FELIPE VI

KING OF SPAIN

To all who present it and understand it.

Sabed: That the General Courts have approved and I come to sanction the following law.

EXPLANATORY STATEMENT

The current Economic Convention between the State and the Community of Navarre, approved by Law 28/1990 of 26 December, provides for an additional third provision that in the event of a substantial reform in the (a) the State's tax law shall be governed by the two administrations, by mutual agreement, to the adaptation of the Economic Convention.

Since the last modification of the Convention, by Law 48/2007 of 19 December, there have been a number of new developments in the tax law of the State that require the adaptation of the Convention.

With this amendment, various taxes approved by the General Courts are incorporated into the Convention, in particular the Tax on Gaming Activities, provided for in Law 13/2011, of 27 May, of regulation of the game; the Tax on the Value of the Production of Electrical Energy, the Tax on the Production of Spent Nuclear Fuel and Radioactive Waste Resulting from the Generation of Nuclear Power and the Tax on the Storage of Spent Nuclear Fuel and Radioactive Waste in Centralised Facilities, introduced by Law 15/2012 of 27 December 2012 on tax measures for energy sustainability; the Deposit Tax on Credit Entities, as regulated in Article 19 of Law 16/2012 of 27 December, for which adopt various tax measures aimed at the consolidation of public finances and the promotion of economic activity and, finally, the Tax on Greenhouse Gases, established by Law 16/2013 of 29 October, laying down certain measures in the field of environmental taxation and adopting other measures tax and financial measures.

Likewise, the competition is required to require the retention of the special charge on prizes for certain lotteries and bets, created by Law 16/2012 of 27 December, for which various tax measures are adopted aimed at the consolidation of public finances and the impulse of economic activity, and which has been reproduced by the tax regulations of Navarra.

Other changes in the state tax system to which the Convention is to be adapted are the replacement of the Retail Sales Tax of Certain Hydrocarbons by an autonomous rate of the Hydrocarbon Tax. carried out by Law 2/2012, of 29 June, of General State Budgets for the year 2012 and the recent modification of the configuration of the Special Tax on Electricity, carried out by Law 28/2014, of 27 November.

In addition to the adequacy of the Convention to the latest reforms of the tax system, some technical and systematic improvements are incorporated in the tax system. In this respect, it has been considered appropriate to advance the coordination between the State and the Foral Community when new state taxes are established. On the other hand, the points of connection of the Income Tax of non-residents are adapted and a rule of competence is introduced in the management and inspection of this tax in relation to the income obtained through establishment permanent.

This same purpose of technical improvement responds to the adaptations in the tax domicile change procedure and in the presentation of certain informational statements.

The rule on regulations applicable to tax groups is also amended, so that they will have to be integrated by companies subject to the same rules. With regard to another special scheme of corporate tax, which applies to mergers, divisions and other business reorganisation operations, it is envisaged that the legislation approved by the Foral Community will have the same content as the common territory rules.

Changes to institutional aspects of the Convention are also included. Thus, the referral to the Arbitration Board of the tax consultations on which no agreement has been reached in the Coordinating Committee is made available and the possibilities of constituting subcommittees of the same are broadened.

On the other hand, a standard is provided for the tax debts corresponding to one administration and that are entered into another, so that the tax liability may request the extinction of the tax debts. by indirect taxes which may be claimed by an Administration, in the equivalent part of debt effectively satisfied in the other, when certain requirements are met.

Finally, the usual transitional rules on the effects of the new convention are incorporated.

This Law is a consequence of the agreement reached by both administrations at the meetings of the Negotiating Commission of the Economic Convention of 17 February and 23 March 2015 (Acts 1/2015 and 2/2015).

Single item. Amendment of Law 28/1990 of 26 December on the approval of the Economic Convention between the State and the Autonomous Community of Navarre.

The amendment of the current Economic Agreement between the State and the Community of Navarre, approved by Law 28/1990 of 26 December, is approved, in accordance with the provisions of Article 45 of the Organic Law 13/1982, August 10, Reintegration and Improvement of the Foral Regime of Navarra, and in the third provision of the said Convention, in the terms established in the Annex to this Law.

Single end disposition. Entry into force.

One. This Law shall enter into force on the day following its publication in the Official Gazette of the State.

Two. The charges agreed under the amendment to the Economic Convention incorporating this Law are understood to apply with effect from 1 January 2013.

