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 rule relating to the taxpayer MATRIZ PROPIETARIA SL.

The report declares that the circumstances established in article 15.1 of the General Tax Law exist in relation to the intervention of the parent entity in the activity of the subsidiary entity of the interested party. This subsidiary entity carries out an activity essentially exempt from VAT and rents the flats and apartments that it then exploits by renting them to third parties.  In the opinion of the Advisory Commission, the intervention of the parent company in the acquisition and works carried out on the acquired properties is strictly due to improperly overcoming the impossibility of deducting and, ultimately, recovering the VAT contributions paid, by the subsidiary whose activity is essentially exempt from VAT.