Minutes of the session

MINUTES OF THE PLENARY SESSION 1/2023

Minutes of the Plenary Meeting of the Forum of Federations and Associations of Self-Employed Workers
held on March 13, 2023

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 Collection Department

Mrs. Virginia Muñoz Fernández

Director of the Tax Information Technology Department

Mr. Jose Borja Tome

Director of the Planning and Institutional Relations Service

Mr. Ignacio Fraisero Aranguren

Members representing Federations and Associations of Self-Employed Workers

National Federation of Associations of Self-Employed Workers (ATA)

Executive Vice President

Mrs. Celia Ferrero Romero

Union of Self-Employed and Entrepreneurial Workers Associations (Unión de Asociaciones de Trabajadores Autónomos y Emprendedores - UATAE)

Chairperson

Mr. Raul Salinero Lacarta

Union of Professionals and Self-Employed Workers (Unión de Profesionales y Trabajadores Autónomos - UPTA)

Secretary of Organization

Mr. Cesar Garcia Arnal

Technical Secretariat of the Forum of Federations and Associations of Self-Employed Workers

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

Mrs. Maria Dolores Carreno Beltran

On March 13, 2023, the third plenary session of the Forum of Federations and Associations of Self-Employed Workers will be held, attended by the persons mentioned, and in accordance with the following

AGENDA

1. Opening of the session.
2. Approval of the minutes of the meeting held on October 24, 2022.
3. Approval, where appropriate, of any changes to the Forum's Operating Rules.
4. Planning and accountability of the Tax Agency.
5. Elimination of pre-declaration in form 303. Information on the enabled payment letter system (individuals and entities without monthly settlement other than companies A and B).
6. Electronic billing: regulatory projects.
7. New Auction Portal AEAT .
8. Next call: dates and topics to be discussed.
9. Other considerations, requests and questions.

1. Session opening

The session is opened by Mr. Ignacio Fraisero Aranguren, Director of the Planning and Institutional Relations Service, who, after welcoming and thanking the attendees for their presence at the third session of the Plenary Session of the Forum of Federations and Associations of Self-Employed Workers, apologises for the absence of Ms. Soledad Fernández Doctor, General Director of the Tax Agency and President of the Forum, who was prevented from attending the plenary session due to last-minute scheduling problems.

2. Approval of the minutes of the meeting held on October 24, 2022

Mr. Ignacio Fraisero 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 the Forum, who states that the minutes of the second plenary session were sent to the federations and associations prior to this meeting, and that no comments had been received; He adds that if there were none at this time, it would be definitively approved. Since no objection has been raised, the minutes of the second plenary session held on 24 October 2022 are hereby approved and it is announced that they will be published on the Tax Agency's electronic headquarters in the section dedicated to this Forum.

3. Approval, if applicable, of the modifications to the Forum's Operating Rules

In relation to this point of the agenda, the Director of the Planning and Institutional Relations Service points out that at the previous plenary session it was announced that it would be appropriate to modify the Rules of operation of the Forum, establishing an ordinary plenary meeting per year and that, likewise, depending on the issues to be addressed, it could be determined that ordinary or extraordinary sessions of the Plenary of this Forum and the Plenary of the Forum of Small and Medium-sized Enterprises would be held jointly. He added that these amendments had been submitted to the members of the Forum, but that no comments had been received to date and that, if no comments were made at this time, they would be approved; Since no objections are raised, the amendments to the Forum's Rules of Operation are hereby approved. In this regard, the Director of the Planning and Institutional Relations Service informed those present that this issue was also included in the agenda of the third plenary session of the Small and Medium-sized Enterprises Forum and had been approved by its members. Finally, Mr. Ignacio Fraisero clarifies that, of course, extraordinary sessions may be held as deemed appropriate.