Therefore,

I command all Spaniards, individuals and authorities, to keep and keep this law.

Madrid, 24 June 2015.

FELIPE R.

The President of the Government,

MARIANO RAJOY BREY

ATTACHED

Agreement of the Negotiating Commission of the Economic Convention. Minutes 1/2015 and 2/2015

Agreement

Approve the amendment of the Economic Convention between the State and the Community of Navarre, in accordance with the new wording to be given to Articles 2, 6, 14, 27, 30 and 5, 30 and six, Forty-three, forty-three, forty-six, forty-seven, sixty-seven, and to the third additional provision and the addition of Articles 30a, thirty-one-bis, thirty-one-terthirties, and one-tert, the additional provision eleventh and the transitional provisions fourteenth, fifteenth, sixteenth and seventeenth.

" Article 2. Tax powers.

1. In the exercise of the tax authority referred to in the previous article, the Community of Navarra shall respect:

(a) The criteria for the harmonisation of the tax regime of Navarre with the general regime of the State established in this economic agreement.

(b) The powers which, in accordance with the provisions of this economic agreement, correspond to the State.

(c) International treaties or conventions entered into by the State, in particular those signed to avoid double taxation, as well as the European Union's rules on tax harmonisation, with the obligation to assume the proceed as a result of the application of such conventions and standards.

d) The principle of solidarity referred to in Article 1 of the Organic Law on Reintegration and Improvement of the Foral Regime of Navarra.

e) The institutions, faculties and competences of the State inherent in the constitutional unit, as provided for in Article 2. of the Organic Law of Reintegration and Improvement of the Foral Regime of Navarra.

2. Without prejudice to the laws of general government of the State, the Community of Navarra may establish and regulate taxes other than those referred to in this Convention, in compliance with the principles laid down in paragraph 1. and the harmonisation criteria provided for in Article 7 of this Convention. "

" Article 6. Modification.

Any amendment to this Economic Convention must conform to the same procedure followed for its elaboration and approval.

The same procedure should be followed to harmonize the tax regime of Navarra with the new taxes that the State can establish in the future.

When a Bill is presented that the State establishes a new tax, the Coordinating Committee, or the Subcommittee on which it delegates, will be convened to evaluate and analyze the adaptation of the Convention to the new figure. State-projected tax, in accordance with the procedure provided for in the third provision of the Convention. "

" Article 14. Withholding and income on account for certain asset increases.

1. Deductions and income on account relating to increases in assets arising from the transmission or redemption of shares and units of collective investment institutions shall be required, in accordance with their own rules, by the Community. Foral when the shareholder or participant has its tax domicile in Navarra.

2. The deductions for the special Gravamen on the prizes of certain lotteries and bets will be required by the Community of Navarra when the recipient has his habitual residence or tax domicile in his territory. In the levy of these deductions the Community shall apply identical rates to those of common territory.

3. Holds and revenue for prizes other than those specified in the previous paragraph which are delivered as a result of participation in games, contests, raffles or random combinations, whether or not they are linked to the offer, promotion or sale of certain goods, products or services, shall be required, in accordance with their own rules, by the Community Foral where the payer of the goods has his registered office in the territory of Navarre. In any event, they shall be required by the State Administration or by the Foral Community when they correspond to awards for them. "

" Article 27. Tax regime for groups, temporary unions and tax groups.

1. The tax system of economic interest groups and temporary joint ventures shall be the responsibility of Navarre when all the entities that integrate them are subject to foral regulations.

These entities shall impute to their partners the corresponding share of the amount of transactions carried out in one territory and another territory, which shall be taken into account by them to determine the proportion of their operations.

2. The following rules apply to determine taxation of tax groups:

1. The fiscal consolidation regime will be the one for the Foral Community when the dominant company and all the dependents are subject to the rules of the individual taxation system, and it will be the for the system of fiscal consolidation of common territory where the dominant company and all the subsidiaries are subject to the tax regime of the common territory under individual taxation. For these purposes, companies that are subject to the other rules shall be considered to be excluded from the tax group.

2. The tax groups in which the dominant entity is subject to the rules of the individual taxation regime shall be equated in their tax treatment to tax groups in which the dominant entity is not resident on Spanish territory.

3. In any event, identical rules shall apply to the one established at any time by the State for the definition of the tax group, the dominant company, the dependent companies, the degree of dominance and the internal operations of the group.

