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Guide to mutual agreement procedures

c.10 Details of any administrative or judicial appeals brought by the applicant or by the other parties involved, as well as any decisions issued regarding the same question

The Spanish competent authority must be informed of any kind of appeal or claim relating to the transactions covered by the procedure, even if it was not brought in Spain.

Example:

The corporation tax of an Italian company is being adjusted because of transactions carried out with a Spanish associated company.

The Italian company challenges the assessment in the Italian courts.

If it wishes to initiate a mutual agreement procedure in Spain, the request must necessarily mention the appeal filed in Italy.