'TADAT' evaluation

• Nine major areas of performance are evaluated, broken down into 28 indicators, of which the AEAT has obtained the highest scores in more than 78%.
• The 'TADAT' method allows an examination of the performance of tax administrations so that they can assess the degree to which they comply with what the IMF considers good international practices in the matter.
• The Agency will develop an action plan based on the evaluation, with proposals for improvement in matters such as streamlining VAT refunds and the resolution time for replacement resources. 

March 22, 2021 .- The Tax Agency has good fiscal risk management and census control, consistently encourages voluntary compliance and achieves adequate presentation and payment of the taxes it manages, in accordance with the Tax Administration Assessment and Diagnostic Tool ('TADAT', for its acronym in English), an examination of the performance of tax administrations that the International Monetary Fund, in collaboration with other international organizations, offers to countries so that they can assess the degree to which they comply with what the IMF considers good international practices on the matter. 

The Tax Agency has undergone the TADAT examination under the self-assessment modality assisted by IMF officials, in the period between September 2019 and November 2020. The AEAT is one of the first European tax administrations to carry out the TADAT evaluation, already used by more than 80 countries and a series of subnational jurisdictions on the five continents to identify the strengths and weaknesses of their administrations, and define possible improvements.

In accordance with the provisions of the 2020-2023 Strategic Plan, the Agency has carried out the TADAT analysis and will now take into consideration the results of the evaluation for the update and development of its strategic planning instruments.

The TADAT tool evaluates nine major areas of performance, broken down, in turn, into 28 indicators, of which in more than 78% the AEAT has obtained the highest scores ('A' or 'B').

Database integrity and risk control

In the section relating to the degree of accuracy and reliability of the information available on taxpayers, and knowledge of the base of potential taxpayers, the TADAT evaluation certifies that the AEAT database has updated information that allows controlling access and the actions carried out. It also highlights that secure access is offered to companies and individuals, and that all people and entities are registered in the census of taxpayers through a single NIF.

Regarding effective risk management, the review highlights the existence of tax compliance risk mitigation programs, continually reviewed from the management level, and also highly values the existing system for risk control in labor and infrastructure matters. , among others.

Promotion of voluntary compliance

The information on taxpayer rights and obligations is adequately segmented and updated, the degree and agility of the information and assistance available to the public is appreciated, and also the existence of civic-tax education programs. Likewise, the report assesses the current tax and accounting simplifications for certain segments of taxpayers, also highlighting the Agency's permanent contact with taxpayers, groups and tax intermediaries to obtain feedback on the services provided.

Presentation, payment and control of taxes

In the TADAT evaluation for the Tax Agency, the degree of punctuality – submission on time – in the tax return is considered high, which is linked to the efforts made both in the census and tax control sphere, as well as in promoting compliance. volunteer. In addition, it values that all declarations and payments of the main taxes are made electronically.

TADAT also considers the degree of punctuality in payments positive and appreciates the clear improvement in outstanding debt in recent years, highlighting the data on the degree of collection of debt older than one year.

In the section on accuracy of the declared information, the scope of the measures taken to detect and dissuade what TADAT calls 'inaccurate declarations' is positively valued, and the existence of the system of tax consultations and binding resolutions for the Agency, such as the creation of cooperative compliance forums.

In terms of effective dispute resolution, the dispute resolution process is seen as very positive, highlighting its staggering, the information on the right to appeal that is offered to the taxpayer and the analysis and monitoring that the Agency carries out on the results of the disputes. controversies for the purposes of modifying procedures and possible proposals for regulatory changes.

Efficient administration and accountability

On the other hand, the TADAT evaluation appreciates the contribution of the tax administration to the budget process with forecasts and monitoring of collection. It also values that the accounting system is fully automated and subject to internal and external audits. At the same time, it considers the design and verification of the VAT refund system to be appropriate, as well as the differentiated treatment offered to taxpayers included in the Immediate Supply of Information (SII) and the Monthly Refund Regime.

Regarding the scope of accountability, the evaluation determines that the Tax Agency has solid internal audit and information security instruments. It also values the existence of external supervision bodies and emphasizes that the Agency takes into consideration surveys that measure public confidence in the Tax Administration. Likewise, the management by objectives model is highlighted based on strategic planning instruments, the periodic accountability of the Director General to Parliament and the annual publications of control guidelines, results and the Agency's report.

Action plan

There are other indicators of the TADAT methodology that lead the AEAT, depending on each case, to establish an action plan with improvement measures, or to maintain the suitability of its actions if it considers that the current situation represents a benefit for the taxpayer.

Regarding the action plan, the TADAT model warns about the resolution times for replacement appeals, although it recognizes the dismissal effect that occurs within a month if there is no express resolution. In any case, in the action plan, the Agency incorporates monitoring of resolution deadlines with TADAT methodology to reduce these times.

In terms of VAT refunds, and based on the TADAT diagnosis, the Agency commits in the action plan to accelerate checks and risk studies, and with it also refunds, while underlining the effort already made in recent years. years to expedite returns to SII taxpayers.

Regarding the debt pending collection, the action plan indicates that action will continue along the lines set by the 2020-2023 Strategic Plan on the causes that produce litigation and on the average resolution times, without prejudice to continuing with improvements in the collection procedures to expedite collection.

In relation to the degree of accuracy of the information declared by taxpayers, the Agency highlights in the action plan its commitment to measuring voluntary compliance based on the comparison of related fiscal and economic magnitudes, but also points out that it has supported the recent decision by European tax administrations to extend current studies on the VAT tax gap to other taxes.

Within the analysis of the suitability of the income accounting system, the TADAT methodology requires an immediate accounting imputation, while the Spanish system historically accounts for fortnights. This entry is made into restricted accounts that are unavailable, but, in any case, the action plan indicates that it will evaluate the procedure again.

In the field of training, the TADAT evaluation calls for specific tax training programs for entrepreneurs, a line in which the Tax Agency undertakes to analyze with the Institute of Fiscal Studies the preparation of training material and possible virtual courses for taxpayers who are starting out. an economic activity. The action plan also highlights other initiatives that the Agency is already developing in the context of the OECD's 'Right from the start' strategy to improve the services provided to these taxpayers, in the case of census assistants.

Maintenance of measures for the benefit of the taxpayer

On the other hand, there are other matters identified by the TADAT evaluation that the Agency considers appropriate not to review as the current situation offers greater benefit to the taxpayer. An example of this is the lower rating given in the exam due to the fact that the amount of payments made on time does not reach 90%. This ratio is conditioned by the existence of the unsecured deferral system for debts of up to 30,000 euros, an important liquidity instrument for numerous individuals and SMEs that is considered advisable to preserve.

This is also the case of the different declaration period for companies with a split fiscal year (not coinciding with the calendar year). If they had the same filing period as the rest of the companies, these entities would have compliance problems, given that the accounting – the Spanish corporate tax is an accounting-based tax – can only be closed when the year ends and, therefore, the year accounting and tax must coincide.