The entry into force of Law 27/2014 of 27 November of the Corporate Tax has resulted in a new typology of tax groups, considering the existence of groups constituted by dependent entities, in the which the dominant status is held by a non-resident entity in Spanish territory or an entity subject to the foral regulation in accordance with the Economic Concert with the Basque Country. In these groups, it is one of the dependent entities that assumes the representation of the group, which is why Article 56.2 of Law 27/2014 has replaced the mention of the "dominant company" with that made to the "representative entity" by referring to the the entity that is subject to compliance with the material and formal tax obligations arising from the tax consolidation regime.

Also, after the aforementioned Law, by Royal Decree 634/2015, of July 10, the new Corporate Tax Regulation is approved. Article 7 of that Regulation lays down the body responsible for the instruction and resolution of the files relating to the repayment plans, indicating that it shall be exercised by the body of the State Administration of Taxation corresponds in accordance with its rules of organic structure. In addition, the special investment plans are deleted in that text.

This Resolution is aimed at introducing in the Resolution of 24 March 1992, of the State Agency of Tax Administration, on the organization and assignment of functions to the Inspection of the Taxation in the field of the competence of the Department of Financial and Tax Inspectorate, the precise amendments to comply with the provisions set out in those rules.

In addition, in the area of groups, it is necessary to maintain the membership of the entities representing the same to the Management Units of Large Enterprises, even if they do not have the status of great company, in order to for these Units the management of the last of the models to be submitted by a group of companies can be completed when it is no longer taxed under the corporate tax consolidation scheme or by the special scheme of the group of companies. entities of Value Added Tax.

For the purposes set out in point (c) of paragraph 4 (c) and point (g) (g),

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By virtue of the foregoing and in use of the authorization conferred by the 15th section of the Order of 2 June 1994, for which the structure of the State Administration of Tax Administration is developed, according to established by Article 103.one.5 of Law 31/1990 of 27 December 1991 on the General Budget of the State for 1991, available:

Unique. Amendment of the Resolution of 24 March 1992 on the organization and assignment of duties to the Inspectorate of Taxation in the field of competence of the Department of Financial and Tax Inspection.

The Resolution of 24 March 1992, of the State Agency for Tax Administration, on the organization and assignment of functions to the Inspectorate of Taxation in the field of the competence of the Department of Inspection Financial and Tax, as follows:

One. Paragraph 4, number 7 shall be worded as follows:

" 7. Large Enterprise Management Unit.

It is up to the Large Enterprise Management Unit of the Regional Inspection Unit to exercise the functions of tax management attributed to it and the adoption of the corresponding agreements and acts, in relationship with tax authorities with a tax domicile in the field of the respective Special Delegation of the Tax Office, on which the Central Delegation of Large Contributors does not exercise its jurisdiction and where any of the the following circumstances:

(a) That its volume of operations exceeds the figure of 6,010,121,04 euros during the preceding calendar year, calculated in accordance with the provisions of Article 121 of Law 37/1992 of 28 December 1992 on the Tax on the Value Added.

b) That the Special Delegate of the Tax Office order it, prior to the favorable report of the Directors of the Departments of Tax Management and the Financial and Tax Inspectorate, in consideration of the importance or complexity of their operations in the field of the respective Special Delegation or for their connection or relationship with the former or with other tax obligations to which the Large Enterprise Management Unit extends its competence.

(c) In the case of entities representing a group that is taxed in the tax consolidation regime of the Corporate or Dominant Entities Tax which is taxed in the special scheme of the group of tax entities on the value added and the option provided for in Article 163 e has been exercised. five of the Law 37/1992 of 28 December of the Value Added Tax. These entities shall continue to be attached to the Large Enterprise Management Unit, if they are no longer taxed by the special schemes and even if they do not have the status of a large undertaking, until the calendar year following that in which they occur. the presentation of the consolidated or aggregated statement of the group for the last period of validity of the referred schemes.

The Large Enterprise Management Units of the Regional Inspection Dependencies will have in this field the competencies attributed to the Dependencies of Tax Management by the Resolution of 19 February 2004, of the Presidency of the State Agency of the Tax Administration on the organization and assignment of functions in the field of competence of the Department of Tax Management and, in general, those of the field of tax management.

The Head of the Regional Inspection Unit and the Deputy Regional Inspectors shall exercise, with respect to the persons or entities attached thereto, the tax management powers conferred on the Heads of Dependence Regional Tax Management.

Without prejudice to the foregoing, the tax authorities may, in any event, present their statements, resources, consultations and any other document with a tax significance in the Delegation or Administration that corresponds to your tax address. "

Two. Paragraph 5, number 2 shall be worded as follows:

" 2. It is up to the Chief Inspectors to plan, coordinate and monitor the actions of the Teams and Units of the corresponding Inspectors, in order to achieve adequate utilization of the available means for the most efficient of the actions.

In addition, it is up to the Chief Inspectors to exercise the following powers:

a) Order the start of the test and investigation actions, as well as their scope and extent.

(b) Agree to the modification of the extent of these actions, the extension or reduction of their scope, as well as the assignment of the file to a different official, team or unit.

(c) Dictate the settlements for which the tax situation of the obligor is regulated, as well as the other agreements that put an end to the inspection procedure and the limited verification procedure.

d) Make the individual requirements for obtaining information, except in cases where the current regulations attribute this competence to other bodies.

e) Authorize the initiation of sanctioning files in cases where regulatory regulations require such authorization, and dictate the acts of imposition of sanctions.

f) Conduct verification and investigation actions when agreed by the Director of the Financial and Tax Inspection Department.

g) Solve the procedure relating to repayment plans, plans for expenditure related to environmental actions, investments and expenditure of communities with common hand-side neighbourhood.

h) Initiate and resolve sanctioning procedures arising from non-compliance with limitations on cash payments. It shall also be the responsibility of the Head of Team, Head of Unit or official to instruct such sanctioning procedures.

(i) Any other powers and functions assigned to them by the laws and regulations and other provisions that apply. "

Single end disposition. Entry into force.

This Resolution shall enter into force on the day following that of its publication in the "Official State Gazette".

Madrid, July 16, 2015. -President of the State Tax Administration Agency, Miguel Ferré Navarrete.