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What to Do Before the Start-Up of the New Single Authorized Electronic Address - DEHU
It is possible that recently your company and also professional or business individuals have received a notice from the Tax Agency that a change will soon take place in the Enabled Electronic Address that will mean that notifications will no longer be received in the mailbox current and to be received in a different one.
For practical purposes: what does this mean? and What should be done, if anything is to be done?
The answer is yes, indeed, all those who are obliged to receive electronic notifications must make changes to continue receiving them and to be able to access the Administration's electronic notifications in the future.
As these are technical issues where computer issues are mixed with other more legal ones, we will explain the changes step by step.
To begin: what was the situation so far?
Until now, when the Tax Agency issued a notification to someone obliged to receive it electronically, it sent it to the Enabled Electronic Address, which meant that taxpayers had to enter the address notifications.060.es to access its content.
It is essential to know that, if ten days after the notification the taxpayer does not open it, it is considered notified, with the pertinent economic and legal consequences (loss of deductions for not having justified them, elapse of the period to appeal, ... ).
To open it, the taxpayer has two ways:
- Go to portal 060, where notifications are received from many Administrations (basically state and also some Town Councils, leaving those of the Autonomous Communities outside this portal, since they usually use their own)
Due to its special importance, it should be mentioned that, if it was a notification from the Tax Agency, everything and could be accessed through the previous system, its content could also be opened through the Tax Agency's own website in the sub-section of notifications .
- In the case of notifications from Administrations not attached to 060, the taxpayer had to periodically enter their own portal (for example, in the case of the Generalitat de Catalunya in the eNotum).
An important point is the possibility of configuring a notification system for notifications via email, which some portals allow and others do not.
Therefore, until now, if previously, the taxpayer configures, with his electronic certificate, in his mailbox of Portal 060, an email address, at the time the Tax Agency issues a notification, the taxpayer receives a Email advising that a notification has just been received and that there is a maximum of 10 days to open it.
But beware: if this email is not received (due to an error, going to spam, SPAM, or for any other reason), the notification after ten days is considered equally issued and correctly communicated. That is why Manubens has always insisted on the importance of carrying out a periodic control of the portals, without fully trusting in receiving a prior notice by mail.
And what will be the current situation, both temporary and future?
On September 6, 2021, article 42 of RD 203/2021 came into force, which regulates that all state-level administrations must issue their electronic notifications in the Enabled Electronic Address Unique ( https://dehu.redsara.es/ ).
This means that, to continue receiving prior notice by email of the receipt of an electronic notification, after the transitional period that we will later mention, we must enter the new unique enabled address and configure / communicate again the email address where we want to receive the notices.
To do this, simply enter https: // dehu. redsara.es/ with your own electronic certificate and in the "Personal data" section indicate the email where the notification of the notification is requested to be produced.
It should be emphasized that by making this change, only notifications (basically of a state nature) that use the DEHU portal will be received via email https: // dehu .redsara.es / (which replaces portal 060, which will foreseeably stop working after the transitional period).
Given the importance of this change, and the possibility that due to confusion, neglect or ignorance in technical matters, notifications may cease to be received (with the important and burdensome effects mentioned above) the Tax Agency has established a transitional period that affects only your notifications, until next April 4, 2022 , in which the Tax Agency will issue the notifications in both electronic addresses (Unique Enabled Electronic Address https://dehu.redsara.es/ and in the Enabled Electronic Address-Portal 060). Of course, as of April 4, it will only issue electronic notifications to the new Single Enabled Electronic Address .
This means that, until April 4, if no change is made, you will continue to receive a notice in the mail that was configured in 060, mail that will no longer be received from the indicated date of April 4.
The importance of periodically opening notification portals
As already indicated above, even if an email address is configured to notify us of the receipt of a new electronic notification, if for any reason ( including technical reasons at the time of receiving the notice email) the portal is not accessed , after 10 days from the issuance of the notification it is It will be considered received and communicated , so it will begin to compute the legal term that applies in each case.
It is for this reason that our advice as a firm is to periodically consult, at least once a week, the Enabled Email Address to verify that no notification has been received. In the current transitional period, we recommend consulting both the Enabled Electronic Address and the Unique Enabled Electronic Address on a weekly basis.
As a reminder, those required, among others, to communicate electronically with the public administration and therefore to receive notifications in this way are the following:
- Corporations and Limited Companies
- Any natural person who for the exercise of their professional activity requires compulsory membership. (notaries, lawyers, architects, doctors, pharmacists, etc.).
- Any representative, physical or legal, of a person obliged to receive electronic notifications.
- Communities of goods.
- Communities of owners.
- Permanent establishments and branches of non-resident entities in Spanish territory.
- Companies whose NIF begins with the letter V.
- Temporary Union of Companies.
- Taxpayers registered in the registry of large companies.
- Taxpayers who are taxed by the corporate tax consolidation regime.
- Taxpayers who pay under the special regime of the group of VAT entities.
- Taxpayers registered in the VAT Monthly Refund Regime (REDEME).
- Taxpayers authorized to submit customs declarations through the electronic data transmission system (EDI).
What can Manubens do to facilitate regular monitoring of the most important and common notifications?
With the aim of facilitating our clients weekly consultation of the enabled email addresses and, above all, avoiding that they may be notified of communications from the administration due to failure in communication via email, Manubens has a service for which is in charge of consulting the Enabled Electronic Address weekly (during the transition period we will consult both addresses) and is notified individually at the time that any notification is received to report it and decide together the best response.
In order to manage the service, the office has software that consults the notifications that may exist in the different electronic addresses with which it is compatible and if it finds any notification, download it. The software is constantly updated and is increasingly able to consult more public administrations. In fact, they are already finalizing the version that will add the possibility of consulting the Unique Enabled Electronic Address (DEHU).
Thus, the program will consult the notifications of 8,291 public organizations through its connection to the DEHU (currently the DEH), and directly those corresponding to the portals of entities such as:
- Authorized Electronic Address (Tax Agency among other organizations)
- Social Security
- General Directorate of Traffic
- Generalitat de Catalunya / eNotum
- Community of Madrid
- Junta de Andalucía
- Generalitat Valenciana (entities of the Valencian Community)
- Xunta de Galicia
- Junta de Castilla y León
- Autonomous Community of the Basque Country
- Provincial Council of Bizcaia
- Provincial Council of Gipuzkoa
- Provincial Council of Seville
- Las Palmas de Gran Canaria City Council
Weekly a person from the office consults with the program if there is any notification and if there is an incident in the consultation, the program issues a notice of possible failure and the person in charge performs the check manually to ensure at all times that it does not exist no notification received.
If you are interested in more information or if you have doubts about the changes that will take place, please contact the office and we will be happy to help you.
One of the things Mr. Balcells like most about his job is when you get a safe, legal and fair tax situation for the sake of the taxpayer's tranquility and economy, both in previous structuring and planning, and when certain criteria have to be defended before Tax administration.
As a lawyer, he always try to put himself in the place of the one who asks for advice, so that all the options or alternatives that are considered as solutions, are those that would adopt at a personal level if the interested party is himself.