Spain publishes a decree amending Mutual Agreement Procedure (MAP)

15 June, 2021

On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008.

The decree implements three packages of initiatives to enhance the existing MAP framework.

Full implementation of Council Directive (EU) with respect to tax dispute resolution mechanisms.
Includes certain provisions recommended by the G20/OECD base erosion and profit shifting (BEPS) project final report on Action 14.
The decree aims to resolve certain problems identified by the Spanish competent authority when entering into these types of procedures.

Royal Decree 399/2021 entered into force on 10 June 2021.

Spain

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