4. Planning and accountability of the Tax Agency

The Director of the Planning and Institutional Relations Service reports that the addendum for the 2023 fiscal year of the Strategic Plan of the Tax Agency 2020-2023 had been published on the electronic headquarters last February, and that the following issues could be highlighted from it:

• In 2023, work is being done on implementing a new information and assistance model by structuring the coordination between face-to-face and telephone assistance services, distributed throughout the national territory, with the Comprehensive Digital Assistance Administrations ( ADI ), which will provide not only digital assistance to taxpayers, but also to the Tax Agency staff dedicated to assistance tasks, thus achieving a permanent connection and homogeneity in terms of action protocols and criteria. The aim of the model is to ensure that most services are provided through all channels, facilitating and simplifying access to them so that citizens can decide how they want or need to be served. This model is developed from the following instruments:
  • New appointment application that incorporates more understandable language and improves usability.
  • Definition of a complete service charter to be published on the electronic site, facilitating access to said services. A simplified version will also be included in the Tax Agency's APP.
  • Unification of telephone assistance provided by Tax Agency staff, regardless of their territorial location, through a centrally coordinated service via the ADI .
• Strengthening the cooperative relationship: The establishment of a Forum with companies, institutions and public entities is planned, as well as, within the framework of the Large Companies Forum, the approval of a new annex to the Code of Good Tax Practices that will enable the early provision of information relating to transfer pricing by entities that voluntarily decide to do so.
• Progress in resolving requests for corporate tax refunds from SMEs: This project, to be developed over several years, aims to gradually advance the agreement on refunds that meet certain requirements, so that a significant percentage of the amount requested would be returned closer to the end of the tax filing period.
• Review of the current criteria for processing deferrals and installment payments, so as to make granting them more flexible for those who meet certain requirements.
• Digitalisation project for self-employed workers and SMEs: We will continue to advance this project in order to modernize and professionalize administrative management and facilitate compliance with formal obligations for these groups.

Regarding this last issue, Mr. Ignacio Fraisero indicates that it will be developed in the 6th point of the agenda, dedicated to electronic invoicing.

5. Elimination of pre-declaration in form 303. Information on the enabled payment letter system (individuals and entities without monthly settlement other than companies A and B)

To present this point on the agenda, the Director of the Planning and Institutional Relations Service gives the floor to Ms. Rosa María Prieto del Rey, Director of the Tax Management Department, who begins her speech by pointing out that this feature is aimed at individuals and entities that are not public limited companies or limited liability companies and that it consists of the possibility of, once the self-assessment has been submitted through the electronic office, printing a payment letter and going to a financial institution to pay it within the voluntary submission period. Thus, it adds that in the months of October and November an information letter was sent to taxpayers who had submitted the pre-declaration in the corresponding quarters of 2022, informing them that, for the self-assessments corresponding to the year 2023 and following, the possibility of submitting form 303 in printed paper was eliminated and that it was replaced by an easy-to-use and secure procedure, since in order to submit the self-assessment the taxpayer would have to identify himself/herself at the electronic headquarters using Cl@ve and certificate or DNI electronic. On the other hand, Ms. Rosa María Prieto informs that, once again, information letters will be sent to taxpayers who have submitted the pre-declaration in the 4th quarter of 2022, which are approximately 98,000, representing a fairly small percentage in relation to the filers of the same quarter who have used one of the electronic identification systems. Finally, the Director of the Tax Administration Department indicates that approximately 65,000 taxpayers who have used the paper pre-declaration in the 4th quarter do not have a means of electronic identification, so it is foreseeable that they will use the assistance services of the Tax Agency to obtain it or that they will decide to present the self-assessments of model 303 through a social collaborator.

6. Electronic billing: regulatory projects

To address this point on the agenda, the Director of the Planning and Institutional Relations Service gives the floor to Mr. Javier Hurtado Puerta, Director of the Department of Financial and Tax Inspection, who points out that, as everyone present knows, there are currently two regulatory projects in process that are, in some way, related to this matter, although with notable differences in terms of their content, information structure and purpose:

• Draft Royal Decree approving the regulations establishing the requirements that must be adopted by computer or electronic systems and programs that support the billing processes of entrepreneurs and professionals, and the standardization of billing record formats: promoted by the Tax Agency, is issued in development of article 29.2.j) of Law 58/2003, of December 17, General Tax, in the wording given by Law 11/2021, of July 9, on measures to prevent and combat tax fraud, in relation to the prohibition of dual-use software or sales concealment, affecting both B2B and B2C invoices. Likewise, the entities obliged to the SII are not within its subjective scope, since it is considered that it meets the security requirements of the data supplied. On the other hand, regarding its processing, it is currently awaiting the report from the Council of State.
• Draft Royal Decree implementing Law 18/2022, of September 28, on the creation and growth of companies in relation to electronic invoicing between companies and professionals: Promoted by the Ministry of Economic Affairs and Digital Transformation, its objectives are to provide greater efficiency to commercial traffic by advancing the digitalization of the Spanish business fabric, as well as reducing late payments by facilitating access to information on payment terms. On the other hand, it extends the obligation to issue and send electronic invoices to all commercial relations between entrepreneurs and professionals, that is, it establishes its universality, although it only affects B2B invoices. As regards its processing, the draft Royal Decree is currently in the prior public consultation phase.

