Article 116 of the General Tax Law establishes the obligation to draw up an annual tax control plan, which will be reserved without prejudice to the advertising of the general criteria that inform it. For its part, Article 170 of the General Rules of Procedure and the procedures for the management and inspection of taxes and for the development of common rules on procedures for the application of taxes provides that the control plan Tax shall be integrated by the plan or by the partial inspection plans, which shall have a reserved character and shall not be the subject of publicity or communication.

Moreover, Law 22/2009 of 18 December, regulating the system of financing of the Autonomous Communities of the common regime and cities with the Statute of Autonomy and amending certain tax rules, provides for the coordinated planning of the actions carried out by the various administrations on the taxes transferred.

The State Tax Administration Agency, hereinafter the Tax Agency, develops its actions through a General Plan of Tax Control, a fundamental instrument for planning the control actions. tax and customs of an organisation such as the Tax Office which works with specific objectives for each financial year. The General Plan is structured in the following sections:

(a) General Guidelines, in which the main areas of fiscal risk that require priority attention and the basic criteria for the development of the Plan are set out.

b) The Control Plans for each of the areas that carry out control tasks: Financial and Tax Inspection, Customs and Excise, Tax Management and Collection. The Parcial Plans define the criteria that govern the programming of actions of each area and its distribution between the different units and territorial areas.

(c) Rules for the integration of partial plans, including the provision of joint, successive or coordinated actions and how many are required to give unity to the control action of the tax office. The priority actions to be developed in collaboration with the autonomous tax administrations in the framework of the control of the taxes are also planned.

The challenges facing the Tax Agency for 2011 are framed in an economic and social context in which the economic crisis affecting the global economy and the Spanish economy, the phenomenon of globalization, is highlighted. The internationalisation of the Spanish economy and the rapid deployment of new technologies.

In our country, the fiscal consolidation policy, which is one of the pillars on which the measures for economic recovery, the fulfillment of the objectives, are based, is particularly relevant in this context. the reduction of the public deficit and the correction of the deterioration of public finances.

In order to meet these challenges, the tax administrations need approaches adapted to the current, open and strongly internationalized societies and this need pushes for the search for more effective formulas for the development of the role of legalizing the resources necessary for the maintenance of public expenditure, with the greatest efficiency, justice and simplicity, for which prevention and the fight against fraud are at the strategic line basic and priority of the tax office.

According to these challenges and context, the 2011 General Tax Control Plan contains the planning of preventive or ex-ante control and control actions in the strict sense, be it verification actions and General or specific research, in the strategic framework of the Fiscal Fraud Prevention Plan of 2005, updated in 2008, and the Comprehensive Plan for the Prevention and Correction of Fiscal, Labor and Security Fraud Social of 2010.

The main areas of risk and the basic criteria for the development of the General Tax Control Plan are grouped in three broad areas. The first of these are the actions of verification and investigation into tax fraud, among which the reinforcement of the actions on the sectors or activities in which there is a greater perception of the fraud, as it is, is important. the case of professionals or taxpayers with external signs of wealth that do not correspond to the declared income levels.

In the same way, actions aimed at combating the submerged economy will be strengthened, which will be undertaken in a joint and coordinated way with the Labour and Social Security Inspectorate and the General Treasury of Security Social, for which actions of an in-person nature are foreseen.

In this same area, tax engineering and abusive tax planning will be areas of priority attention, as well as the pursuit of trust structures and corporate fabrics created to evade tax payments, or the creation of intragroup financial liabilities generating financial expenses to reduce or eliminate tax bases obtained and to be taxed in Spain.

the strengthening of the exchange of information between administrations and international cooperation, particularly in the field of the OECD, will make it possible to undertake more effectively the fight against tax havens and low taxation, in particular for the detection of assets, deposits and financial products in those territories whose ownership corresponds to citizens resident in Spain. The Tax Agency will make every effort in international forums and also bilaterally so that collaboration between tax administrations improves and results in practical results.

other areas related to international taxation will also be the subject of priority attention, such as the misuse of transfer prices in three main concepts: restructuring business, the valuation of intangibles and the treatment of losses arising from the global economic crisis.

