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 Regulations 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 conflict in the application of the tax rule relating to the taxpayer, YY, SA is published.

The operation analyzed in the report consists of the artificial interposition of a company, "YY SA", to deduct the VAT quotas borne by the works carried out in properties that are exploited by the entity "XX SA", user and beneficiary of them for the performance of the teaching activity. The Advisory Commission's Report on conflict in the application of the tax rule concludes that, when the operations are considered as a whole, they are artificial and their only relevant effect is that they allow "YY SA" to deduct the input VAT that "XX SA" could never have deducted, since the teaching activity is exempt from VAT , and therefore does not grant the right to deduct the input VAT incurred in the acquisition of goods and services related to it.