As has become customary in recent years, taxpayers (and their advisors) have to wait for the Tax Administration to issue its opinion on a recently enacted regulation that the legislator (or more likely, the drafters of the legislation) has not been able to express clearly enough to avoid generating conflicts, which are generally unnecessary. Article 25 of Law 27/2014, on Corporate Income Tax (LIS), presents one such case: subparagraph b) of paragraph 1 refers to the allocation of the capitalization reserve, which is one of the requirements