Established
The controlled public record identifies the EU/ERDF connection for the MYND/GC/836/P06 project.
OPEN FILE · AWARD ≠ PAYMENT ≠ FINAL ELIGIBILITY
GC/836/P06: from the public award to a complete investment, employment and control trail.
The question is not whether Hotel New Trend, S.L. received a published award. It did. The professional review asks which asset and perimeter were available, which costs were eligible, which other sources were declared, what employment was committed and verified, what was paid and what control, modification, issue or closure exists.
Published beneficiaryHotel New Trend, S.L.
Investment€11,469,714.00
Subsidy€3,440,914.20
Employment60 jobs
ERDF / FEDER · evidence → traceability → action
ERDF / EU funds: what is established, what remains open and what to do next
How to use this page. GC/836/P06 file: keep award, payment, final eligibility, employment, co-financing and closure separate.
Still to produce
Exact operation and percentage, eligible expenditure, invoices, payment/certification, verifications, audits, corrections and recovery.
Keep separate
RIC tax relief, RICPE investment, Regional Incentives, State aid and FEDER/ERDF are not one funding source.
Minimum production needed to close the ERDF question
- operation identifier and programme/fund
- beneficiary and title/availability record
- eligible-cost schedule and invoices/supporting records
- funding sources and other aid declared
- certifications, payments and verified employment
- verifications, audits, issues, corrections or recoveries
Directive (EU) 2024/1260 · FEDER/ERDF · EPPO/OLAF: Editorial action-routing aid; it does not establish fraud, corruption, duplicate funding, EU-budget loss, a PIF nexus, EPPO/OLAF competence or individual liability.
A guide enabling the file to be audited from beginning to end.
It organises the published award, general scheme requirements, expected production and dependencies with RICPE, RIC, ERDF, property and employment.
An assertion of an irregular subsidy or proved duplicate payment.
Coexisting instruments create a reconciliation requirement. They do not prove overlap, non-compliance, improper payment or intent without the cost, payment, aid and verification file.
THE CASE IN 7 MINUTES
Six gates an examining or control officer should be able to reconstruct.
Who applied for what
Beneficiary, group, real sponsor, location, memorandum, timetable and exact hotel project.
Title and availability
Which units, common areas, rights and works formed the investment; what remained outside and under which primary source.
Own resources and other sources
Self-financing, RICPE/RIC, banking, suppliers, other aid and treatment of related-party transactions.
Eligible cost and payment
Contract, supplier, invoice, line item, asset, date, bank payment and exclusion of ineligible cost.
What the 60 means
Person, employer, registration, period, hours/FTE, net creation or maintenance, outsourcing and retention.
Verification, settlement and closure
Interim/final conditions, inventory, inspection, payment, modification, non-compliance, sanction, correction or recovery.
CONTROL FRAMEWORK
The general scheme already contains concrete questions.
Viability and self-financing
The Regulation requires technical, economic and financial viability and generally at least 25% self-financing, subject to the rules applicable to the specific file.
Start of investment
The application must precede the start of investment and the first firm commitment affecting the project, subject to the applicable confirmation and rules.
Assets and related parties
Eligible material assets must be identifiable; related-party transactions require the treatment and, where applicable, express authorisation provided in the file.
Temporal control: the applicable version must be fixed by the dates of application, award, modification, execution and settlement of GC/836/P06. This page uses the official framework to formulate questions; it does not replace file-specific legal analysis. Royal Decree 899/2007 · BOE →
WHAT CHANGED?
The award is one station in a longer chain.
BEFORE / APPLICATION
Project, beneficiary, title/availability, investment, own resources, other aid, employment and timetable declared.
WHAT WAS VERIFIED?
AFTER / OUTCOME
MYND Yaiza operating, published support and ERDF identified. The public record still lacks operation ID, certified cost, payments, verified jobs and closure.
Rule: a published award proves the award and stated figures. It does not by itself prove full disbursement, final eligible expenditure, employment compliance or absence of overlap.
DECISION TREE
From the award to a reasoned conclusion.
Were the asset and beneficiary eligible?
Property/right map, availability, group, related parties and project.
Did costs and finance match approval?
Budget, other aid, invoices, payments and source-and-use.
Were conditions and employment met?
Interim/final reports, inventory, workforce and verification.
What outcome followed?
Settlement/payment, modification, closure, non-compliance, sanction, correction or recovery.
FILE PRODUCTION
Minimum list for a reproducible review.
- Complete application and project memorandum.
- Individual award, acceptance and conditions.
- Asset map and title/availability evidence.
- Group, beneficial ownership and related parties.
- Finance plan and self-financing.
- Other-aid and cumulation declarations.
- Valuations and approved budget.
- Contracts, suppliers and authorisations.
- Invoices and bank payments.
- Eligible-cost schedule and exclusions.
- Asset inventory.
- Project, deadline or holder modifications.
- Interim and final conditions.
- Regional authority report.
- Administrative and on-the-spot checks.
- Workforce: persons, FTE, periods and employer.
- Partial/final settlements and payments.
- Inspection, issues and representations.
- Non-compliance, sanction, correction or recovery.
- Communications with ERDF/SNCA/IGAE and other bodies.
Financial reconciliation: the 20 September 2023 RICPE prospectus totals €6,570,713.56; a separate accounts reconstruction gives €6,573,703.10. The €2,989.54 difference must remain attributed and open. Neither figure is automatically added to the subsidy.