Will continue the control actions of previous years such as those related to VAT fraud schemes in intra-Community operations, taking advantage of the progress made by the new EUROFISC programme and the amendments to the Regulation on mutual assistance promoted by Spain, the checks of tax groups on companies and groups of entities in VAT, those in the real estate sector and others, adjusted to the current importance of these activities and the estimated risks.

In relation to the control of foreign trade and excise duties, special attention will be given to the control of the value in Customs of imported goods, to the actions related to the security of the chain logistics as well as to the control of the application of the exemptions or bonuses, in particular, in the Tax on Hydrocarbons and in the Special Tax on the Determinated Means of Transport.

It should be noted that for the development of the actions described above, the Tax Agency will reinforce the actions aimed at collecting information from different sources of tax importance, among which the from international conventions and agreements for the exchange of information and also the IT tools for the selection of contributors to ensure maximum effectiveness and coordination in the implementation of control actions, taking advantage of the opportunities offered by the new technologies of the information and communications, which allow, inter alia, to implement the system of electronic notifications for a good number of entities.

The second of the major areas in which the Control Plan is articulated focuses on the fight against fraud in the collection phase for which the risk assessment in the inspection phase is consolidated as the criterion for achieving greater efficiency in collecting data.

The programme of coordinated actions is expected to be widespread in order to make it possible to anticipate the actions to be taken at the liquidation stage. The control of debtors with systematic non-compliance with obligations, the actions of specific collection control in relation to the congration processes that will be chaired by the criterion of strengthening the participation of the Tax agency in the different phases of the competition, as well as the actions of control collected in relation to the crimes against the Public Finance.

Finally, the guidelines of the Plan address a third area of actions in which control is included on the taxes transferred, as an expression of the need to carry out coordinated actions with the Tax administrations of the Autonomous Communities responsible for the management of such taxes, which highlights the full consolidation throughout 2011 of the Single Shared Census and the priority nature of the coordinated actions in relationship to the most significant real estate or social operations with an impact on the Temporary taxes.

By virtue of the above, I have:

First. Approval of the general guidelines of the 2011 General Tax Control Plan.-The general guidelines of the 2011 General Tax Control Plan of the State Tax Administration Agency, which are set out in the Annex to the General Tax Control Plan, are approved. Resolution.

Second. Dissemination of the general guidelines of the 2011 General Tax Control Plan.-The publication of these general guidelines is ordered in the "Official State Gazette", as well as its dissemination by any means appropriate to its general knowledge.

Madrid, February 2, 2011. -Director General of the State Tax Administration Agency, Juan Manuel López Carbajo.

ANNEX

2011 General Tax Control Plan Guidelines

The Tax Agency's General Tax Control Plan is articulated around three broad areas:

Checking and investigating tax fraud.

Control of fraud in the collection phase.

Control of fraud in relation to temporary taxes.

I. Tax fraud checking and investigation

The control actions are aimed at checking the statements made by the taxpayers and the investigation aimed at the discovery of undeclared facts or bases, in order to practice the necessary actions. regularisations of the tax situation of taxpayers until the effective recovery of the debts and tax penalties resulting from such regularisations is achieved.

In this regard and in relation to the control by the various areas of the Tax Agency, coordinated methods of selection will be used, which define the risk groups on which each of the areas.

The priority areas of control are set out below in 2011.

1. Control over tax liability with higher tax risk.

(a) Control of professional activities. -They will be expanded and enhanced control actions on income derived from professional activities through the use of new sources of information or external signs of wealth that will allow the discovery of undeclared income, as well as to detect the inclusion of fictitious expenses in the declarations presented by the professionals, through the examination of those items of expenditure that, according to the activity in question appears to be disproportionate or not in line with it.

