Established
The controlled public record identifies the EU/ERDF connection for the MYND/GC/836/P06 project.
100% TRANSPARENCY · QUESTIONS TO THE BODY WITH THE COMPETENCE AND THE FILE
Series F, Series G and Decree 224/2022: let the record show what each institution authorised and what each euro financed.
This page does not publish a finding of fraud or illegality. It publishes a concrete timing and documentary question, the legitimate explanations that may exist, the records capable of resolving it, and the authority competent to answer.
Did Decree 224/2022 and the AEAT binding report of 17 November 2022 expressly cover Series F — €1,598,849.32 for Hotel MYND Yaiza — Series G — €4,974,853.78 for employment creation — both, or was there a second/amended authorisation?
ERDF / FEDER · evidence → traceability → action
ERDF / EU funds: what is established, what remains open and what to do next
How to use this page. Series F/G: link each authorisation, purpose, drawdown and use to the asset and the other declared instruments.
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.
Series F
€1,598,849.32
RICPE's audited 2023 accounts identify 253 shares in Series F — Hotel MYND Yaiza project for this amount and a participatory loan of the same amount to Hotel New Trend, S.L.
Question: what precisely was the money used for, which eligible expenditure supported the loan, and which administrative record authorised that use?
Series G
€4,974,853.78
The same accounts identify 785 shares in Series G — MYND Yaiza Employment Creation for this amount and participatory financing to HNT for the same amount.
Question: was this phase already included in the 2022 application/report/decree, or was it subject to a separate act, amendment, file or later control?
Evidential boundary. The two specific series are documented. The complete public chain of the idoneidad application, AEAT report, Decree 224/2022 and any amendments linking each series to the administrative authorisation has not yet been reconstructed.
The timing question: refurbishment, idoneidad, loan and opening
2020Sun Park appears in RICPE materials as an investment/refurbishment project.
20 Jul 2021RICPE records 54 CAM properties, LPB/third-party assets, unsigned LOI and full DD not yet started.
29 Dec 2021A prior capital-increase decision linked to Sun Park is referenced.
21 Feb 2022Deed/adjudication of the enumerated insolvency perimeter.
17 Nov 2022AEAT binding report referred to by RICPE and confirmed as an antecedent in Resolution 28/2026.
1–16 Dec 2022Idoneidad on 1 Dec; Series F/loan €1.598m; RICPE places opening after reform/transformation on 16 Dec.
2023Series G / employment: €4.975m.
If Series F was refurbishment financing and the hotel was already at the point of opening after reform/transformation on 16 December, which works, invoices, outstanding liabilities, earlier eligible expenditure, permitted reimbursement or bridge financing did the €1,598,849.32 loan actually finance?
A lawful explanation may exist. That is why the application, invoices, works certificates, payments and applicable rule should be produced.
Four open scenarios — none is presumed
1 · One file covered both phases
The application, AEAT report and final act should then identify the two phases, instruments, amounts, timetable and authorised uses.
2 · Separate authorisations existed
The application, binding report, resolution/decree, date, amount, instrument and file for each phase should be identified.
3 · The approval was amended
The amendment, date, reason, scope and file should be identified, showing what changed from the original approval.
4 · No second act existed
The competent authority and RICPE should identify the legal/documentary basis on which each series and use was treated as covered by the existing authorisation.
Who must answer what
| Authority / actor | Why it can answer | Precise question | Records that resolve it |
|---|---|---|---|
| Canary Islands Council of Government | The official procedure identifies the Council of Government as the body that resolves supervision/idoneidad of these issues. | Which instruments did Decree 224/2022 cover exactly? Series F, Series G, both? Was there an amendment, second decree or complementary act? | Full decree, annexes, proposal submitted to Council, notification and amendments. |
| Tax Policy Service / Vice-Ministry of Finance | The official procedure identifies the Tax Policy Service as the processing body. | What project, entities, timetable, amount, instruments and uses did RICPE describe in its application? What changed between application and execution? | File 02/2022 index; application; project memorandum; requests; reports; proposal; AEAT referral/response; amendments. |
| AEAT | Article 15 requires a binding AEAT report for the supervised issue. | Which instruments/project did the 17/11/2022 report assess? How did it treat refurbishment expenditure already incurred, if any, and the later employment phase? | Full or segregable report; metadata; application and annexes received; clarifications; earlier/parallel reports; communications with Canary Islands. |
| CNMV | RICPE is a registered/supervised SCR and its audited accounts form part of the regulated record. | What information on idoneidad, use of funds, conflict, Series F/G and corrections to 2020–21 representations was available to governance/control functions and investors? | Accounts, regulatory communications, prospectuses, corporate approvals, investor information and corrections. |
| RICPE / Board / Control Unit | They hold or should identify the underlying corporate and contractual records. | What justified re-entry, Series F and Series G? Which invoices/expenditure did they finance? What did Control receive on title, works, litigation, third parties and other funding? | Idoneidad application, DD, control report, minutes, abstentions, contracts, drawdowns, bank account, invoices, certificates and investor communications. |
| HNT / CAM | Borrower and related/promoter entities in the described perimeter. | Who funded the works before the December 2022 loan? Which liabilities or costs remained outstanding? Was there bridge financing or reimbursement? | Ledger, suppliers, invoices, certificates, bank statements, bridge loans, payments, capitalised costs and sources/uses. |
Documents that could answer this tomorrow
- Full Decree 224/2022 and annexes.
