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Conflict no. 11.Value Added Tax.Exempt activitiesArtificial splitting of language teaching activity into two companies for input VAT deduction purposes

For the purposes of the provisions of Article 206.bis of Law 58/2003, of 17 December, General Taxation and in accordance with the provisions of Article 194.6 of the General Regulations on tax management and inspection actions and procedures and on the development of the common rules for tax application procedures, approved by Royal Decree 1065/2007, of 27 July, a copy of the report of the Advisory Committee on conflict in the application of the rule relating to the taxpayer "CXZ" is hereby published.

The report states that there is a conflict in the application of the tax rules in the case of the simultaneous creation of two companies by the same partners, whereby one of them leases the premises where the activity is carried out and assumes the work necessary for their refurbishment, together with other costs, and transfers them to the other company, also providing it with other services, so that the latter can carry out the language teaching activity.