The actions aimed at ensuring the correct impact of VAT on invoices will also be strengthened, especially when individuals are directly targeted. Control of external signs of wealth

Check-out actions will be carried out on tax obliged to present external signs of relevant wealth that manifest a high economic capacity that does not correspond to the declared income levels. To this end, specific IT tools will be designed, focusing on the heritage analysis and detection of external signs in natural persons, and at the same time, direct research actions will be strengthened with the intervention of the Customs and Excise Operational.

(b) Control of means of payment. -Actions directed towards taxpayers involved in operations using high denomination banknotes in order to detect undeclared income or assets will continue to be Priority focus is given. Investigations shall be extended to cash movements for particularly high amounts and to those who are obliged to tax credit with significant credits in their bank accounts.

In this area, collaboration with the customs services of the countries of origin or destination of the funds will be enhanced, through the exchange of information on the patrimonial situation or the history of the people carrying of the means of payment.

(c) Control of fraud in the subcontracting sector. -Action will be taken to detect false sub-contracting firms which, under the guise of works or service providers for a The main contractor has actually been the sole object of issuing false invoices without responding to real and effective economic activity, invoices which are used by the recipient to obtain tax deductions. (i) Similarly, in this field, action will be taken on sub-contractors which carry out a real economic activity while on the one hand they employ workers without a high level of social security and, on the other hand, they do not submit taxes or present them without entering the due fees.

The information on subcontracting in the Tax Agency, the General Treasury of Social Security and the Labor and Social Security Inspectorate will be shared in order to detect these assumptions of fraud and to schedule the joint or coordinated actions to be carried out by these three bodies.

In particular, precautionary measures will be taken on operators who have ceased their activities in view of the obvious tax risk arising from the difficulty of recovery.

d) Control of non-residents. -It will investigate the legal relationships that non-resident holders of bank accounts may have in Spanish territory with businesses located in Spain, in order to evaluate the possible existence of income obtained in Spain.

e) Control of the tax situation of tax authorities convicted of tax crimes.-The follow-up of the taxpayers who have been the subject of a complaint or conviction for crime against the Public Finance will be carried out of the adoption of the measures.

(f) Control of tax obligations under objective taxation regimes.-The control of issuers of false invoices that are taxed in objective estimation regimes will be a priority area of care, so that the address both the issuers and the recipients of those invoices.

In addition, it will be particularly active in relation to those taxpayers in objective estimation that artificially divide their activity among several subjects in order to circumvent the exclusion of this regime.

On the other hand, you will have an impact on the control of unusual operations or excessive amounts linked to entrepreneurs in modules with other entrepreneurs or professionals in direct estimation.

The control actions to be carried out will be reinforced by the implementation of a plan of visits to contributors in modules, which will provide evidence of the existence of some of the irregularities mentioned.

(g) Control of non-declarants.-A control action plan shall be carried out in respect of those taxpayers who have failed to fulfil their obligations to submit the relevant self-procedures for any In order to demand the tax quotas that would have resulted from a correct self-validation.

2. The black economy comprises all the legal productive activities that are deliberately hidden from the authorities in order to avoid both the payment of taxes and social security contributions and the fulfillment of labour regulations.

In the framework of the Comprehensive Plan for the Prevention and Correction of Tax Fraud, Labor and Social Security, the control bodies will focus their action on the detection of undeclared economic activities or on which the amount of the object of the declaration is proportionally very small in relation to the activity actually developed. These actions will also pursue the identification of falsely self-employed workers and the discovery of natural persons who do not declare the perceived income which, in addition, may be in receipt of welfare benefits in respect of unemployment or Social Security.

Measures to combat the shadow economy provided for in the Comprehensive Plan for the Prevention and Correction of Tax, Labor and Social Security Fraud will be implemented in a coordinated or joint manner with the Labour Inspectorate. and Social Security or the General Treasury of Social Security.

