month. This system will allow the embargo to be reduced or lifted, as well as reducing the outstanding debt in deferrals and installments.

The Director General of the Tax Agency thanks the Department of Tax Collection and the DIT for their efforts in the new system that allows for addressing needs in a much more agile manner, and asks whether there are any interventions on this matter.

Both Mr. José Castaño and Mr. Joan Torres congratulate the Tax Collection Department and the DIT and emphasize the speed of information not only in the payment of debts but also in the payment of penalties.

6. Status of pending proposals

The Director of SEPRI explains that, in relation to pending tasks, a distinction has been made between completed measures, those under study, those in process and those that are not viable, and that those that are completed and not viable must be gradually eliminated in order to focus the working groups on the pending viable proposals.

Regarding the first proposal, to eliminate notification notices on weekends, this was already implemented in March and has now been extended to national holidays, so it is considered fulfilled.

Secondly, declaring the month of August as a non-working month requires a regulatory change, which is why it is considered unfeasible.

Thirdly, the modification of the taxpayer's calendar in relation to local holidays is not considered viable due to the high number of municipalities.

As for proposal no. 4, unifying the submission deadlines to be carried out in the month of January, bringing them all to the 30th, this requires a regulatory modification and a budgetary assessment, which is why it is considered unfeasible.

Proposal No. 5, to make the deadline for direct debiting of self-assessments coincide with the last day of the deadline for their submission, has already been explained in detail, with a commitment to reduce the deadline to the lesser of 3 working days or 5 calendar days. The Director of the Tax Collection Department adds that the novelty is that this commitment will be recorded at a ministerial level.

Regarding proposal no. 6, dedicated to the specialized appointment aimed at professionals adhering to the Code of Good Tax Practices, it has already been mentioned that a pilot test was launched on April 8, limited to certain territorial areas and services, extending from July 1 to the entire national territory. A guide has also been sent to the Colleges and Associations, which contains the steps to follow in order to request this specialised appointment with the different professionals. The Special Delegates will also meet with the schools and associations in their area to inform them that they have the option of making a specialised appointment throughout the country. This proposal has been fulfilled, although improvements will continue and special work will be done to broaden the dissemination of the measure.

Proposal No. 7 on the simplification of administrative language has also been fulfilled, starting with collection documents and income requirements for 2023, among others.

Proposal No. 8, the recognition of the social work of the tax intermediary, is included in the Strategic Plan 2024-2027 itself, where the relevant role of tax professionals is already established, and is therefore considered to be fulfilled.

Measure No. 9, greater participation of social collaborators in the preparation of regulatory projects, is considered fulfilled; However, No. 10, which refers to greater participation in meetings with financial institutions, is not viable.

Proposal No. 11, bringing the verification procedures closer to the date or time of the taxable event, is currently under study, as it requires a period of maturation.

The following proposal, number 12, the provision of the NIE by a single member of the governing body of non-resident entities for the performance of specific operations, requires a modification of the regulations.

Proposal No. 13 involves the creation of a logo, which, although approved, is in process, pending the determination of the rules of use.

Proposal No. 14, to direct deposit supplementary income tax returns from previous years for the receipt of wage arrears, is currently in process. Ms. Virginia Muñoz clarifies that, for late direct debits in complementary accounts, it is not feasible, since this implies collecting files to direct debit them with the banks every day. Regarding the supplementary measures submitted on time, Ms. Cristina Álvarez points out that they cannot be implemented in the short term, since coordination with the banks is necessary. For example, in the case of non-resident tax returns, direct debit is allowed, even if it is submitted later; however, this poses a problem because the tax returns submitted throughout the year accumulate and are collected in January. Furthermore, sometimes, mainly in cases of mergers, banks do not remember to collect the direct debit, resulting in numerous problems with declarations by non-residents.

Proposal no. 15, direct debit of form 309, is considered fulfilled.

Regarding the unification of the CNAE and IAE codes, proposal no. 16 is classified as under study, with no new developments.

Proposal No. 17, the introduction of greater netting in bank transactions between accounts of the same account holder, requires a redesign of the information supply model and has high indirect costs for banks, which is why this proposal is currently under study.

The following, number 18, consisting of reiterating to the Notarial Council and the Council of Property Registrars instructions regarding the revocation of the NIF, has been carried out. Option 19, the inclusion of a simple note in the information provided in real estate auction procedures, has also been fulfilled.

As regards greater coordination between the Tax Agency and the Autonomous Communities in relation to taxes whose management is transferred, proposal no. 20, this is in process to improve the existing mechanisms.

Proposal No. 21, to provide companies with a certificate of withholdings when the employment relationship has ended and there is more than one payer during the same financial year, requires regulatory modification and involves more indirect costs, with doubts existing as to whether the financial information of a payer can be shared with another payer. It is therefore considered unfeasible.

Proposal 22, sharing data relating to the self-employed regime with Social Security, has already been fulfilled.

Regarding proposal no. 23, to improve the management of the refund of the special tax on non-reusable plastic packaging, work is being done on a computer development for the presentation and processing of refund requests and in the Electronic Office itself taxpayers can find both an Excel where they can reflect the list of supporting documents and the refund request model.

As regards reducing delays in the procedures for obtaining the NIE, proposal no. 24 is considered unfeasible, since it is not the responsibility of the Tax Agency.

Proposal No. 25 is also considered unviable since certain issues regarding corrective self-assessments can no longer be reflected in the regulations.