Mr Javier Hurtado said that he had made these clarifications in order to avoid confusion, since some sectors had thought that the second project subsumed the first, which is not the case. However, he clarifies that the Ministries of Economic Affairs and Digital Transformation and of Finance and Civil Service are working together to determine the technical and information requirements to be included in the electronic invoice and that, within the framework of said work, the Tax Agency has presented a comprehensive proposal to provide an efficient and viable solution to the issue, which will be presented below by the Director of the Tax Information Technology Department.

Next, Mr. José Borja Tomé, Director of the Tax Information Technology Department, takes the floor and comments that before presenting the Tax Agency's proposal, he will elaborate on what the Director of the Financial and Tax Inspection Department had already pointed out, reiterating certain differences between the two projects:

• On the one hand there would be the systems of reporting fiscal, as is the case of SII or the current regulatory project for the development of secure billing systems, among which there is a modality that involves immediate sending of information to the Tax Agency, although it only involves supplying the information that is relevant from a fiscal point of view and not the complete content of the invoice. It should be noted that its objective is the prevention and fight against tax fraud.
• On the other hand, there would be the regulatory project for the development of Law 18/2022, which would establish the obligation of electronic invoicing in B2B exchanges and whose objectives are the reduction of commercial late payment and the digitalization of the Spanish business fabric. The Ministry of Economic Affairs and Digital Transformation is promoting, together with the Ministry of Finance and Public Administration, an electronic invoicing architecture whose scheme includes the following elements:
  • intermediated by a network of electronic invoice exchange platforms subject to minimum regulations regarding security, syntax, etc.;
  • supplemented by a basic public invoice exchange system provided by the Administration, in which the issuers of the invoices or the platforms designated by them will be obliged to deposit them in the electronic headquarters of the Tax Agency in a single format;
  • interoperable, thanks to the technical capacity of IT solutions and platforms to translate the most commonly used structured formats, based on international standards;
  • which also includes information on the payment date of invoices for transmission between the parties, as well as to the Administration for monitoring, promoting transparency as a measure against abuses in payment deadlines.

Mr. José Borja continues his presentation by pointing out that an architecture based on an interoperable network of platforms presents important challenges, such as the following:

• It will have a recurring cost for companies and professionals since they will have to contract the service with a private platform and, although this were to be provided free of charge, they would be paying a cost by communicating sensitive information in relation to their business operations.
• Although the possibility of the Tax Agency or a third party developing a public interoperability node to solve the problem of free communication between different platforms has been raised at some point, any such node will provide limited interoperability and the Tax Agency would not be in a position to undertake its construction, since putting interoperability into practice can be very complex, both due to the difficulty in defining and requiring it and in ensuring it.
• A way of ensuring the integrity of invoices will have to be established, probably through cryptographic electronic signature systems, which will complicate their implementation and use. Furthermore, it can be challenging to ensure such integrity when making the necessary format conversions.
• Supporting a multiplicity of formats will also generate invoice transformation costs. Furthermore, the fact that these formats can vary over time and have several variants can, in practice, represent an additional element of complexity.
• It will be necessary to determine what level of security is required of platforms, taking into account that the higher the level, the less likely they are to suffer cyber attacks. However, if the required level of security is very high, there will be fewer electronic billing service providers, which will lead to higher prices.
• It will be very costly for companies and professionals to comply with the obligation to report all payments. It will also be necessary to establish how the platforms consolidate and deliver the information to the Administration.

