Conflicts in applying tax regulations
Access the reports of the advisory Committee on Conflict in the application of the Standard. There is a conflict in the application of the tax rule when the taxable event is totally or partially avoided or the tax base or the tax debt is reduced by means of acts or transactions in which certain circumstances concur. A favourable report from this advisory Committee is required for a declaration of conflict in the application of the tax rule.
Reports of the Advisory Commission
- Conflict no. 1. Corporation Tax. Financial expenses for intragroup financing (288 KB - pdf )
- Conflict No. 2. Corporation Tax. Non-deductibility of losses arising from capital increases of a subsidiary (1,158 KB - pdf )
- Conflict no. 3. Value Added Tax. Exempt activities Artificial filing of a company for deduction of input VAT (247 KB - pdf )
- Conflict No. 4. Withholdings on account of Non-Resident Income Tax on interest paid to a Dutch entity of the Group (791 KB - pdf )
- Conflict No. 5. Value Added Tax (454 KB - pdf )
- Conflict No. 6. Value Added Tax. Exempt activities Artificial filing of a company for deduction of input VAT. Tenant company (831 KB - pdf )
- Conflict No. 6 bis. Value Added Tax. Exempt activities Artificial filing of a company for deduction of input VAT. Leasing company (449 KB - pdf )
- Conflict No. 7. Value Added Tax. Artificial interposition of a community of goods to obtain refunds of input VAT on exempt activities (584 kb - pdf )
- Conflict No. 8. Non-Resident Income Tax. Transfer of participation in a subsidiary using a chain of transmissions between group companies (1.01 MB - pdf )
- Conflict No. 9. Corporation Tax. Financial expenses derived from a loan intended to repay a share premium (965 KB - pdf )
- Conflict No. 10. Value Added Tax. Exempt activities Artificial filing of a company for the deduction of input VAT (349 KB - pdf )
- Conflict No. 11. Value Added Tax. Exempt activities Artificial splitting of language teaching activity in two companies for the deduction of input VAT (303 KB - pdf )
- Conflict No. 12. Value Added Tax. Exempt activities Artificial filing of a company for the deduction of input VAT. Leasing of housing to private individuals (1,176 KB - pdf )
- Conflict No. 13. Value Added Tax. Filing of a family company for the improper application of the special cash basis regime. Purchasing company (675 KB - pdf )
- Conflict No. 13bis. Value Added Tax. Improper application of the special regime of cash criteria in a cash purchase and sale of real estate. Selling company (646 KB - pdf )
- Conflict No. 14. Value Added Tax. Exempt activities Artificial filing of a company for the deduction of input VAT payments. Development and implementation of a platform necessary to provide an exempt financial service. (330 KB - pdf )
- Conflict No. 15. Value Added Tax. Exempt activities Artificial inclusion of a purchase option in a property lease contract for the deduction of input VAT payments. Leasing of a property to a natural person by the development company under its control. (964 KB - pdf )