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].