3. For the application of the tax consolidation regime of tax groups to tax both administrations the following rules will be followed:

1. The members of the tax group shall present, in accordance with the general rules, the statement established for the individual taxation system.

Without prejudice to the foregoing paragraph, the parent company shall submit to each of the Administrations the consolidated accounting statements of the tax group.

2. The tax group will be taxed at one and the other Administration based on the volume of operations performed on one territory and another.

For these purposes, the volume of transactions carried out in each territory shall be constituted by the sum or aggregation of the transactions that each of the companies belonging to the fiscal group carries out in the same, before the intergroup removals that proceed. "

" Article 30a. Management and inspection of tax when income is taxed by permanent establishment.

1. Where income obtained by permanent establishment is taxed, in cases of taxation to both administrations, the rules for the management of the tax provided for in Article 22 above shall apply.

2. The inspection of the tax, when taxed income obtained by permanent establishment, shall be carried out by the Administration which is competent to apply the rules provided for in Article 23 above. "

" Section 6. Tax on the Value of Electrical Energy Production

Article 31a. Applicable rules and levy of tax.

1. In the levy of the Tax on the Value of the Production of Electrical Energy, the Community of Navarra will apply the same substantive and formal rules established at each moment by the State.

However, the Foral Community may approve the models of declaration and revenue which shall contain at least the same data as the common territory and indicate time-limits for entry for each settlement period, which shall not differ. substantially of those established by the State Administration.

2. The levy of this tax shall be the responsibility of the Community of Navarre when the power plant is situated on its territory. Where the installation is situated in the territory of Navarre and in common territory, the levy of the tax shall be the responsibility of the Administration responsible for authorization.

3. Payments on account of this tax shall be required, by one or other Administration, in accordance with the criteria set out in paragraph 2.

4. The returns to be returned shall be effected by the respective Administrations in the amount to which each corresponds. "

" Section 7. Tax on the production of spent nuclear fuel and radioactive waste resulting from the generation of nuclear power and the storage of spent nuclear fuel and waste Radioactive in centralised facilities

Article 31 ter. Applicable rules and levy of taxes.

1. In the tax levy on the production of spent nuclear fuel and radioactive waste resulting from the generation of nuclear power and the tax on the storage of spent nuclear fuel and radioactive waste in Centralised facilities in the Community of Navarra shall apply the same substantive and formal rules established at any time by the State.

However, the Foral Community may approve the models of declaration and revenue which shall contain at least the same data as the common territory and indicate time-limits for entry for each settlement period, which shall not differ. substantially of those established by the State Administration.

2. The levy on the production of spent nuclear fuel and radioactive waste resulting from the generation of nuclear power shall be the responsibility of the Community of Navarre when the fuel-producing plant spent nuclear and radioactive waste resulting from the generation of nuclear power is located in its territory. Where the installation is situated in the territory of Navarre and in common territory, the levy of the tax shall be the responsibility of the Administration responsible for authorization.

3. The levy on the storage of spent nuclear fuel and radioactive waste in centralised facilities shall be the responsibility of the Community of Navarre when the fuel and waste are stored in the Community. located on its territory.

4. Payments on account of these taxes shall be required by one or other Administration, in accordance with the criteria set out in paragraphs 2 and 3 of this Article.

5. The returns to be returned shall be effected by the respective Administrations in the amount to which each corresponds. "

" Section 8. Tax on Deposits in Credit Entities

Article 31c. Applicable rules and levy of tax.

1. In the charge of the Tax on Deposits in Credit Entities the Community of Navarra will apply the same substantive and formal rules established at any time by the State.

Notwithstanding the foregoing, the Foral Community may establish the rates of this Tax within the limits and in the conditions in force at any time in the common territory.

In addition, the Foral Community may approve the declaration and revenue models which shall contain at least the same data as the common territory, and indicate time-limits for entry for each settlement period, which shall not differ. substantially of those established by the State Administration.

2. The levy of this tax shall be the responsibility of the Community of Navarre when the headquarters, branches or offices where the third-party funds are held are located within its territory. The tax corresponding to funds held by non-face-to-face marketing systems and those other than those which are not subject to territorialisation shall be attributed to the Föral Community in the proportion to which it corresponds according to its participation in territorialised deposits.

3. Payments on account of the tax shall be required by one or other Administration in accordance with the criterion set out in the previous paragraph. '

" Article 35. Levy of Excise Duties.

