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Conflict No. 11. Value Added Tax. Exempt activities Artificial splitting of language teaching activity in two companies for the deduction of input VAT

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 "CXZ".

The Report declares that there is a conflict in the application of the tax law in the event of simultaneous creation of two companies by the same partners, with the aim of one of them renting the premises where the activity is carried out and assuming the works necessary for its conditioning along with other costs and transfers them to the other company, also providing other services, so that the latter carries out the activity of language teaching.