In this field, the following actions will be the focus of attention:

(a) In-person actions in premises located in certain geographical areas or in which activities specific to certain economic sectors are carried out. -These actions shall be directed towards obtaining evidence of the carrying out hidden economic activities in certain productive sectors.

b) Exploitation and analysis of information on economic activities exchanged with the General Treasury of Social Security or with the Labour and Social Security Inspectorate. the discovery of economic activities which, having been declared before the social order bodies, have not been before the Tax Office. It is also intended to detect economic activities whose nature does not correspond to the type of activity that has been declared to the Tax Office or to the agencies under the Ministry of Labour and Immigration, with the aim of Misuse of any tax or social benefit.

c) Treatment of information from the new annual information statement on electrical energy consumption (model 159)-To detect buildings where a certain level of energy consumption has been appreciated electrical and do not consist of as intended for use, either for the development of economic activities or for the rental.

Exploitation and analysis of information provided by the new information statement on credit card terminals (model 170).

For the purpose of detecting, among others, tax authorities who have several credit card terminals that are being used as a means of collecting undeclared income from the Tax Office.

(d) Monitoring of foreign trade operations carried out through the Spanish customs.-The coherence between the import and export operations carried out through the Spanish customs and the Spanish customs will be analyzed. economic activity as declared by the importer or exporter in order to detect cases where the subject making the foreign trade operation remains in the field of the black economy.

(e) Control over the economic activities arising from the importation of goods from Asia and other third countries. The phenomenon of undervaluation of imported goods and economic activities The situation in the area of the Community's internal market is of great importance to the Community's own resources. This also directly affects trade, intellectual property rights and the protection of citizens as a result of product counterfeiting.

It is necessary to have an integral control that encompasses measures of different nature that are presided over by the aim of greater efficiency. Collaboration with other public bodies takes on a fundamental role. The following actions will be taken in this priority area:

Research on marketing channels for imported goods, including in-person performances.

Intensification of control in Customs on goods imported into aspects such as customs value of goods, detection of counterfeit goods, preferential arrangements, breaches of trade policy and anti-dumping duties.

Research into the fabrics of companies operating in this field in order to know the real operation of the sector and to obtain rational indications of tax defaults.

3. Fight against relocation and abusive tax planning. -Control will be intensified on all actions of tax engineering or abusive tax planning that pursue the use of structures to conceal or undermine The tax is unduly paid in accordance with the true spirit and purpose of the tax rules.

These research actions will focus on the following extremes:

Trust structures consisting of corporate fabrics created to evade taxes, launder capital, or to hide ownership of income or wealth.

Planning centers that market products that target tax fraud.

Financial practices that can lead to the opacity of accounts or operations.

Practices that pursue the undue accreditation of financial expenses, especially intragroup, to reduce or eliminate taxable bases that should be taxed in Spain.

In addition, this type of action will be directed to pursue the artificial relocation of income, wealth or the false residence of the taxpayer outside the scope of the tax office, in order to tax the income or property that is fictitious or artificially located by the taxpayer outside the taxpayer, especially in countries or territories with low taxation.

In particular, the research actions will focus on the detection of assets, deposits and other financial products outside our borders, but whose real ownership corresponds to citizens resident in Spain. The changes that have been taking place in recent years in international fora, especially the OECD, in the fight against non-cooperative or traditionally non-cooperative territories or havens is allowing for the information on assets, deposits and other financial products existing in those territories whose actual ownership corresponds to citizens resident in Spain.

4. Transfer pricing control. -In the field of international taxation, the actions envisaged in relation to the abusive use of transfer and transaction prices between companies will be particularly relevant. linked in three major areas of risk: business restructuring operations, in which there is a lack of correlation between the economic substance of the operation and the adopted form or the conduct of unfair valuations, operations with intangibles, with particular attention to their assessment and, finally, will be attended to treatment of losses arising from the crisis in order to avoid compensation strategies.

In this same sense, and as a preventive action, advance valuation agreements (Advance Price Arrangement, or APAs) will be encouraged as the most appropriate instrument to eliminate the risks associated with the application of an incorrect transfer pricing strategy.