- Complete index of Canary Islands file 02/2022.
- Original RICPE application and project memorandum.
- Entities named as implementers/borrowers.
- Amounts, instruments and timetable in the application.
- AEAT binding report of 17/11/2022.
- Canary Islands referral to AEAT and annexes.
- Requests for clarification and responses.
- Tax Policy Service/Vice-Ministry proposal.
- Any amendments, extensions or later acts.
- Series F and G corporate approvals.
- Subscription documents and value dates.
- Participatory loan agreements.
- Transfer orders and drawdowns.
- Refurbishment invoices and works certificates.
- Accrual/payment dates for each invoice.
- Bridge/supplier financing, if any.
- Source of funds used before December 2022.
- Control Unit report.
- Conflict/abstention minutes.
- Investor communications for each phase.
- Reconciliation with other aid, incentives and employment commitments.
Evidence standard. No authority is being asked to adopt Project Sun Rock's hypothesis. It is being asked to identify the existing administrative/corporate record that allows the hypothesis to be accepted, corrected or rejected.
Public answer ledger and status
| Question / file | Status at 18 Aug 2026 | What is known | What remains |
|---|---|---|---|
| Canary Islands access request: Decree 224/2022 / AEAT report | Appeal pending | Request filed 7 Jul 2026. Resolution 28/2026 of 10 Aug refused access in full. The act itself identifies Decree 224/2022, file 02/2022 and the AEAT report of 17 Nov 2022 as procedural antecedents. | Segregable decree/file content, index, application, memorandum, scope of instruments and amendments. |
| Canary Islands Transparency Commissioner | Appeal filed 11 Aug 2026 | The appeal against Resolution 28/2026 requests category-by-category review, an index, partial access, metadata and competent transfers; appeal file 12/2026-0710092416. | Commissioner's decision and material compliance. |
| Separate AEAT channel | Requested | A separate 7 Jul 2026 access request seeks the binding report, antecedents and traceability; the state channel does not replace the Canary Islands idoneidad file. | Formal response/status and, where lawful, segregable access or metadata. |
| New Series F/G question | Supplement needed | Controlled evidence now separates F = €1,598,849.32 and G = €4,974,853.78 and places hotel opening on 16 Dec 2022. | Express answer whether Decree 224/2022 + AEAT report covered F, G or both, and the temporal/economic use of Series F money. |
Important: a transparency refusal, silence, transfer, closure or pending appeal is not proof of an underlying irregularity. This record states the exact procedural effect and no more.
Reconciliation with other financial lives
Do the same works, invoices, assets, costs, jobs or economic value appear in more than one layer — Community, RICPE/RIC, HNT, GC/836/P06, FEDER or other financing — and, if so, what compatibility/accumulation rules were applied?
Material overlap does not automatically equal prohibited double funding. Each instrument's expenditure base must be compared, coincidences identified and the applicable rule explained.
Public sources and legal framework
Council of Government · 1 Dec 2022 · F.O.D. 25RD 1758/2007 · art. 15Official RIC procedure · Canary Islands
The official Council of Government agenda for 1 December 2022 records, as F.O.D. 25, approval of the draft decree declaring the suitability/idoneidad of the financial instruments referred to in an application submitted by RIC Private Equity Investment Partners, S.C.R., S.A. Article 15 of RD 1758/2007 requires the application to identify who will carry out the project, describe the project and RIC requirements, its timetable and the characteristics of the instruments; it also requires a binding AEAT report. The Canary Islands procedure identifies the Tax Policy Service as processing body and the Council of Government as deciding body.
Series F/G figures and the hotel-opening date derive from RICPE's audited 2023 accounts controlled in the RICPE/CNMV dossier. The full Resolution 28/2026 and appeal contain personal data and are not reproduced here unredacted; their procedural effects, references and necessary metadata are recorded.
Right of reply, correction and contrary evidence
This is a living record. The Canary Islands Government, AEAT, CNMV, RICPE, CAM, HNT, their directors, professionals, investors, employees or any source with primary records may provide an explanation, correction or document.
A verified response showing that one authorisation clearly covered both phases, that a second act existed, that Series F reimbursed prior eligible expenditure, financed outstanding liabilities, or any other legally valid reconciliation will be published with the same prominence as the original question.
Editorial rule: never turn a documentary gap into culpability. Never turn an interested explanation into fact without source. Never hide a contradiction because it is uncomfortable. Publish what is known, what is missing, who has competence to answer, and what document would change the analysis.