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 report of the Advisory Committee on the conflict in the application of the rule relating to the taxpayer "SOCSL ESP" is hereby published.

The report states that the circumstances established in article 15.1 of the General Tax Law exist in relation to the withholding operations on account of Income Tax for Non-Residents derived from the payment of financial interest on a loan received from a Dutch company belonging to the same Group as the taxpayer, limiting the tax effects that must be regularized to the requirement of the applicable withholding in the CDI with the USA in the periods subject to verification.