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Guide to mutual agreement procedures

c.12 Declaration stating whether the request includes any question which may be regarded as forming part of an agreed prior assessment procedure or another similar procedure

The request for initiation must state whether it includes any question which may be regarded as forming part of an agreed advance price agreement (APA) or another similar procedure, both before the Spanish tax administration and before the tax administration of the other state.

For example, there could be a unilateral agreement with a tax administration, Spanish or foreign, that affects the subject matter of the mutual agreement procedure.