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Conflict Report No. 2. Corporate Taxes. Non-deductibility of losses arising from the capital increase of a subsidiary

For the purpose of the provisions of Article 206.bis of Act 58/2003, of 17 December, General Taxation Act, and in accordance with the provisions of Article 194.6 of the General Regulation of the tax management and inspection actions and procedures and of the development of the common taxation procedure norms, approved by Royal Decree 1065/2007 of 27 July, a copy is hereby published of the report of the Advisory Committee on conflict, in application of the regulation regarding the taxpayer "Spanish Limited Company".  

The report states that the circumstances set out in Article 15.1 of the General Tax Law are met in relation to losses arising as a result of certain successive capital increases, capital reductions and new capital increases in a subsidiary.