The declared operations consist, first of all, of the separation of two partners (MMDD and PPAA) of the entity DSM SLU through the transfer of their shares to the company, agreeing on deferred collection. Secondly, a real estate sale transaction is agreed upon by the company DSM SLU to a family intermediary company (FRP SL) of which the transferors of the shares and their children are the owners, with the payment also being determined in a deferred manner and DSM being accepted. SLU to the special cash criterion regime.

The Report declares that there is a conflict in the application of the tax law as it is a case of artificial interposition by a family company, on the part of the buyer, in order to improperly deduct the VAT that was taxed on the sale of the properties