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Publication of a copy of the Conflict report No. 9. Corporation Tax. Financial expenses derived from a loan intended for the return of an issue premium

For the purposes of the provisions of article 206.bis of Law 58/2003, of December 17, General Tax and in accordance with the provisions of article 194.6 of the General Regulation of the actions and procedures of tax management and inspection and of development of the common rules of tax application procedures, approved by Royal Decree 1065/2007, of July 27, a copy of the report of the Advisory Commission on conflict in the application of the relative tax rule is being published to the taxpayer "PQ HOLDING".

The report states that there is a conflict in the application of tax regulations in relation to a set of corporate operations that, in the context of the transfer of a part of PQ SA to an independent investment group, involve the interposition of several companies and the generation of a share premium whose partial return is financed with a loan supported by the Spanish group.