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.