1. The levy on special manufacturing taxes shall be the responsibility of the Community for the production of the excise duty on the territory of the Community.

The returns of the Special Tax of manufacture will be made by the Administration in which the quotas whose return is requested have been entered. However, in cases where it is not possible to determine in which Administration the quotas were entered, the refund will be made for the territory where the right to return is generated.

The control, as well as the system of authorization of the establishments located in Navarra, will be the responsibility of the Foral Community. However, prior communication to the State Administration shall be necessary for the approval of the tax deposits.

2. The Special Tax on the Determinated Means of Transport will be required by the Community of Navarre when the means of transport are the object of definitive registration in Navarre territory.

The registration will be carried out in accordance with the criteria established by the current regulations on the subject. In particular, natural persons shall make the registration of the means of transport in the province where their registered office is located.

The refunds of the quotas of this Tax will be made by the Administration in which they were entered.

By way of derogation from paragraph 5, the Foral Community may lay down the rates of taxation of this tax within the limits and under the conditions in force at any time in the common territory.

3. The Special Tax on Coal will be required by the Community of Navarra when the accrual of the same occurs in Navarre.

The accrual will be considered at the time and place of the consumption.

The consumption is understood to be produced at the time of the first sale or delivery of coal after production, extraction, importation or intra-Community acquisition. They shall also have the first sale or delivery of any subsequent sales or deliveries by the employers who use the coal for resale when it has been applicable to them when the exemption is purchased for resale.

It is also understood that the consumption is produced at the moment of the coal consumption. The use or consumption of coal by producers or extractors, importers, intra-Community acquirers or employers referred to in the preceding paragraph shall be considered to be self-consumption.

4. The Special Tax on Electricity will be required by the Community of Navarra when the accrual of the same occurs in Navarre.

In the case of the supply of electrical energy, the accrual shall be deemed to be produced at the time and place of the placing on the market of the acquiring person or entity.

In the case of consumption by the electricity producers of that electricity generated by themselves, the accrual shall be considered to be produced at the time of the self-consumption.

5. In the levy of Excise duties corresponding to the Foral Community, it shall apply the same basic principles, substantive and formal rules in force at any time in the territory of the State. However, the Administration of the Autonomous Community of Navarre may approve the models for declaration and revenue, which shall contain at least the same data as the common territory and indicate the time limits for entry for each liquidation period, which shall not differ substantially from those established by the State Administration. Notwithstanding the foregoing, the Community of Navarra may lay down the rates of taxation of these taxes within the limits and under the conditions prevailing at any time in the common territory. "

" Section 3. Tax on Greenhouse Gases

Article 36. Applicable rules and levy of tax.

1. In the levy of the Tax on the Greenhouse Gases of the Greenhouse the Community of Navarre will apply the same substantive and formal norms established in each moment by the State.

However, the Foral Community may approve the models of declaration and revenue which shall contain at least the same data as the common territory and indicate time-limits for entry for each settlement period, which shall not differ. substantially of those established by the State Administration.

2. The levy shall be charged to the Foral Community where the final consumers referred to in the State rules make use of the products covered by the tax on installations, equipment or apparatus located within their territory.

When fluorinated greenhouse gases are the subject of self-consumption, the levy shall be the responsibility of the Community of Navarre when such self-consumption occurs on its territory.

In the rest of the cases not covered by the preceding paragraphs, the levy will be charged to the Community of Navarre when the taxpayer's establishment in which the taxable event occurs in its territory.

3. The refund to be returned shall be made by the administration in which the quota for which the refund is paid is entered in respect of the amount. "

" Article 40. Levy of applicable taxes and regulations.

1. The Rate on the Games of Luck, Envite or Azar will be exacted by the Foral Community when the taxable event takes place in Navarre.

2. The Tax Rate on Rifas, Tomballs, Gambling and Random combinations will be exacted by the Foral Community when their authorization must be carried out in Navarre.

3. The levy of the Tax on Gaming Activities shall be the responsibility of the Community of Navarre, the State Administration or both Administrations in proportion to the volume of operations carried out in each territory during the financial year.

The taxable persons shall be taxed, whatever the place in which they have their tax domicile, to the different Administrations in proportion to the volume of transactions carried out in each territory during the financial year.

