e. Informing courts of acceptance of the request for suspension purposes

In accordance with Article 4 of the Regulation on Mutual Agreement Procedures, the relevant Spanish competent authority shall communicate the initiation of the mutual agreement procedure to the administrative or judicial body, for the purposes of suspending any appeals relating to elements of the tax obligation affected by the mutual agreement procedure. In the case of mutual agreement procedures relating to transfer pricing or the attribution of profits to a permanent establishment, responsibility for informing the administrative or judicial body regarding initiation of the procedure always rests with the International Taxation Office, even for those mutual agreement procedures initiated with another competent authority for Spanish adjustments.