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 reports of the Advisory Commission on conflict in the application of the tax rule is published.

Conflict Report No. 20. The operation analyzed in the report consists of a purchase of own shares by COMPANY 1 from three of its partners (BROTHER 1, BROTHER 2 and BROTHER 3) to carry out a subsequent capital reduction with amortization of the acquired shares. This transaction is declared by the partners as a transfer that generates a capital gain, not subject to withholding tax. 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 clearly artificial and improper and do not produce any relevant legal or economic effects other than tax savings, the usual or proper operation being a capital reduction with a return of contributions to the partners.

Conflict Report No. 20 bis. The operation analyzed in the report consists of a purchase of own shares by COMPANY 1 from three of its partners (BROTHER 1, BROTHER 2 and BROTHER 3) to carry out a subsequent capital reduction with amortization of the acquired shares. This operation is declared by the partners as a transfer that generates a capital gain, to which they apply the ninth transitional provision of Law 35/2006 on Personal Income Tax. 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 clearly artificial and improper and do not produce any relevant legal or economic effects other than tax savings, the usual or proper operation being a capital reduction with a return of contributions to the partners.

Conflict Report No. 20 ter. The operation analyzed in the report consists of a purchase of own shares by COMPANY 1 from three of its partners (BROTHER 1, BROTHER 2 and BROTHER 3) to carry out a subsequent capital reduction with amortization of the acquired shares. This operation is declared by the partners as a transfer that generates a capital gain, to which they apply the ninth transitional provision of Law 35/2006 on Personal Income Tax. 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 clearly artificial and improper and do not produce any relevant legal or economic effects other than tax savings, the usual or proper operation being a capital reduction with a return of contributions to the partners.

Conflict Report No. 20 quater. The operation analyzed in the report consists of a purchase of own shares by COMPANY 1 from three of its partners (BROTHER 1, BROTHER 2 and BROTHER 3) to carry out a subsequent capital reduction with amortization of the acquired shares. This operation is declared by the partners as a transfer that generates a capital gain, to which they apply the ninth transitional provision of Law 35/2006 on Personal Income Tax. 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 clearly artificial and improper and do not produce any relevant legal or economic effects other than tax savings, the usual or proper operation being a capital reduction with a return of contributions to the partners.