The proportion of the volume of operations carried out in each territory during the financial year will be determined according to the relative weight of the amounts played for players resident in Navarre and in common territory. This ratio shall also apply to liquid quotas derived from game modes in which the player's residence and the fees for non-resident players in the Spanish territory cannot be identified.

By way of derogation from the foregoing paragraph, the levy of the tax resulting from the conduct of mutual sportsbook and state horse-race betting on which the residence of the player is not identified, shall be the responsibility of the Community of Navarre when the point of sale where the bet is placed is located on its territory.

4. The taxable persons shall submit the declarations-liquidations of the tax to the competent authorities for their levy, in which they shall in any event contain the applicable proportion and the quotas resulting from each of the Administrations. In any event, the taxable persons shall incorporate in the models to be submitted to each of the authorities concerned the totality of the information relating to the activities taxed by this tax.

5. The returns to be returned shall be made by the respective Administrations in the amount that corresponds to each of them.

6. In the taxes referred to in paragraphs 1 and 2 of this Article, when their authorization is to be carried out in Navarre, the Foral Community shall apply the same rules as that laid down at any time by the State in respect of the event. taxable and taxable person.

7. In the levy of the Tax on Gaming Activities the Community of Navarra will apply the same substantive and formal rules as those established at any time by the State.

notwithstanding the foregoing, in respect of the activities carried out by operators, organizers or by those who carry out the activity taxed by this tax with tax residence in their territory, the Community of Navarra will be able to raise the tax rates up to a maximum of 20 percent of the rates established at each moment by the State, an increase that will be applied exclusively on the proportional portion of the tax base corresponding to the participation in the game of tax residents in the territory of Navarro.

In addition, the Community of Navarre may approve the models of declaration and revenue which will contain at least the same data as the common territory, and indicate time limits for entry for each liquidation period, which does not differ substantially from those established by the State Administration.

8. The Inspection of the Tax on Gaming Activities shall be carried out by the organs of the Administration where the tax domicile of the taxable person or his representative in the case of non-resident taxable persons is provided, without prejudice to the cooperation of the other tax administrations concerned, and shall have effects vis-à-vis all competent administrations, including the proportion of taxation applicable to them.

However, it will be up to the State Administration to inspect the taxable persons whose tax domicile in the territory of the country has been established when the aggregate amount of the quantities played in the previous year exceeding EUR 7 million, and the proportion of those carried out in common territory, in accordance with the points of connection specified in paragraph 3 above, is equal to or greater than 75 per 100.

addition, it will be for the Community of Navarre to inspect taxable persons whose tax domicile is located in common territory when the aggregate amount of the quantities played in the previous year has exceeded EUR 7 million and have been made, in accordance with the connection points specified in paragraph 3 above, of all its operations in the territory of Navarre.

If, as a result of the inspection actions, a debt is incurred to be entered or an amount to be returned that corresponds to both Administrations, the recovery or the corresponding payment shall be made by the Acting Administration, without prejudice to the compensation provided by those persons.

The competent inspection bodies shall communicate the results of their actions to the other administrations concerned.

The provisions of the foregoing paragraphs shall be without prejudice to the powers of the Community of Navarre in the field of verification and investigation within its territory, without the possibility of its actions being economic effects vis-à-vis the taxpayer in relation to the final settlements carried out as a result of actions by the competent authorities ' bodies.

The proportions set out in the checks by the competent authority shall have effect against the taxable person in relation to the obligations settled, without prejudice to those which, after such checks, are agreed on a final basis between the two administrations. '

" Article 43. Discrepancies and change of tax domicile.

1. Natural persons resident in common territory or in the foral who have their habitual residence in one to the other, shall complete their tax obligations in accordance with the new residence where the latter acts as a point of connection.

In addition, where under the following number it is to be considered that there has been no change of residence, the natural persons must submit the accompanying declarations which correspond to the interest for late payment.

2. There will be no effect on changes of residence that aim to achieve lower effective taxation.

It will be presumed, unless the new residence continues on a continuous basis for at least three years, that there has been no change, in relation to the Income Tax of the Physical Persons and with the Tax on the Equity, where the following circumstances are present: first, that in the year in which the change of residence occurs or the tax base of the Income Tax of the Physical Persons is higher in, at least, a 50 percent to that of the year before the change; second, that in the year in which the The effective taxation of the Income Tax of the Physical Persons is lower than that which would have been paid in accordance with the regulations applicable in the territory of residence prior to the change and, thirdly, that it be returned to have the habitual residence in that territory.