The Director of the Tax Information Technology Department then comments that the Tax Agency has participated in the working group that has defined the architecture promoted by the Ministry of Economic Affairs and Digital Transformation, where, from the outset, it has maintained that it lacked the means and technical skills to implement public systems to support it and, in particular, an interoperability node or a free public electronic invoicing platform that interoperates with the rest of the platforms. The Tax Agency has also pointed out some of the challenges outlined above and the impossibility of participating in a detailed definition of the system. Mr. José Borja also indicated that the Tax Agency has proposed a scheme for electronic invoicing which, based on a public system for the basic exchange of invoices and respecting the added value that electronic invoicing platforms can provide, would ensure the viability and usefulness of the system. He adds that this system would be additional to the fiscal billing information systems ( SII and Veri*factu) and that all companies and professionals would incorporate all their issued invoices into the electronic headquarters of the Tax Agency, with a unique format that would be validated together with the NIF of the issuer and the receiver. Likewise, these invoices would be available to both their recipients and the Tax Agency on its electronic headquarters. The Director of the Tax Information Technology Department points out that the proposed system is based on the following elements:

• Establishment of a public system for the exchange of B2B invoices in a single format, which could be Facturae, since its use is widespread because it is mandatory in B2G relationships, although it could also be another one that was aligned with European standards, but always maintaining uniqueness. However, the final decision on the single format to be adopted will have to be taken by the Ministry of Economic Affairs and Digital Transformation.
• Obligation to communicate all B2B invoices to the electronic headquarters of the Tax Agency by their issuers.
• Made available to recipients or representatives at the electronic headquarters of the Tax Agency. Thus, as a universal obligation, all companies and professionals will have all their invoices available online. However, the taxpayer may also use a private invoicing platform to exchange invoices and manage everything related to them.
• It is prohibited to force the issuer to communicate the invoice to the recipient through a platform other than the electronic headquarters of the Tax Agency.
• Validation of the format and the NIF of the issuer and receiver of the invoices at the headquarters of the Tax Agency, rejecting those that do not conform to the standard format. This validation is the minimum required for invoice recipients to automatically integrate the electronic invoices received into their computer systems. Although initially the rejection of invoices for other reasons is not proposed for reasons of simplicity, in order not to hinder the exchange of invoices and limit the Tax Agency's access to their non-tax content, the possibility and opportunity will be evaluated later. of other content validations and, in particular, of its consistency with the VAT record books.
• The Tax Agency will offer a form at its headquarters for the preparation and registration of simple invoices for small issuers. These invoices will be available to their recipients in Facturae format on the Tax Agency's electronic headquarters.
• Invoice payment information would be communicated compulsorily by invoice recipients of SII and voluntarily by Veri*factu invoice issuers. Your counterparties may consult this information at the Tax Agency's headquarters and, where appropriate, report discrepancies both as to whether the payment has not been made and the actual date on which it was made. In addition, the possibility of converging the invoice exchange system with SII and Veri*factu would be studied at a later time, when the invoice exchange was well established. On the other hand, the participation of financial institutions in the model has been ruled out due to the complexity that it would entail, especially with regard to the identification at the time of payment of the recipient, the origin of the payment, and the invoice to which it may refer.

The Director of the Tax Information Technology Department then points out that the following advantages and disadvantages of this proposal can be highlighted:

• Advantages:
  • This is a viable alternative with a moderate cost for companies and professionals, lower than any other alternative in the timeframes proposed.
  • The different parts of the project can be developed independently and will add value as soon as they are put into service. For example, payment information that would be articulated on the current books of invoices received from SII , can begin to be consolidated regardless of whether the complete invoice information from all business owners and professionals has begun to be received.
  • It does not require entrepreneurs to communicate sensitive information to private platforms.
  • The system allows companies and professionals to exchange structured electronic invoices that can be automatically incorporated into their computer systems.
  • By establishing a single format, a national standard is adopted that simplifies automated processing in most cases.
  • A system is being implemented that allows for basic control of payment periods, especially for large companies, without imposing a disproportionate burden of information. This information will be consolidated in the Tax Agency for use by the economic authorities.
  • The risk of invoice alteration on private platforms with fraudulent intent is reduced.
  • Maintaining a minimum validation of the format and the NIF of the invoices exchanged in the system will make its deployment easier. Similarly, maintaining a submission of invoice content independent of the submission of billing records from the SII and Veri*factu systems will simplify compliance with the obligations of business owners and professionals.
  • Additionally, and on a voluntary basis, private platforms may be used for purposes that provide added value to the mere exchange of invoices in a standard format.
  • A future convergence of tax information systems and invoice exchange is much simpler in the proposed model than in any other that could be proposed.
• Disadvantages:
  • The Tax Agency must assume the cost of implementing the system, although this cost is controlled as it is based on available infrastructure.
  • The information regarding invoice payments will be incomplete, as only total payments will be recorded. Furthermore, the provision of such information will only be mandatory for certain companies. However, once the system has been implemented, if necessary, it is feasible to establish greater information obligations for issuers and recipients of invoices.
  • Business owners and professionals must submit two pieces of information to the Tax Agency: SII log books (or automatic transmission of Veri*factu records) and invoice content. This double obligation responds to the different nature of the information that must be communicated to the tax authorities and to clients, and even to the different treatments that both processes may require. However, this is an automatable technical process and the independence between both systems is necessary to be able to implement the system in a short period of time. Likewise, any other model that may be proposed for electronic invoicing, such as one based on private invoicing platforms, faces the same problem and, in addition, if the tax and invoicing information are sent to different systems, it would be much more complicated in the future to seek a possible convergence of the two.

