Publication of a copy of the Conflict report No. 8. Non-Residents' Income Tax. Transfer of participation in a subsidiary using a chain of transmissions between group companies

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 taxpayer "M CORPORATION".
The Report declares that there is a conflict in the application of the tax law in the event of the transfer by a US company of its Spanish subsidiary through a chain of operations between group companies, evading taxation by relying on the provisions in the Protocol to the Convention between the Kingdom of Spain and the United States of America to avoid double taxation and prevent tax evasion with respect to income taxes.