a. Notification of acceptance/refusal to the Spanish taxpayer
The competent authority will have six months from when it receives the request, if it has not requested the amendment or improvement of the request or any additional information, or from when it receives all the documentation, where it has made such a request, in order to decide whether or not to accept the request for initiation, which will be notified to the taxpayer (Article 11.1 of the Regulation on Mutual Agreement Procedures).
Where, within those time limits, the taxpayer has not been notified of any decision regarding the matter, the request will deemed to have been accepted.
For the purposes of deciding the acceptance or denial of the request or whether the objection is well-founded, the competent authority may request whatever documentation and reports it considers appropriate.
The grounds on which the application may be denied are set out below.