5. General control actions. -Permanent actions will be maintained which, in general, develop the tax office in order to ensure adequate compliance with the tax system, appropriate to the importance of currently have these sectors and activities and with the specifications that are indicated in each case.

a) Control of VAT fraud schemes in intra-Community transactions. -In particular, fraud in the sale of CO_{2 emission}, certified emission reductions and units of VAT will be particularly affected. the reduction of greenhouse gas emissions referred to in Law 1/2005, which regulates the regime of greenhouse gas emissions trading, and the Royal Decree 1031/2007, for which the framework of the greenhouse gas emissions trading framework participation in the flexibility mechanisms of the Kyoto Protocol.

The participation in multilateral controls with the tax administrations of other countries of the European Union will be strengthened and the control of the returns requested by taxpayers linked to schemes for intra-Community fraud, both in the case of applications of an annual nature and in the case of monthly applications.

Finally, the investigation will continue with respect to intra-Community operators linked to fraudulent plots, in order to obtain the necessary evidence for the submission of immediate complaints to the competent bodies and achieve the decommissioning of the detected operational fabrics.

This framework will investigate the reality of intra-Community delivery of goods released for free circulation in Spain.

b) Control of the real estate sector. -It will continue with the development of operations of control of operations with relevant economic result in the field of the activities of construction and real estate with the object of verify the proper taxation of such operations. In addition, the verification of the real estate transmissions shall be continued in order to detect any non-declared income.

(c) Census control acts. -These actions will be directed to the enhancement of controls in the main industrial centers and commercial zones where undeclared economic activities may be taking place.

The training and maintenance of the census will also continue with special attention to the census of businessmen, professionals, retainers and landlords of local business. Also, census control actions will be developed for both large companies and Special Tax operators.

On the other hand, the single census shared with the tax administrations of the Autonomous Communities will be consolidated and the exchange of information between the tax office and the tax administrations will be promoted. autonomic and local entities.

Finally, the possibility of resolution, in an agile and secure manner, will be enabled on the part of the contributors of certain census incidents through the electronic headquarters of the Tax Agency, either with prior character, at the same time or after the submission of any declaration, and progress will be made on the possibility of correction by the taxpayer itself of minor material errors in the declarations in respect of which the absence of guilt.

(d) The verification of tax groups for the tax on companies and groups of entities of value added tax. -In the framework of the tax control on the application of these schemes priority will be given to the following aspects:

Control over the most specific operations to which the application of the system of consolidated tax groups in the Company Tax and that of groups of entities of the Value Added Tax.

Analysis on compensation of negative taxable bases, both from the group itself and the individuals prior to joining it.

Assessment of assumptions of corporate integration or exclusion in the tax group.

e) Control of return or compensation requests. -In addition to the general controls on tax returns, a new control model will be introduced with the improvement of the rating and quantification systems of the tax risk.

(f) Registration of Intra-Community Operators and Registration of Monthly Return.-Measures to prevent fraud in this field shall be maintained by means of appropriate control of access to the Register of Intra-Community Operators and to the Monthly Return Record. In addition, the operators registered in the Register of Intra-Community Operators and in the Monthly Return Register will be monitored in order to assess compliance with the requirements for the permanence in these registers.

A priority area of action is the detection of risks in the allocation and subsequent use of the tax identification number for the purposes of Value Added Tax.

g) Control of exemptions and tax benefits. -Control actions will be developed on taxable persons who unduly reduce their tax bases or quotas by incorrect application of bonuses, reductions, deductions or exemptions.

In the field of Excise Excise, the application of exemptions or bonuses, especially in relation to the Tax on Hydrocarbons to credit the use and destination of the gas oil or exempt in activities, will be monitored. to justify exemptions or bonuses, as well as the application of the tax regime to biofuels.

In the matter of the Special Tax on Certain Means of Transportation, attention will be focused on the acquisition of means of transport that reveal a high purchasing power, whose acquirers try to avoid unduly taxation by means of the fictitious affectation of the means of transport to a business activity, in particular in cases of exemptions declared in recreational craft, aircraft and land vehicles for the purpose of lease.

h) Hold control. -It will analyze the correct compliance of the retention rules by checking the cash income of the retained quantities, verifying the consistency between the holds entered and the information provided by the retainers, and the analysis of the discrepancies between the amount declared by the taxpayers who support holds and the amounts declared and entered by the retainers.

