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Guide to mutual agreement procedures

c.3 Identification of the competent foreign tax authority

The request for initiation must identify all competent authorities involved in the mutual agreement procedure, indicating whether they have also been sent a request.

Example:

A Spanish company is tax audited resulting in tax adjustments in its corporation tax regarding transactions with French, German and Italian companies.

If the Spanish taxpayer wishes to initiate mutual agreement procedures to eliminate the double taxation which may have been caused by that tax assessment, it must submit three requests for initiation:

A request for the initiation of a mutual agreement procedure with France.

A request for the initiation of a mutual agreement procedure with Italy.

A request for the initiation of a mutual agreement procedure with Germany.

In the three requests, it must indicate that the competent authorities in Germany, France and Italy are involved in the mutual agreement procedure.