Minutes of the meeting

Large Companies Forum

MINUTES OF THE PLENARY SESSION 2/2023

President of the Forum of Large Companies

President of the State Agency for Tax Administration - Secretary of State for Finance

Mr. Jesus Gascon Catalan

Vice President of the Forum of Large Companies

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 Department of Financial and Tax Inspection

Mr. Javier Hurtado Puerta

Director of the Collection Department

Mrs. Virginia Muñoz Fernández

Director of the Department of Aduanas and Excise Duties

Ms. Mª Pilar Jurado Borrego

Central Delegate of Large Taxpayers

Mr. Manuel Trillo Alvarez

Deputy Central Delegate

Mr. Joan Cano Garcia

Head of Procedural Support Area - Department of Financial and Tax Inspection

Mr. Marcos Alvarez Suso

Members representing Large Companies

ACS

Tax Advice Director

Mr. Alfonso Moreno Garcia

AMADEUS IT GROUP SA

Secretary to the Board of Directors

Mr. Jacinto Esclapés Diaz

SABADELL BANK

Deputy Director General Tax and Labor Advisory

Mr. Carlos Augusto Lazaro Rico

BANCO SANTANDER

Global Head of Taxes

Mrs. Carmen Alonso Peña

BBVA

Tax Discipline Leader

Mr. Manuel Diaz Corral

LA CAIXA

Director of Direct Taxation

Mr. Gonzalo Mendizábal Carredano

CEPSA

Fiscal Director

Mr. Alberto Martin Moreno

COFARES

Advisory Board of Directors

Mr. Luis Valdeolmos Gonzalez

EL CORTE INGLÉS

Director of the Tax Department

Mr. Luis Maria Sanchez Gonzalez

ENDESA

Head of Tax Affairs

Mrs. Maria Muñoz Viejo

FCC

Director of the Tax Department

Mr. Daniel Gómez-Olano González

GENERALI ESPAÑA

Director of Accounting Area

Mr. Martí Jo Ruiz

IBERDROLA

Global Director of Tax

Mrs. Begoña Garcia-Rozado Gonzalez

IBERIA

Spanish Tax Lead

Mrs. Cristina Santana Negrin

INDITEX

Director of Tax Advisory

Mr. Andres Sanchez Iglesias

MAPFRE

Tax Advice Director

Mr. Antonio Lafuente Gonzalez de Suso

MERCADONA

Fiscal Director

Mr. Rafael Hilario Lopez Villanueva

MICHELIN

Fiscal Manager

Mrs. Rosa María Peña García

RENAULT ESPAÑA

Director of Tax and Customs Affairs

Jesus Perez Esquide

Tax specialist

Ms. Alejandra Force Jara

REPSOL

Director General of Economic and Fiscal Affairs

Mr. Luis Lopez-Tello and Diaz Aguado

SEAT

Director of Taxes and Customs

Mrs. Susana Sanchez Arenas

SIEMENS

Director of Taxes

Mrs. Ana María Moreda Galante

TELEFÓNICA

Fiscal Director

Mr. Angel Martin Gomez

VODAFONE

Tax Consulting

Ms. Gema de Frutos Rodríguez

Technical Secretariat of the Large Companies Forum

Technical secretary

Ignacio Fraisero Aranguren

The twenty-seventh plenary session of the Large Business Forum will be held on November 27, 2023, 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 June 8, 2023.
3. Summary of the second semester working groups.
4. Spanish Presidency of the European Union: projects in progress.
5. Next call.
6. Other considerations, requests and questions.

1. Session opening

The Secretary of State for Finance welcomes those attending the plenary session of the Forum of Large Companies, firstly thanking them for their contributions for the report to be prepared on the progress and results of the measures of the law on the prevention of tax fraud, a commitment made with the European Commission.

Mr. Jesús Gascón alludes to the fact that the start of the legislature will allow the regulatory situation to be unblocked, giving as examples the Royal Decree approving the Regulations for the development of the law on the prevention of fraud in relation to the use of dual-use software , the promotion of rectifications of self-assessments with a double rectification system, or the draft law on the transposition of the Pillar 2 Directive, among others.

The Secretary of State also points out that, in parallel, the processing of the 2024 budget has begun, which cannot be approved before December 1, so the Secretary of State anticipates that there will be a budget extension.