6. Control over Foreign Trade and Excise. -In this area, the actions will focus primarily on the following aspects:

(a) Prevention in the field of Customs and Excise. -Control of the intervention regime of the factories and tax warehouses of alcohol and derived beverages, which will be carried out in the control over the the manufacturing processes, the denaturing of alcohols, the accounting and justification of the statutory losses, the carrying out of stock counts and accounting records, the control over the processes of production and distribution of biofuels, the verification of mixtures of biofuels with conventional fuels, and the control of tax deposits which are considered to be logistical or which are made up of oil or gas pipeline networks.

In addition, actions on the prevention of tobacco smuggling will continue and maritime patrols will be maintained in the operational area of Customs and Excise in the areas of northern Spain, as well as the capacity for air intervention, for the purpose of controlling the smuggling of narcotic drugs.

(b) Control over imports, exports and Community aid for the export of agricultural products. -This includes actions aimed at combating illicit activities that transcend the tax area. and they affect public health, such as health controls, which have an impact on the quality of products, guaranteeing the safety of the consumer, and those aimed at the protection of intellectual and industrial property.

Also, the export of sensitive goods, such as defense and dual-use material, chemicals, substances that may be used as precursors of narcotic drugs and psychotropic substances, will be monitored, cultural goods, as well as species of fauna and flora protected by the CITES Convention.

Finally, the control of agricultural products subject to the application for a refund under the common agricultural policy as determined by Regulation (EC) No 1276/2008, Regulation (EC) No 612/2009, and Regulation EC 485/2008, specific to controls on agricultural refunds.

c) Control of Excise Duties. -Measures to check the activity developed by companies holding authorized establishments for the purposes of the Special Tax of Manufacture will be enhanced.

Will constitute area of preferential attention in the field of the Special Taxes of Manufacture the newly created societies that are forced to these taxes

Finally, control actions will be carried out on recreational boats, aircraft and land vehicles not declared to have a non-Spanish flag, although they are used by residents in Spain.

(d) Security and protection checks at Customs.-The obligation to include certain security data in declarations relating to the import and export of goods will imply that Customs will have new and better tools for detecting potential threats.

In the field of security of the supply chain of international trade, the verification actions resulting from the applications of the status of the Authorized Economic Operator that will be carried out by the agents will continue economic activity in Spain or another country of the European Union, the activity of which is linked to the movement of goods in the Community customs territory and the introduction into the Community customs territory of goods from third countries.

Will continue the development of the actions of surveillance of the maritime and air patrols, and of the actions of collaboration in the field of aerial surveillance with other agencies of the State with presence in the sea and with others customs administrations.

(e) Investigation into the smuggling, drug trafficking and money laundering of these illicit drugs. -The following actions will be carried out aimed at the repression of the extreme manifestations of fraud in the customs area:

Actions aimed at interception and apprehension, both in customs and maritime areas, of contraband (narcotic, tobacco, counterfeiting and other genera), strengthening investigations and the special techniques such as the monitored deliveries.

Actions aimed at the financial dismantling of drug trafficking and smuggling networks.

Actions of location and intervention of assets from the crimes of smuggling, drug trafficking and money laundering.

Performances in customs precincts for the discovery of undeclared currency movements.

7. Information collection. -Action to collect information and, in particular, international exchanges of information and with other Public Administrations, with the dual purpose of prevention of non-compliance, will be promoted. taxation and detection of suspected underground economy.

In particular, the capture actions will be directed to the following scopes:

Financial, allowing the detection of those taxpayers with undeclared income or whose investments do not correspond to their previous income or wealth.

Cobros and payments abroad, which are indicative of the existence of branches or activity abroad in order to incorporate into the tax base of the Corporate Tax the obtained world income.

Rents or assets located in tax havens or low-tax territories for the discovery of income actually obtained in Spanish territory but which have been artificially dislocated by the taxpayer by means of tax engineering operations to place them formally in those territories, thus avoiding the taxation of such income in accordance with Spanish tax law. The collection of information will be facilitated by the application of the new double taxation agreements signed by the Kingdom of Spain and by the increase in the exchange of information between the OECD countries.