The representatives of the Federations and Associations present at the session then raised the following questions:

• Regarding the form that the Tax Agency is going to offer on its electronic site for the preparation of simple invoices, it is asked whether, once completed, it could be sent, to which the Director of the Tax Information Technology Department responds that, once it has been completed, it is not necessary to send it, since it is prepared on the electronic site itself, where the invoice would be available to its recipient in a format that would allow it to be integrated into its accounting. In addition, the invoice issuer may choose to send it to the recipient through other channels (private platform, email, etc.).
• The question is whether electronic invoices will be linked to the registration books, to which the representatives of the Tax Agency reply that at first this will not be possible, mainly due to the planned implementation deadlines. Furthermore, it is noted that in order to prepare the registration books with the content of the electronic invoices, these should be subject to a series of validations that would introduce a certain complexity in a document that contains a part of non-fiscal information and of a commercial nature. However, the fact that all B2B invoices are in a repository at the electronic headquarters of the Tax Agency will facilitate the convergence of the tax information supply and electronic invoicing systems in the medium term, contributing to the implementation of a model that allows progress in the automation of all these tasks, thus simplifying compliance with legal obligations for companies and professionals.
• Regarding the use of private platforms, it is pointed out that sensitive data on commercial activity would indeed be transferred and that, in addition, this would have a cost. For their part, the representatives of the Tax Agency, supporting their interventions with a power point presentation, indicate that the use of these would be voluntary, since there is the possibility that there are companies or professionals who, for different reasons, prefer their use. In this case, it would be the platform itself that would be responsible for fulfilling the obligations of sending information to the Tax Agency.
• It is stated that the fact that all invoices are deposited at the headquarters of the Tax Agency would facilitate the activity of tax professionals who deal with accounting, since they would not have to wait for their clients to send them.
• The case of invoices B2C is raised, to which those responsible for the Tax Agency point out that, although the sending of said invoices will not be mandatory, however, to avoid possible errors in the qualification of the recipient (consumer or company and professional) it is advisable that, voluntarily, the invoices issued to the final consumer clients are also sent.
• The question is about the “Ticket Bai” that is being implemented in the Basque Country. Representatives of the Tax Agency respond that it is already in force in Gipuzkoa and that it is more similar to the Veri*factu systems than to those for sending invoices, since only certain information is sent and not the complete content of the invoices.
• Regarding customer identification systems to consult their invoices in the electronic office, the Director of the Tax Information Technology Department indicates that in the case of natural persons they may use the electronic certificate or DNI and the Cl@ve system.
• The entities present at the meeting point out that, in relation to these new information obligations, they hope that the possibility of having a tool with which they can prepare their invoices and that these are sent directly to the Tax Agency will be implemented, without the need to have a private platform that entails new costs and that involves the transfer to a third party of data that could be considered sensitive regarding the company's own activity.

To conclude this point on the agenda, the Director of the Tax Information Technology Department points out that after the meeting, a document will be sent to the members of the Forum explaining in greater detail what was presented at the meeting. The Commission also encourages those present to participate in the public consultation and submit their proposals and observations, since the opinion of SMEs and self-employed workers in this draft legislation is of considerable importance.

Since there were no further interventions, the Director of the Planning and Institutional Relations Service gave way to the next point on the agenda and gave the floor to Ms. Virginia Muñoz Fernández, Director of the Collection Department.

