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Conflict No. 14. Value Added Tax. Exempt activities Artificial filing of a company for the deduction of input VAT payments. Development and implementation of a platform necessary to provide an exempt financial service

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 "SOCIETY A".

The Report declares that there is a conflict in the application of the tax rule in a case of artificial interposition of an entity "SOCIETY A", to deduct the VAT payments incurred in the acquisition of goods and services for the development of the technological platform. “MARK A” necessary to provide the exempt financial service, in accordance with art. 20 One 18 of the LIVA, carried out by the entity "SOCIEDAD B".