a. What requirements must the request for initiation comply with?

There is no mandatory model for submitting the request for initiation.

The only formal requirement for the mutual agreement procedure request in Spain is that it be submitted in writing to the competent authority.

In addition to the above, the request must include the minimum content set out in the following section.

The Spanish competent authority can only accept requests for initiation that comply with the regulatory requirements and provided that the taxpayer is willing to provide additional information.

Consequently, if a request for initiation does not include the minimum information set out below, the taxpayer will be requested to amend any error found.

If the taxpayer does not amend the initial request within three months starting from the day following the one they were requested to do so, the proceedings will be dismissed and the request will be regarded as not having been submitted.