Regarding the criteria for admission of deductible expenses, proposal no. 26, it is under study since the criteria are derived from the regulatory field, from the binding doctrines of the DGT and the Economic Administrative Court.

Regarding proposal no. 27, unifying the filing date of forms 349 and 303, this is not viable since changing form 303 has a strong impact and furthermore form 349 is likely to be subject to a Community modification.

Proposals submitted by the College of Economists have also been incorporated. Firstly, number 28 on updating a note on bankruptcy proceedings is in process. Regarding the lack of a requirement for a specific format to provide documentation, number 29, this has been put under study because it is necessary to specify what the specific request is.

Proposal No. 30, adapting the calendar so that tax payments do not coincide with days before public holidays, is not considered viable. Nor is option 31 considered viable, the presentation of annual accounts according to the model in force when they were approved, provided that it is presented before the publication of a new model, due to lack of competence.

Proposal No. 32, improving procedures to avoid in-person verification of documentation, has been put under review, but there are doubts regarding the scope of the request.

Proposal No. 33, to analyse requests for unification of criteria put forward by professionals when different actions are reported in similar cases, is considered to have been fulfilled, since the Code of Good Tax Practices includes the possibility for professionals to contact the Tax Agency to resolve such discrepancies.

Regarding the proposals in the memorandum of Asesores Unidos, all attendees agreed not to include them since the Forum is the place created to analyze and debate the proposals of the representatives of the professionals and it is unknown who signed the measures in the memorandum.

Mr. Adolfo Jiménez asks if the updated list can be forwarded to him, to which Mr. Ignacio Fraisero replies that the list will be sent to everyone.

Mr. Manuel López Frías asks how to solve the problem regarding the impossibility of requesting an official NIF to make an import declaration by a non-resident, since by not having a NIF he cannot submit the declaration.

Ms. Nerea Rodríguez indicates that the official NIF is a tool used in very specific cases, and that, therefore, it would be necessary to see whether or not the specific case meets these requirements. Mr. Manuel López Frías answers that he will forward the assumption to him.

Likewise, Mr. Ignacio Fraisero reiterates that any new proposals or problems that arise should be sent in writing.

Mr. Juan Manuel Herrero asks, regarding proposal no. 18, whether it is possible to forward the reiteration formulated to notaries and registrars so that they do not cause problems in cases of dissolution and liquidation.

Ms Rosa Mª Prieto explains that work is being done on the possibility of considering this as a cause for reinstatement of the NIF, so it would be more prudent to wait for the change and thus avoid causing further confusion.

Mr. Jesús Fernández Bravo adds some problems such as the impossibility of presenting accounts in the Commercial Registry, the short deadline for filing the Corporate Tax or the scarce information provided by the declaration of share ownership.

Ms. Rosa Mª Prieto refers to the great need for both human and technological resources needed for Income Tax, making it difficult to anticipate more tax data for Companies, with the Director General of the Tax Agency emphasizing that there has been a lot of progress in the tax data for Income Tax and that it is understandable that the same will happen with Companies, steps will be taken and an attempt will be made to provide more information.

Ms. Soledad Fernández adds that the requirement to have information on the beneficial ownership of companies has its origin in the commitments with Europe, since for certain European aid and funds it is necessary to carry out a control of beneficial ownership, information that was not always available.

Ms. Pilar Otero then reports, with regard to proposals 29 and 32, that in some delegations the problem of issuing generic information requests persists, requesting all invoices for a financial year. The Director General of the Tax Agency requests that these problems be sent in writing in a brief and precise manner.

Mr. José Castaño indicates, with regard to the subject of the tax data of Companies, that the surcharges and penalties of the Tax Agency do not appear in the tax data, and Ms. Rosa Mª Prieto responds that the specific case should be sent to her in order to analyze, if applicable, the incident that occurred.

7. Next call

Ms. Soledad Fernández stated that the intention was to maintain the semi-annual frequency of the meetings, noting in this regard that the next meeting would likely be held in November.

8. Other considerations, requests and questions

The Director General of the Tax Agency refers to the question raised by FETTAF on the sixth Additional Provision of Royal Decree Law 8/2023, which adopts measures to address the consequences of the conflicts in Ukraine and the Middle East, as well as to alleviate the effects of the drought.

This provision establishes that the Tax Agency will assess the sufficiency of the assistance measures in filing personal income tax returns electronically; However, Mr. Joan Torres requests clarification of the provision when he says that the assessment may be carried out through reports from members of the Professional Forum. Mr Joan Torres alleges that the data is held by the Tax Agency and that it is not clear what report the professionals must prepare.

Ms. Rosa Mª Prieto clarifies that this assessment must be made by the Tax Agency and transferred to the Council for the Defense of the Taxpayer, which is the one that prepares the final report. The Tax Agency already has this information through the surveys carried out during the campaign.

The Director of the Tax Management Department also reports that the Sixth Additional Provision refers to association forums, so in September a document will be sent to the associations so that they can respond and add what they consider necessary. Once the information has been received, a report will be prepared with the Tax Agency's assessment and will be sent to the Taxpayer Protection Council so that they can complete the final report.

On the other hand, the representative of AEDAF asks when the electronic invoicing regulations are expected to be published, with the Director General of the Tax Agency clarifying that they do not have a date since a question related to data protection was being analysed, adding the Director of the Legal Service that a regulation with the rank of law would be necessary.

Since there are no new interventions, the Director General of the Tax Agency thanks those who attended for their presence and participation and closes the twenty-fifth plenary session of the Forum of Associations and Colleges of Tax Professionals.