Business activities, with the aim of detecting hidden income and ensuring adequate control over the income of the participants in the operations. Special attention will be given to obtaining information in the field of electronic commerce to detect the interveners, the place from which the companies that offer goods through the Internet operate, terminals where they are billed sales, and real flows of goods, thus allowing an integral analysis of the financial and real flows of companies operating in this economic sector. In this area, the increase of effective coordination with the other countries of the European Union for the exchange of information will be encouraged.

Professional activities, in respect of which it will be a preferred line of action to obtain external information on the income from the development of professional activities, while continuing the actions aimed at obtaining information on external signs of wealth of these professionals. In particular, actions aimed at proving that the ownership of vehicles, boats and mooring points, formally attributed to legal persons, will actually correspond to the natural persons who use them.

Exchange of information with the General Treasury of Social Security and the Labour and Social Security Inspectorate for the purpose of detecting undeclared economic activities through discrepancies between information held by these bodies (location, developed activity, staff) and available at the tax office.

II. Control of fraud in the collection phase

The second of the major areas in which the General Control Plan is articulated focuses on actions aimed at achieving the effective recovery of regularisations and liquidations arising from the earlier detailed actions. of tax and customs control. The main criteria and principles that will govern these actions are set out below.

1. Evaluation of the risk collection in the inspection phase. -The program of monitoring of coordinated actions between the teams and units of Financial and Tax Inspection, Customs Inspection and Collection from the the initiation of the verification to anticipate the adoption of precautionary measures and the procedures for the declaration of liability, in order to ensure the recovery of the tax debts resulting from these procedures check.

2. Control of debtors with systematic non-compliance with their tax obligations. -It will be an area of special monitoring of the debtors who are in a situation of systematic failure of their tax obligations. The following shall be made in respect of such debtors ' actions as a result of the assets deposited in their offices and of how many credits are possible according to the accounting information that may be obtained in the said proceedings. This, with the dual purpose of collecting the outstanding debt and preventing action on the market of these subjects, in order to prevent the injury resulting to the public finances, as well as the illicit competition that this tax fraud entails. in respect of the economic sector in which it occurs.

3. Personnel of the collection bodies in the cases of higher complexity collection. -The effective presence of the organs of collection in the premises of the forced tributaries will be intensified in the following cases:

Debtors with significant amount of executive period debts.

Requests for deferment or fractionation for relevant amounts in order to assess the financial and patrimonial situation of the tax authorities.

4. Monitoring of apparent insolvencies. -In particular, the participation of apparently insolvent debtors will be investigated in the creation of successive commercial companies that do not enter their tax obligations, in which the recovery of the debt receivable.

The actions to be carried out will, on the one hand, lead to evidence of the accreditation of punishable insolvency cases and, on the other hand, to the early adoption of the debt recovery insurance measures which proceed.

5. Control of processes involving the increase in the number of cases requires specific actions to be taken in order to prevent acts of fraud which seek to take advantage of the protection afforded by insolvency law. to avoid the payment of tax debts or to avoid incurring the liability assumptions provided for by the tax rules. The following control actions will therefore be intensified in the field of insolvency:

Opposition to the approval of accounts in contests in which alterations are detected in the order of payment of the credits and in which there are credits against the tax-related mass of nature pending payment.

Impulse control of the responsibilities of the conclave administrators.

Potentiation of a more active participation in the qualification phase in order to obtain and contribute those tests that allow a guilty contest qualification when it is estimated that the assumptions collected in the Article 164 of the Insolvency Law.

6. Actions to be collected in relation to the crime against the Public Finance. -It will strengthen the actions collected in relation to the crime against the Public Finance, both through the referral of the file to the criminal field in order to propose to the judicial bodies the adoption of precautionary measures where risk is collected, as well as through the establishment of systems of patrimonial surveillance in relation to those called to answer for the civil responsibility arising from the offence against the Public Finance during its judicial proceedings, detecting conduct of patrimonial emptying and even alleged punishable insolvencies (as provided for in Article 258 of the Criminal Code). This monitoring will also make it possible to properly inform the collection side of the proposals for compliance.

