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 Regulation of the actions and procedures of tax management and inspection and development of the common rules of the procedures for the application of taxes, approved by Royal Decree 1065/2007, of July 27, a copy of the report of the Advisory Commission on the conflict in the application of the rule relating to the taxpayer, natural person "PPAA" is hereby published.

The operations consist, firstly, in the separation of two partners (MMDD and PPAA) from the entity DSM SLU by means of the transfer of their shares to the company, agreeing to deferred payment and adhering to the special rule of temporary imputation of forward or deferred price operations. At the same time, a sale of real estate is agreed by the company DSM SLU to a family company (FRP SL) owned by the transferors of the shares and their children, with payment also being determined on a deferred basis.

It should be noted that this same operation is the subject of analysis in the reports of the Advisory Commission on Conflicts in the Application of the Standard published under numbers 13, 13 bis and 16 bis.