As regards the evolution of revenue, he indicates that this year has been quite positive, although without reaching the growth rates of 2022 and 2021, since it would be almost impossible for revenue to grow for 3 consecutive years by around 15%. He also points out that tax collection is growing by around 4% this year and is expected to reach 6%. He also said that, as regards tax bases, the forecast is that they will grow at the same rate as consumption, although income is growing less than nominal GDP.

On the other hand, Mr. Jesús Gascón acknowledges the excellent work that has been carried out from a technical point of view by the teams of both the General Directorate of Taxes and the Tax Agency, promoting extremely complex files in some cases.

As regards Europe, he said the aim was to achieve greater harmonisation and uniformity of regulations, and that support for Ukraine was currently one of the most important issues. At the international level, the discussion focuses on the role of the United Nations in relation to the OECD, especially in the design of the architecture of international taxation, where the difficulties that exist in reaching an agreement on Pillar 1 and the creation of a global framework on international taxation.

Regarding the management area, the Secretary of State for Finance points out that in the centres that depend on the Secretary of State for Finance, strategic plans are being prepared for the following period, the one relating to 2024-2027, with the aim of giving predictability to the actions carried out.

2. Approval of the minutes of the meeting held on June 8, 2023

Mr. Ignacio Fraisero thanks those present and stresses that, once the draft minutes of the meeting of June 8, 2023 were submitted, no comments were received.

There were no observations or suggestions for modifications to the content of the minutes during the session, and the minutes are approved.

3. Summary of the second semester working groups

The Secretary of State gives the floor to the Director of the Department of Tax Management, who begins the presentation of what was discussed in the working group for the Analysis and Rationalization of Indirect Tax Burdens, which was held on November 6, and where the various modifications that had been addressed in the approved ministerial orders were presented. Among them, the one related to the model of pension plans and funds, virtual currencies, regulatory changes related to withholdings, emerging companies and the Artist's Statute, the modification of model 390, as well as the modification planned for models 189 and 720 were discussed.

It was also reported that the draft order approving form 281, on acquired goods that do not physically pass through the Canary Islands, was being processed; Model 379, which introduces some international obligations relating to the control of electronic commerce (CESOP), Model 238, which includes the information declaration by platform operators (DAC7); and finally, reference was made to form 604, in relation to the tax on financial transactions that must be self-assessed not only at the Tax Agency, but also at the regional treasury according to the registered office of the entity to which the shares being acquired belong.

Another topic that was explained and that generated controversy was the breakdown of the tax withholdings in the area of the groups that have a presence in the Basque Country, since from the modification of the economic concept and with a resolution of the arbitration board, it is necessary that the withholdings be made in accordance with the percentage of taxation of the group.

The purpose of these changes to the information declarations, says Ms. Rosa Prieto, is to have this information more broken down to avoid requests, so that the data held by the different administrations is more accurate and the tax data for filing income tax returns is also more precise.

The Director of Management indicates that, in the section of requests and questions of the working group, the increase in tax burdens that the breakdown and verification of withholdings entailed was discussed, to which it was answered that this increase in tax burdens was something necessary and convenient in order to provide more appropriate tax data to taxpayers, being also a rule that is imposed and that exceeds the Tax Agency, due to the existence of the regional regime.

Finally, the working group asked whether it would be possible to communicate the IS refunds to the regional treasuries and for them, in turn, to inform the Tax Agency. The answer was that this was a topic that would have to be analyzed, and that information would surely be provided in the next working groups as to whether it was possible.

Next, Mr. Jesús Gascón gives the floor to Mr. Javier Hurtado, who summarises the meeting that took place on 16 October, within the framework of the working group on the Analysis of tax regulations and conflict reduction, which was attended by the Deputy Director General of Taxes on Legal Entities of the General Directorate of Taxes, Natalia Jaquotot, who addressed the transposition of pillar 2, pointing out that, due to the political situation, it had not yet been possible to initiate the public information procedure.

The Deputy Director also answered questions from the attendees during the working group and clarified that it was a transposition that would be subject to the wording of the directive. The Director of the Inspection Department adds that the transposition of Pillar 2 is proving to be quite complex, as the directive itself is complex, not only because of its technical content, but also because of certain terminological aspects.

The second issue that was discussed was the publication by the Tax Agency of a note, on July 28, in relation to the VAT taxation of mixed-use vehicles transferred to employees. The purpose of this note is to provide legal certainty by clarifying certain tax legal situations, and was the result of the coordinated work of different departments of the Tax Agency, not only the Inspection Department.