With regard to the administrative procedure for the recovery of civil liability arising from a crime against the Public Finance (and since 23 December 2010, the fine, as provided for in the new paragraph 5 of the article) 305 of the Penal Code, introduced by the Organic Law 5/2010, of June 22), the organs of collection will pay special attention to the conduct of the convicts, in case they would have to put them in the knowledge of the judges requesting the withdrawal of the suspension of the entry in prison in the face of non-compliance with its obligations of entry without being insolvent.

8. The main measures to be taken in the framework of the correction of fraud in the collection phase will focus on the consequences of liability. In this respect, the actions of investigation aimed at the application of the alleged lifting of the veil, administrators of fact and responsible for the concealment of goods, with exercise in the case of the actions, will be expanded (a) judicial proceedings.

9. Reinforcement of the adoption of precautionary measures. -The precautionary measures are being revealed in recent years as a very effective instrument in the fight against the patrimonial emptying. This is why this kind of action will be taken with the collaboration of the areas of Tax Management, Tax Inspection and Customs and Excise.

III. Control of fraud in relation to temporary taxes.

Law 22/2009 of 18 December, which regulates the system of financing of the Autonomous Communities of the common regime and cities with the Statute of Autonomy and changes certain tax rules, provides for the promotion and development of information exchanges between the autonomous and state tax administrations, as well as the need to set up coordinated planning of the actions carried out by the various administrations on the Temporary taxes.

On the other hand, the General Rules of Procedure and the procedures for the management and inspection of taxes and the development of common rules for the application of taxes, approved by Royal Decree 1065/2007 of 27 July 2007, establishes in Article 2 the monthly exchange of census information between the Tax Agency and the Autonomous Communities and Cities with Autonomy Statute, as well as with the Local Entities with which collaboration agreements are signed. In turn, the Fiscal Fraud Prevention Plan, along the lines of strengthening collaboration between tax administrations, refers to the Unified Census Shared as a database built with the census information obtained by the State and regional tax administrations. This mechanism was launched in 2009, and its full consolidation is planned throughout 2011.

Finally, Law 4/2008, of December 23, established a 100 percent bonus in the Heritage Tax from January 1, 2008, which does not exclude the control of the declarations regarding this tax for previous years.

In this framework of collaboration between Administrations, in which the exchange of information plays a relevant role, the following actions will continue in 2011:

(a) Realization of coordinated actions in relation to significant real estate operations. -We will advance the collaboration in the procedures for selecting the most significant real estate operations. consider liable to be taxed for VAT or, alternatively, for the concept of "Heritage Transmissions" of the Tax on Proprietary Transmissions and Documented Legal Acts, as well as for the exchange of information and collaboration in property valuation material.

b) Realization of coordinated actions in relation to the most significant corporate operations declared exempt from the concept of "Societarian Operations" of the Tax on Inheritance Transmissions and Legal Acts Documented as having received the special tax regime of Chapter VIII of Title VII of the Recast Text of the Corporate Tax Act.

c) Realization of coordinated actions for the control and verification of the cooperative tax regime.

d) Control of the Tax on the Heritage for the pre-2008 tax periods not prescribed and its relation to the Tax on Successions and Donations. -Autonomous and state tax administrations continue to collaborate in the selection procedures, which will focus primarily on the crossing of information on the ownership of goods and rights and the identification of non-reporting taxpayers who are required to make a statement.

e) Coordination of value-checking actions with respect to real estate operations.

f) Collaboration with other tax administrations through the transmission of information deemed relevant, obtained in the control procedures, by means of collaborative measures.

g) Treatment of information received on the operations of dissolution of companies, reduction of social capital and loans between individuals for the detection of tax breaches in taxes direct.

(h) Realisation of coordinated action to inspect certain exemptions from the import of means of transport and, in particular, of vessels, subject to the Special Tax on the Determinated Means of Transport and the General Indirect Tax.