We study the X-ray spectral variability of the Narrow Line Seyfert 1 galaxy NGC 4051 as observed during two XMM-Newton observations. The data show evidence for a neutral and constant reflection component and for constant emission from photoionized gas, which are included in all spectral models. The nuclear emission can be modelled both in terms of a ``standard model (pivoting power law plus a black body component for the soft excess) and of a two--component one (power law plus ionized reflection from the accretion disc). The standard model results indicate that the soft excess does not follow the standard black body law. Moreover, although the spectral slope is correlated with flux, which is consistent with spectral pivoting, the hardest photon indexes are so flat as to require rather unusual scenarios. These problems can be solved in terms of the two-component model in which the soft excess is not thermal, but due to the ionized reflection component. The variability of the reflection component from the inner disc closely follows the predictions of the light bending model, suggesting that most of the primary nuclear emission is produced in the very innermost regions, only a few gravitational radii from the central black hole. (abridged)
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