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Guide to mutual agreement procedures

d. Cases where the request has been accepted in the other state

As mentioned above, the request for the initiation of mutual agreement procedures under the mechanism established in the Directive must be sent, simultaneously, to the competent authorities of all Member States concerned.

In the case of mutual agreement procedures initiated under the applicable Tax Treaty or the Arbitration Convention, a situation may arise in which the request for initiation is not sent to the Spanish competent authority.In such cases, the Spanish competent authority may also deny the initiation of the procedure when any of the grounds for denial set out in section 3.B arise as per the legal instrument under which the mutual agreement procedure is to be conducted.