7. New Auction Portal AEAT

Ms. Virginia Muñoz, who used a power point presentation in her presentation, reports that on November 24, the Tax Agency had launched the “Project for the commercialization of assets at auction”, consisting of a new information and assistance system in matters of alienation focused not on debtors with the Public Treasury affected by an alienation procedure, but on all those persons interested in participating in said procedure. He added that the purpose of the new feature is to promote the sale of seized movable and immovable property through electronic auctions held by the Tax Agency. The Director of the Tax Collection Department thus indicates that she will briefly highlight the following aspects of the new system:

• Internally, the National Disposal Team and the National Auction Board were created, which has made it possible to provide the service and make decisions at a national level, standardizing the disposal procedures. Likewise, the management and purification of the stock It is unique for the entire national territory, having implemented a computer function ("asset selection map") that allows the classification of an asset according to an algorithm that determines its alienation capacity (based on the type of asset, alienable right, percentage of ownership, value, charges, etc.) and that, in addition, geopositions the real estate in google maps .
• A specific telephone service has been launched to provide the general public, and not just specialists in the field, with personalized attention, providing them with the information they need and guiding them throughout the entire process, with the aim of increasing participation and the amount of the awards. The average duration of calls answered is between 15 and 20 minutes, which may give an idea that the information provided is very complete (legal, technical, procedural, etc.). In addition, the new service has an “outgoing call” system. On the other hand, it also has an internal audit system to ensure compliance with rigorous quality standards.
• The new functionality, whether on the Tax Agency's electronic headquarters or in the APP, is visually attractive, accessible and easy to use, so it is expected to encourage participation. Its appearance is similar to other platforms on the market.
• At the moment, it is aimed at the sale of real estate, although its extension to movable property is planned during 2023.
• The auctioned properties include detailed descriptions, photos and all the information considered useful for the public, as well as a link to the property's cadastral information. It also includes a link to the Auction Portal BOE , where you can consult the auctions that are active and participate in them.
• The assets can be viewed in “List” or “Map” format and, in any case, there is a system of filters and search engines that is complemented by a catalogue of frequently asked questions in order to facilitate management for people who wish to participate. In addition, interested parties can save their search criteria and subscribe to a “notifications” service that will allow them, after electronic identification, to receive a SMS or an email when there are new assets that meet those criteria.

8. Next call: dates and subjects to deal with

Mr. Ignacio Fraisero comments that, as agreed with the amendments to the Forum's Operating Rules approved in point 3 of the agenda, the next plenary session is scheduled to take place in March 2024 and will be held jointly with the plenary session of the Small and Medium-sized Enterprises Forum. However, the Director of the Planning and Institutional Relations Service adds that the date is indicative and, of course, it would be possible to modify it depending on the evolution of the activity of the working groups.

9. Other considerations, requests and questions

The Director of the Planning and Institutional Relations Service offers the floor to those present in case they wish to make any comments, observations, etc.

First of all, Ms. Celia Ferrero took the floor to point out that the Administration must carry out a dissemination campaign on the regulatory changes planned regarding electronic invoicing and how important it is for self-employed workers to have an electronic certificate when carrying out administrative procedures. Thus, he comments that during the pandemic it became clear that a significant percentage of the group he represents did not have an electronic certificate and that, although the number of self-employed workers who have one has been increasing since then, ATA considers that this issue must continue to be insisted upon. In this regard, it is suggested that it would be advisable to facilitate the procedures for obtaining it and, in addition, to have a specific support service. Finally, he stresses that having an electronic certificate can also mean a reduction in indirect costs, since one could not depend on a social partner.

Next, Mr. César García Arnal takes the floor and states that he agrees with the comments made by the representative of ATA , but wishes to insist that, in addition, the procedures for obtaining the electronic certificate, as well as its use, should be facilitated. He adds that there are certifying companies that, upon payment, provide it to you without having to travel, keep it in the “cloud”, notify you when it needs to be renewed, etc. He therefore points out that it would be advisable for the Administration to simplify everything related to electronic certificates.

Representatives of the Tax Agency have indicated that they have taken note of the issue raised and have requested that entities submit to the Administration any proposals they consider appropriate.

Then, since there were no further requests for the floor, Mr. Ignacio Fraisero thanked all those present for their attendance and closed the third plenary session of the Forum of Federations and Associations of Self-Employed Workers.