On the other hand, it was commented that in order to put the note into context, it was necessary to take into account the appearance of certain resolutions of the Central Economic Administrative Court and the Court of Justice of the European Union, which addressed the issue of the burdensomeness of the contribution by the car company to its employees.

It was indicated that the note did not end the iuris tantum presumption of 50% deductibility of VAT that is in article 95.2 of the law, given that the context in which the note is produced is very different.

As for the content of the note, it was explained that it was divided into 5 sections. The first is based on the hypothesis of affectation. Nowadays, cars have to be affected by economic activity. Once they are affected, in the event that part of them is for private use, the percentage of deductibility will depend on the degree of availability of the vehicle.

Secondly, the note addresses the issue of burdensomeness. Until now, it was considered that onerousness was implicit in the worker's remuneration, so that, if a worker received a car as part of his remuneration, the delivery was onerous. However, the case law of the Court of Justice of the European Union had led to a reconsideration of the position, in the sense that, unless there is an express agreement that alters the monetary remuneration of the professional or the worker as a consequence of the delivery of the car, or the worker chooses it among several possibilities, the availability of the car does not imply the existence of onerous delivery.

The third topic addressed in the note is that of deductibility. Fourthly, the possibility of considering the existence of self-consumption is discussed, and, finally, a fifth section is included that has given rise to some controversy, which determines what the VAT tax base is and relates it to the payment on account in personal income tax.

In the working group, the company representatives commented that it was an extremely complex system and that it would be interesting to objectify these amounts, replying that it is indeed complicated to evaluate the availability of each of the cars, but the opposite could go against the general justice of the system.

Some representatives in the working group mentioned that they had signed prior agreements to value remuneration in kind at 50%, considering that the car was 50% for business use and 50% for private use, with the administration pointing out that these agreements were made at the time, but that they had not existed for almost 8 or 10 years now.

It was indicated that there was currently a tendency towards the idea of availability, dividing the day into three parts of 8 hours each, taking into account that working hours are 8 hours and the other 16 hours are for private use. Sometimes more than 8 hours, 10 hours, 12 hours were considered, but in no case was a full day considered a business day.

The Secretary of State for Finance then gives the floor to the Director of the Tax Collection Department, who points out that two issues within her field were discussed at the same meeting. The first one is related to the derivations of responsibility for certain seizure proceedings that fall on pledged assets, where the representation of some entity commented that they were having problems. He was informed that the modus operandi had to be as follows: The bank had to file the seizure order and present the third party claim of better right as soon as possible; This amount would be recorded and this third party claim would be resolved as quickly as possible.

The second issue was a problem raised by a financial institution in relation to the filters of the creditor courts. It was explained that the Agency receives seizure orders from the courts and that these are complied with in their strict terms. In this particular case, the court seizure orders came with a comma shift, a typographical problem, and the Agency executed it as is, without reviewing it due to lack of jurisdiction to do so. In this case, the financial institution had a refund request and, having a debt and a compensation, acted accordingly.

The Director apologizes for the problem caused, but points out that there is nothing to do but execute orders. He also said that the possibility of introducing some kind of control filter will be studied and that the Planning and Institutional Relations Service will be asked to contact the courts so that they can take special care with the sending of these embargoes.

Mr. Jesús Gascón thanks Ms. Virginia Muñoz for her intervention and gives the floor to the Director of the Customs Department to address the issues discussed in the working group on Excise Taxes. Ms. Pilar Jurado points out that the tax on plastic packaging was discussed again, and the experiences that had been had during the year were brought to light. One company commented on the problem of the final determination of tertiary plastic and that sometimes there was no reliable information from suppliers, adding more complexity to management. It was pointed out that the difficulty was not only determining the amount of plastic, but also how much was recycled and how much was not.

It was concluded at the working group meeting that it would be desirable to have an objective estimate, a suggestion that was rejected at the time by the General Directorate of Taxes due to the regulatory impossibility of making any changes at that time. It was also indicated that, as of 2024, certification and the UNE standard that would determine the plastic recycling protocol would be applied, with this certification by the certifying company being an objective element of proof.

Ms. Pilar Jurado then points out that the other issue raised was the registration in the registers of extractors of fiscal warehouses of hydrocarbons and alcohol and derived beverages. The modification introduced by the fraud law meant that the owner of the fiscal warehouse has a subsidiary responsibility for the VAT not paid by the companies that remove the product and do not pay the VAT, generating the VAT assimilated at that time by the previous delivery. It was also stated that the owners of tax warehouses were excluded from this liability if the owner of the product had registered with the REDEF, which is a register of extractors of certain products.