OPEN KIMONO · BEST PRACTICE AND ITS OPPOSITE
A public-aid file should be explainable without relying on institutional trust.
Open and reproducible Regional Incentives control
- Beneficiary, group, asset and perimeter identified.
- Requirements and applicable rule version fixed.
- Other aid and finance reconciled before and after award.
- Invoice, payment, asset and eligible cost linked.
- Employment proved by person and period.
- Modifications, inspections and decisions reasoned.
- Issues and exculpatory evidence preserved.
The opposite practice
- Award treated as payment and final compliance.
- Unitary hotel project without a property/right map.
- Different instruments used to avoid cost reconciliation.
- Employment repeated in headlines without population or period.
- Related transactions without an authorisation or valuation trail.
- File closed without inventory, payment, verification or compliance decision.
Boundary: this comparison does not assert that GC/836/P06 contains every negative deficiency. It defines the documentary test that can confirm, correct or reject the concern.
WHO DOES WHAT
Policy, processing, inspection and funds control are not one function.
Subdirectorate-General for Regional Incentives
Executes state policy and supports the Regional Incentives Governing Council within the currently published official functions.
Competent regional authority
Receives and analyses evidence of interim/final conditions and issues the reports provided by the applicable scheme.
Inspection and Control
The published state structure assigns this function inspection/checks of incentives, non-compliance, sanctions and proposed resolution, without prejudice to IGAE.
Competence warning: a favourable decision by one body does not automatically resolve questions belonging to another: title, eligibility, tax, ERDF control, insolvency and criminal responsibility retain their own records and standards.
CONNECTED ROUTES
CNMVRICPE governance, information, DD and re-entry.RICPEOrigin, conflict, controls and funding.SNCA / ERDFOperation, expenditure, certification, audit and correction.RIC / taxSeparate materialisation and compatibility.ReconciliationAsset, invoice, job and euro.Clean roomOne factual source, different competences.BOEPublished GC/836/P06 award.
25 October 2026 · receipt-verified presentation and source-qualified party corrections
Registered supplements: Gil Marer reports recovery of five document categories
The Madrid supplement was registered as REGAGE26e00091804140 on 25 October at 02:15:58. The CTBG 3929/2026 supplement was registered as REGAGE26e00091804303 at 02:49:03, following the response registered on 24 October as REGAGE26e00091778502. Madrid retains its original registration REGAGE26e00091776746 and continuations REGAGE26e00091777235 and REGAGE26e00091777533. Times are those printed by the electronic headquarters; no timezone offset is inferred.
What the filed account now corrects
Gil Marer’s supplements state that, after the morning submissions on 24 October, he located, downloaded and examined copies corresponding to five categories: a receipt concerning HNT’s application; the published award; an individual Council assessment sheet; valuation criteria; and the communication inviting HNT to make representations. Current non-obtainment of those copies is therefore no longer maintained. This does not establish when each file was first uploaded or historically accessible, or that the complete aid file was delivered.
- Authentication: later portal occurrence 9118714 of the 21 October ministerial report has a visible CSV wrapper. The earlier examined copy and the later occurrence remain separate. Their formal or binary differences do not themselves establish forgery, manipulation or personal authorship.
- Contrary and limiting evidence: the 9 April decision directed the applicant to the private portal for annexes; the 10 April certificate records opening of the notification; and the 9 June response addressed the access incident. These records must be considered alongside the April complaint. Opening a notification does not certify access to every annex, and reporting an April incident does not prove that it persisted until October.
- Scope and versions: the individual actilla of 26 April 2023 is not automatically the full Council minutes; the received 2025 consolidation of criteria and the separately recovered 21 September 2022 version are distinct sources; HNT’s hearing invitation is not its 4 March opposition or annexes.
Ownership, works and personal attribution remain separate tests
The actilla proposes an ownership condition at the end of the grant’s validity period. That condition alone does not require completed ownership at application or award; it neither transfers civil title nor authorises occupation or damage to another owner’s property. The individual deadline, extensions and compliance require their own records. The Ministry’s 7 June 2022 entry does not by itself establish the first valid regional application or which earlier work formed part of the aided investment.
The 2022 criteria exclude demolition costs from subsidy, but neither the civil-works budget nor earlier works alone establish subsidised demolition, payment or criminality. The corporate Dyrecto channel does not establish David Hoys Bodelón’s personal mandate, receipt, knowledge or authorship. Laura Patricia Acosta Matos is the canonical identity; correcting a source-name error does not extend unproved attribution.
What remains open: original application and project, individual award and conditions, HNT’s actual opposition and powers, file-by-file historical access logs, and the relevant budget, verification and payment records. The supplements maintain the qualified allegations and the CTBG statement NO DESISTO. Registration establishes presentation and attachment identity, not internal incorporation, admission, an opened investigation, eligibility compliance or a merits finding. Prior adverse judicial and fiscal decisions remain part of the record.
Both receipts were compared with the privately preserved filed bytes: Madrid’s two listed attachments and CTBG’s four match their SHA-512 fingerprints. The CTBG annex is the same 131-page compilation filed in Madrid, not independent corroboration. Authored renderings and actual filed binaries retain separate provenance. Gil Marer’s filed CTBG supplement describes the earlier complaint copy as textually and visually identical despite its different bytes; receipt verification does not establish that content-equivalence account. Protected originals and unnecessary personal data remain private.