b.1 International law

• Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises, signed in Brussels on 23 July 1990 (Official Gazette of 21 December 1994) [the Arbitration Convention].

• The equivalent article to Article 25 of the OECD Model Tax Convention on Income and on Capital included in each Tax Treaty signed by Spain.

• Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union [the Directive].