On this issue, Mr. Javier Hurtado points out that hydrocarbon fraud is a major problem for the Tax Agency due to the tax losses it generates. He points out that the modification of the VAT law that establishes the creation of REDEF had a very long process, and has recently come into force, so it is premature to make a joint evaluation of what is happening. However, the Director of Inspection notes that it is working as intended; without prejudice to the fact that criminals in this area always look for loopholes to bypass the prevention systems that have been imposed. He said that the outlook so far is positive, but it is too early to make a joint assessment. Mr. Javier Hurtado invites those present to submit proposals for modification or regulatory progress and stresses that the obligation affects the holders of tax warehouses that allow the extraction of products by unregistered subjects.

The Director of Inspection indicates that the REDEF is a trust registry, therefore, all those who handle petroleum products on a wholesale basis must be registered in that registry. If there is someone who is not registered in that registry makes an extraction to put a product on the market, without paying VAT, the holder of the deposit has a subsidiary responsibility. This liability would not exist if the extraction were from deposit to deposit, since the regime is a suspensive regime. Furthermore, if you have a product in your possession within a bonded warehouse and for whatever reason you are not on the extractors' register, there are two possibilities: register or sell the product within the warehouse to someone who is registered in the extractors' registry.

Following this intervention, Ms. Pilar Jurado commented that the working group discussed the carbon border adjustment mechanism, a mechanism that adds to certain imported products from certain sectors related to the production of electricity, cement, construction, steel, etc. an amount that must be paid to match what is already paid within the European Union, through the emissions market. The Customs Director points out that this mechanism is intended to compensate when products come from abroad.

It was reported in the working group that the transitional period came into effect on 1 October and that during this period operators have to register and also enter into a global register of the European Union, in such a way that it is possible to extract information on all import operations that are transmitted to the European Union, so that later, when the definitive period comes into effect, certificates can begin to be validated, certificates that must be purchased by importing companies.

Likewise, Ms. Pilar Jurado comments on the existence of a new ministerial order that changes the routes and markers that have to be applied for hydrocarbon tax benefits, which would be published shortly in the Bulletin, coming into force on January 19, 2024.

Finally, the working group discussed an issue that has caused some conflict, perhaps due to some administrative action following a ruling by the Court of Justice of the European Union regarding the classification of certain hydrocarbon-derived products. Representatives of entities in this field indicated that a problem was generated, since the records had to be adapted, and it was necessary to know how the procedure should be carried out, and above all how to make the prior determination of the product. For all these reasons, it was agreed that the matter would be discussed with the responsible Sub-directorate, which would follow up to see what could be improved.

Thanking him for his intervention, the Secretary of State for Finance gives the floor to Mr. Manuel Trillo to comment on the matters discussed in the cooperative relations working group on November 15. Specifically, the Central Delegate for Large Taxpayers indicates that two issues and one announcement were addressed. Firstly, the working group presented a first summary of the survey on cooperative relations carried out, which will be discussed in more depth below by Mr. Joan Cano. The second issue was the modification of the system for correcting self-assessments. In relation to this, Mr. Manuel Trillo points out that there were situations in which the taxpayer's only intention, by using the self-assessment rectification procedure, was to obtain an administrative act with which to go to the economic administrative court and to the contentious jurisdiction. For cases in which there may be a violation of a higher standard by: the rule in question, or a possible conflict of constitutionality, the violation of community rules, international treaties or conventions, the new model of the self-assessment rectification system would be meaningless.

At the same time, the change of headquarters of the Central Delegation of Large Taxpayers was announced, after more than 50 years on Paseo de la Castellana.

Regarding the first point, Mr. Joan Cano points out that the results of the survey on the cooperative relationship model were analysed, and it can be concluded that the model has received a positive evaluation and that there is a collective interest in continuing with the model.

Secondly, the need to improve communication channels at all levels was discussed, not only at the higher level, in the plenary and in the working groups, but also at the level of daily management, encouraging the use of existing means to reduce litigation and conflict. Finally, it was agreed that mechanisms were needed to provide entities and groups that wish to participate in the cooperative compliance model with the opportunity to do so.