3. Unless otherwise proved, it shall be presumed that there has been no change in the tax domicile of legal persons when in the preceding financial year or in the following year they become inactive or cease to be active.

4. The taxable persons of the Company Tax, as well as the permanent establishments of non-resident entities, will be obliged to communicate to both Administrations the changes in the tax domicile which give rise to changes in the competition to demand the tax.

In the Income Tax of the Physical Persons the communication shall be understood as produced by the presentation of the tax declaration.

5. The change of domicile of the taxpayer may be promoted by any of the administrations involved. The sponsoring administration shall transfer its proposal, with the necessary background, to the other to decide within four months on the change of address and the date on which the effects are to be rolled back. If the latter responds by confirming the proposal, the competent authority shall inform the taxpayer.

If there is no compliance, the procedure may be continued as provided in the following number of this article.

Prior to the referral of a change of address proposal, the Administration concerned may, in collaboration with the other Administration, conduct a census verification of the tax domicile.

When there is a change of business of domicile, after agreement of both administrations, or as a consequence of a resolution of the Arbitration Board, it will be presumed, unless proof to the contrary, that the new tax domicile so determined shall be maintained for the three years following the date of resolution.

6. The discrepancies between administrations that may occur with respect to the domicile of the taxpayers shall be resolved, after hearing of these, by the Arbitration Board, which is contemplated and regulated in Article 51 of this Convention. "

" Article 46. Reporting obligations.

1. The summaries of the withholding tax and the revenue to be paid shall be submitted, in accordance with their respective rules, to the competent authority for the charge of the withholding and revenue to be included in the deductions.

The entities that are depository or manage the collection of income of securities that in accordance with the corresponding regulations are obliged to the presentation of the annual summaries of retentions and income to account must make the same, in accordance with their respective rules, before the Administration to which the competence for the verification and investigation of those entities corresponds.

Entities that are taxable persons of the Company Tax payable by the State and the Foral Community shall submit annual summaries of withholding and income to account corresponding to the returns to which refer to Articles 10 (1) (f), 12.1 and 30.2 of this Economic Agreement, in accordance with the rules on the place, form and time limit for the submission of declarations by each of the competent authorities for their levy, including the total of the yields and the deductions corresponding to them in the declaration presented to each of them.

2. Statements intended to comply with the various obligations of general supply of legally required tax information shall be submitted, in accordance with their respective regulations, to the State Administration or to the the Foral Community, according to the following criteria:

(a) Trying to have tax obligations to develop business and professional activities, to the Administration to which the competence for the inspection of these activities corresponds.

b) Trying to tax authorities who do not carry out business or professional activities, according to whether they are domiciled in common or foral territory.

For the purposes of the preceding letters, in the case of a lying inheritance, a community of property or other entities lacking legal personality, such statements shall also be filed with the administration in which its members or members are fiscally domiciled.

3. The statements of a censal character shall be submitted, in accordance with their respective rules, to the Administration in which the person or entity required to carry out the tax and, in addition, to the Administration in which the said person is person or entity is required to submit, in accordance with the rules laid down in this economic agreement, any of the following:

a) Statement of withholding and income to account.

b) Declaration-settlement by the Company Tax.

c) Statement-settlement by Value Added Tax.

d) Declaration for the Tax on Economic Activities. "

" Article 47. Mergers and divisions of companies.

The special tax regime applicable to mergers, divisions, transfers of assets, exchange of securities and exchange of registered office of a European Company or a European Cooperative Company from one Member State to another of the Union European legislation approved by the Community of Navarra will have the same content as in the rules of common territory. "

" Article 67. Coordinating Committee.

1. A Coordinating Committee shall be set up, the composition of which shall be:

a) Six representatives of the State Administration.

b) Six representatives of the Foral Community appointed by the Government of Navarra.

2. The competencies of this Coordinating Commission will be:

(a) Carry out studies that are estimated to be appropriate for a proper structural and functional articulation of the foral regime with the state fiscal framework.

b) Facilitating uniform performance criteria, plans and software programmes to the relevant administrations.

c) Examine the assumptions or issues that have been raised in the field of inspection between the State Administration and that of the Foral Community.

d) Issue the reports requested by the Ministry of Finance, the Department of Economy and Finance of the Government of Navarra and the Arbitration Board.

e) Examine assessment problems for tax purposes.

f) Assess the adequacy of the tax legislation to the Economic Convention prior to its approval.

