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Published copy of the report on Dispute nº 9.Corporation Tax.Financial expenses arising from a loan for the repayment of a share premium

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 tax regulations relating to the taxpayer "PQ HOLDING" is hereby published.

The report states that there is a conflict in the application of the tax rule in relation to a set of corporate transactions which, in the context of the transfer of part of PQ SA to an independent investor group, involve the interposition of several companies and the generation of a share premium, the partial repayment of which is financed by a loan borne by the Spanish group.