The Deputy Central Delegate indicated that the need was also raised to positively discriminate those members of the cooperative relationship or cooperative compliance model who made a special effort and who fulfilled their obligations especially well, and who, therefore, could be entitled to some simplification of their compliance obligations, allowing further study of the transparency reporting model.

The entities communicated the need to increase the training and knowledge of all Tax Administration officials on the cooperative compliance model, as well as the possibility of improving some institutional instruments of the model, such as, for example, the convenience of inviting members of the General Directorate of Taxes to discuss certain issues.

Mr. Joan Cano adds that specific proposals are being formulated regarding the renewal of the actors in the cooperative compliance model, the search for elements of positive discrimination, and the possibilities of progress regarding the transparency report. The agency also said that work is being done to improve the training of the Agency's staff and to verify whether the measures to be adopted meet the objectives that have been set.

Mr. Manuel Trillo indicates that the cooperative relationship in the abstract is very good, but that it is necessary to specify it, since not all participants in the cooperative relationship mechanisms are equal, nor do they behave the same; Therefore, the best way to put all this into value is for those who comply the most to notice it a little more, increasing the effort so that the cooperative relationship is present in the verification procedure in every sense, allowing for a value judgment at the end about compliance with the basic precepts of the code of good practices.

The Secretary of State for Finance having had to leave, the Director of the Tax Agency points out that, as there are no observations on the issues raised, this point is considered concluded, moving on to the next point on the agenda.

4. Spanish Presidency of the European Union: projects in process

Ms. Soledad Fernández gives the floor to Mr. Marcos Álvarez to develop the projects in process within the framework of the Spanish Presidency of the European Union.

Mr. Marcos Álvarez begins his presentation by pointing out that these are provisional ideas: They are draft regulations and may change as a result of deliberations in the Council. He points out that this is about future taxation, not current taxation, and stresses that most of the projects have a foreseeable date of entry into force in three, four or five years, assuming that a unanimous agreement on taxation is reached in the Council.

Without prejudice to the fact that there are other issues that are being worked on, such as data protection, transfer of information to third jurisdictions in relation to CRS or Facta, a code of conduct, or the list of tax havens at European level, he says that he will refer to the most notable projects.

In terms of direct taxation, the Unshell Entities project stands out, which consists of exchanging information on certain entities that lack economic substance, and consequently no real economic activity. This exchange of information indicates that tax benefits under the directives or even those established in bilateral double taxation agreements could be denied. Thus, if an entity lacks a minimum substance, the consequence would be to be deprived of these tax benefits. Mr. Marcos Álvarez says that this project is going slowly: It is a directive whose proposal was made public in December 2021, and has been under discussion in the Council at working group level for almost two years, without reaching agreements being easy, because not all Member States have the same concern about non-transparent entities. He notes that the European Commission itself will launch a new proposal this month that would offer much greater flexibility to Member States in considering what minimum substance requirements are required at national level in order for an entity to be considered Unshell , as well as in establishing the consequences arising from an entity being considered Unshell .

He continued his presentation with the second project on direct taxation, called Faster and which affects the taxation of non-residents. The project aims to harmonise common European rules on the issuance of tax residence certificates, including the criteria under which a person may be certified as resident in a Member State, the content of such a certificate and the duration of validity of such a certificate. He adds that the first part of this Faster project is well advanced. The second part of the project would involve establishing a more agile system that is more resistant to possible fraud in the management of income tax refunds, in our non-resident income tax and the equivalent or correlative ones in other European jurisdictions. What is established in this proposal for a directive is to create a series of criteria for certified financial intermediaries to be able to request these refunds on behalf of their clients. Once the withholding has been made in the source State, certain certified and reliable financial intermediaries would request the refund, using a more agile and faster procedure than the original one. This would also be complemented by a system for the exchange of information and a standard procedure for accrediting the chain of intermediaries up to the holder of the income.

Mr. Marcos Álvarez points out that this project also has a part that affects other Member States, not so much Spain, relief at source (exemption at source) , which would be like releasing the obligation to make withholdings at source, in the state of source, these states being those with small financial markets. He points out that this project Faster will probably see the light of day in the short to medium term.

