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 "Z INMOBILIARIA".

The Report declares that there is a conflict in the application of the tax norm in a case of artificial creation and interposition of an entity, Z INMOBILIARIA, which carries out the construction of an educational complex and the acquisition of the necessary furniture, to rent it in non-market conditions to another entity linked without the right to deduct Input VAT, Z EDUCACIÓN, for its exploitation as a school in application of a special educational method.