c.12 STATEMENT DECLARING IFTHE REQUEST INVOLVES ANY ISSUE THAT COULD BE DEEMED AS INTEGRATED IN AN ADVANCE PRICE AGREEMENT 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.