He goes on to point out that the third direct tax project currently on the Council's table is a directive presented in September 2023, which represents a very important change in the management of corporate tax at the European level, which would allow corporate tax returns to be expedited for groups. This project is called Befit ( Business in Europe framework for income taxation ) and has three different aspects: The first is the pure Befit itself, a kind of harmonization of corporate tax at European level for large groups whose turnover exceeds 750,000,000 euros at European transnational level. Based on the accounting results of each of the group's entities, a certain harmonization of the extra-accounting adjustments is carried out to arrive at a harmonized and aggregated tax base at a European level, producing a distribution by jurisdictions of this tax base to be aggregated. Without prejudice to the submission of self-assessments at the national level, in the jurisdiction where the European parent company of the group is located, a kind of macro corporate tax return would be submitted, aggregating all the results, and this would be exchanged with the rest of the affected states. There is even provision for an a priori intervention by what they call a Befit team, a team of inspectors from all the affected Member States, who try a priori, not a posteriori, to reach an agreement on the correct distribution of this aggregate tax base between the jurisdictions.

The second part of this project Befit , is to establish basic harmonized rules at the level of transfer pricing. A third part, which would affect small companies and is in a very recent phase, would allow the application of the corporate tax legislation of the jurisdiction where it was established to everything, including the tax base of permanent establishments in other jurisdictions, and then this determined base is again distributed according to the rules of the country of residence.

As regards other projects that were under consideration, the Commission has already confirmed that they will be left to the next European Commission, which will be elected next year.

Regarding VAT, he comments that there is only one project, but that it also includes three different aspects. It is called VIDA, vat in the digital age , it was presented by the European Commission in December 2022. The first aspect is to expand the assumption of the current single window, and may above all affect entities or groups that are very active in the trade of goods, for example, the operation known as transfer of goods in VAT (moving goods from one Member State to a warehouse in another Member State, even if it is not sold, a taxable event that requires registration as a businessman in the country where the goods have been moved without having sold them), it is intended to be replaced by a purely computerized declaration, a kind single window. This would make the of tax on business to business transactions between entrepreneurs mandatory, when the supplier is not established, etc.

The second point of this project is of particular interest to companies or groups that are very active in the tourism sector, essentially digital platforms involved in short-term accommodation services and passenger transport services. This aspect would aim, apart from harmonizing the location of the taxable event in the service of the platform itself, for short-term rentals to always become subject to VAT in Europe, among other aspects.

The third part of the VAT package is the electronic invoice, called digital reporting , a four-year project that aims to harmonize what an electronic invoice is.

Finally, Mr Marcos Álvarez points out that the intention is to replace our current model of summary declaration of intra-Community operations, 349, with a kind of immediate supply of information at a European level, operation by operation, transaction by transaction, invoice by invoice; and also in real time or almost in real time, no more than two days from when the invoice is issued.

The Director of the Customs and Excise Department then took the floor, highlighting the reform of the customs union and a regulation for the import, export and transit of firearms as key issues in her field. As regards the reform of the Customs Union, he said that there had been an internal debate within the Commission and with the Member States for two or three years now, given that the Customs Union needed to be improved, particularly with regard to e-commerce and internet transactions. Ms. Pilar Jurado points out that the pillars of the reform are: Firstly, a new vision of operators, with the word importer and exporter, and the passive subject, no longer appearing. On the contrary, the current regulations speak of a declarant, so a company that imports will communicate to a computer system that it has a commercial operation, that it will bring merchandise from a place with certain characteristics, making the commercial operation evident. In practice, there will be a single EU IT system, the data-hub , into which all those who have information related to the customs operation will upload information.

The other element related to the economic operator is the Trust and Check , the evolution of the authorized economic operator. It is noted that the operator who is Trust and Check will be so because he has passed this audit, so he will not even have to wait for the customs authority to tell him that he can now take the merchandise, but rather, by entering information into the system, his status will allow him to be able to dispose of the merchandise.

The Director of the Customs and Excise Department comments regarding customs controls, that the risk analysis in the European Union is based on the set of data related to the commercial operation, which has been communicated to that data-hub .

Finally, among other measures, it indicates that the creation of a European Customs Agency is proposed, to which information will be provided, and risk management will be carried out on that information.

Thanking Mr. Marcos Álvarez and Ms. Pilar Jurado for their intervention, the General Director concludes this point.

5. Next call

The Director of the Tax Agency announces that the next call for applications will likely be in June.

6. Other considerations, requests and questions

There being no interventions, requests or questions, the Director of the Tax Agency declared the twenty-seventh plenary session of the Large Business Forum closed, wishing all attendees a Merry Christmas and a Happy New Year.