For these purposes, when, as a result of the exchange of draft regulations, observations are made in relation to the proposals contained in them, any of the two administrations may request, in writing and on a reasoned basis, the call by this Commission, in order to reach an agreement on the possible discrepancies in relation to the content of the tax legislation.

g) Resolve the queries that arise about the application of the connection points contained in the economic agreement. These consultations will be transferred by the receiving administration to the other administration for analysis, together with the motion for a resolution, within two months of its receipt. In the event that no comments on the motion for a resolution have been made within the following two months, it shall be deemed to have been approved. In the event of any comments and if not accepted, an agreement may be reached on the same within the coordinating committee. In any event, two months after the comments have been made without reaching agreement on the same, the Coordinating Committee, as well as any of the administrations concerned, may proceed to transfer the Disagreement to the Arbitration Board within two months.

(h) Determine the economic contribution of both the base year and the remainder of each five-year period referred to in Article 59 in order to raise it to both administrations for the adoption of the relevant agreement.

i) Fix the update of the figure referred to in the additional provision second for approval by both Administrations.

j) Establish the method for the quantification and settlement of indirect tax adjustments as regulated in Articles 65 and 66 of this Economic Convention.

k) Quantifying the annual, provisional and final assessment of the cost of the competences exercised by the Autonomous Community of Navarra in the field of police.

l) Agree on the commitments of collaboration and coordination on budgetary stability in the terms of the Organic Law 2/2012 of 27 April on budgetary stability and financial sustainability.

3. The Coordinating Committee shall meet, at least twice a year, one within each calendar semester and, in addition, when requested by any of the Administrations represented.

4. The Coordinating Committee may set up subcommittees to delegate to them the exercise of the powers contained in paragraph 2 of this Article. These Subcommittees shall be composed of three representatives of each Administration, being able to incorporate the advisors they deem appropriate with voice and without a vote, and the agreements adopted by them will be effective from the moment they are taken, without prejudice to subsequent ratification by the Coordinating Committee. "

" Additional provision third.

In the event of a substantial reform in the tax law of the State, both administrations, by common agreement, will proceed to the adaptation of this Convention to the modifications made and to the review, where appropriate, of the liquid contribution from the base year of the five-year period corresponding, in the form and amount, with effect from the date of the entry into force of the said reform. '

" Additional Disposition 11th.

1. The tax liability may apply for the total or partial extinction of the tax debts which the State Administration or the Foral Community can claim on the equivalent part of the debt actually paid on the other Administration, when the following circumstances are present:

(a) That the fees payable for the same economic operation, in the State Tax Administration or in the State Tax Administration are credited to the autoliquidations of indirect taxes. Foral community other than the one that claims the income.

In the case of autoliquidations to be entered, the payment of the result of self-validation must also be credited, as provided for in the general tax rules of each Administration.

For these purposes, income may have been made by the same taxpayer or by other entities that meet the circumstances referred to in Article 42 of the Trade Code to be part of the same group of companies, irrespective of the residence and the obligation to draw up consolidated annual accounts.

(b) the tax liability to be derived from quotas deducted or returned unduly in the context of indirect taxation, regulated by means of verification and with an amount of more than 600 million euro.

(c) a conflict of jurisdiction between the State Administration and the Foral Community has been brought before the Arbitration Board of the Economic Convention without its decision having determined the competence of any of the Administrations involved.

This requirement shall be deemed to be fulfilled where there has been a prior resolution of the Arbitration Board in the sense indicated in the preceding paragraph to be seen on the same tax, the same economic operation and the same contributors.

d) That there has been a non-sanctionable performance of the taxpayer or his/her group in the income and/or return request, made prior to the commencement of administrative actions leading to the regularization of the same tax liability for any of the tax administrations.

The provisions of the preceding paragraph shall not preclude the possible regularisation of any of the Tax Administrations.

e) that the entity that had made the income, the tax liability or its group of companies in the terms set forth in subparagraph (a) expressly renounces the right to the return of undue income from the Administration in which such income was made, as well as to any resource or claim in respect of the liquidation that was initially entered, already filed, or that could be filed.

This Administration will issue a certificate stating receipt of the waiver of the right to the return of undue income, as well as any recourse or claim in the face of the liquidation, crediting the fulfillment of the provided for in paragraph (a) and in accordance with the legal effects recognised in this provision.

