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Publication of a copy of the Conflict Report No. 9. Corporation Tax. Financial expenses arising from a loan intended for the repayment of an issue premium

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

The report states that there is a conflict in the application of the tax rules in relation to a set of corporate operations which, 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 an issue premium whose partial repayment is financed with a loan supported by the Spanish group.