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Guide to mutual agreement procedures

c. Acceptance of the agreement by the taxpayer of the other state

Where, within a mutual agreement procedure, a mutual agreement is reached eliminating the double taxation or taxation not in accordance with the convention, if the request for initiation was submitted to the competent authority of the other state concerned or, in general, in mutual agreement procedures relating to transfer pricing, the conclusion of the mutual agreement procedure and the sending of the agreement to the competent office to be implemented will require the agreement to be accepted by the taxpayer of the other state, as well as by the Spanish taxpayer.

In that case, the competent authority of the other state will be responsible for obtaining the acceptance of the taxpayer resident in its jurisdiction and informing the Spanish competent authority of that acceptance, so that the Spanish competent authority can continue with the formalities necessary to implement the agreement.