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 "COMPANY C".

The Report declares that there is a conflict in the application of the tax rule in a case of artificial inclusion of a purchase option in a housing lease contract by the promoter of the same, "SOCIEDAD C", at its discretion. partner, with the sole purpose of allowing the deduction of the fees borne by the company in the construction, conditioning and maintenance of the home, intended for the personal enjoyment of the partner and his family. The inclusion of the purchase option in the lease contract determines that it becomes subject and non-exempt and, therefore, enables the deduction of the fees incurred in the acquisition of goods and services intended for the indicated home.