The agreement of the Acting Administration will declare the extinction of the tax liability in the concurrent portion with the amount previously entered, once it has verified the fulfillment of the above requirements.

The jurisdiction to issue such an agreement, within the State Administration, will be the responsibility of the Director of the Collection Department of the State Tax Administration Agency. The competence to make such an agreement, within the Foral Community, shall be the responsibility of the Managing Director of the Tax Finance of Navarre.

2. The termination of the tax liability of the taxpayer for the fulfilment of the above requirements shall result in the termination of the conflict of jurisdiction as provided for in point (c), without any consequence of such termination. claim for this cause between Administrations. "

" Transient disposition fourteenth.

The transitional arrangements for new taxes agreed with effect from 1 January 2013 will be in accordance with the following rules:

First. The Autonomous Community of Navarra shall be subrogated to the rights and obligations, in tax matters, of the State Public Finance, in relation to the management, inspection, review and collection of the taxes referred to in this provision.

However, the State Public Finance shall exercise the above powers when it has carried out actions with a tax obligation prior to the entry into force of this Law, referring to the tax referred to in Article 31 bis of this Law. These powers shall be limited to the exercises to which the actions taken are concerned.

Second. The quantities cleared and incurred prior to 1 January 2013 for situations which would have been incurred by the Foral Community of Navarre to have agreed to the taxes referred to in this provision; and which are entered after 1 January 2013, shall correspond in their entirety to the Foral Community.

Third. The amounts due prior to 1 January 2013 and settled from that date on the basis of inspection measures shall be distributed in accordance with the criteria and points of connection of the taxes referred to in this Article. disposition.

Fourth. Where appropriate, the returns for liquidations practised or due to be made prior to 1 January 2013 shall be made by the Administration which has been competent on the date of the accrual, as the criteria and points of connection of the taxes referred to in this provision.

Fifth. The administrative acts dictated by the Community of Navarre shall be reclaimable in an economic and administrative way to the competent bodies of that Territory. On the contrary, those dictated by the State Administration, whatever their date, will be claimed before the competent organs of the State.

However, the corresponding income shall be attributed to the Administration that is a creditor in accordance with the rules contained in the above rules.

Sixth. For the purposes of the classification of tax infringements, as well as of the penalties which correspond to them in each case, the background to be valid and effective shall be valid on the basis of the facts of the case at the State Treasury with prior to the entry into force of the Convention of the Tributes referred to in this provision.

Seventh. The entry into force of the Convention of the Tributes referred to in this transitional provision shall not prejudice the rights acquired by the taxpayer in accordance with the laws previously issued to that date. "

" Transient Disposition fifteenth.

The charge for the Gaming Activities Tax that taxes the mutual benefit-benefit bets and the state horse-race bets will be the responsibility of the State Administration, as long as its marketing is carried out by the State Company of Lotteries and Gambling of the State, without prejudice to the financial compensation corresponding to the Community of Navarra, which will be calculated by applying as a connection point the territory in which the point of sale is located. The State Lotteries and Gambling Society of the State shall submit annual information statements of the amounts imputed to Navarre in accordance with Article 40.3 of the Economic Convention. "

" Transient disposition sixteenth.

Article 36 of the Economic Convention, in its original wording, adopted by Law 28/1990 of 26 December 1990, approving the Economic Convention between the State and the Community of Navarre, will remain in force in the from 1 January 2013, in relation to the Tax on Retail Sales of Certain Hydrocarbons in respect of non-prescribed exercises. '

" Transient disposition 17th.

Tax groups subject to common rules in tax periods initiated prior to 1 January 2015, which include dependent entities subject to the rules of the single regime of Navarra, may choose to maintain those entities in the tax group in the tax periods that are subsequently initiated, provided that the date of commencement of the tax group is not later than 31 December 2024 and the requirements laid down in Article 58 are met. of Law 27/2014 of 27 November 2014 on Corporate Tax.

The option mentioned in the previous paragraph should be exercised in the first tax period starting from January 1, 2015, and will be communicated to the Tax Finance of Navarra and the State Tax Administration. If the option is exercised, the tax group shall be bound by the option during the following tax periods, as long as the requirements of Article 58 are met and as long as the application is not waived. The waiver shall be exercised within 2 months of the end of the last tax period of its application and shall be communicated to both Administrations. '