Spain has 92 tax agreements in force, as reported in its response to the Peer Review questionnaire. One of those agreements, the agreement with Mexico complies with the minimum standard.

Spain signed the MLI in 2017 and has not listed its agreements with China (People's Republic of), Japan, the Netherlands, Norway, Sweden and Ukraine. It indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used with respect to those agreements. Ukraine has listed their agreements with Spain under the MLI.

Spain is implementing the minimum standard in its tax agreements through the inclusion of the preamble statement and the PPT, combined with the LOB for its agreement with Japan.1

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

Spain’s listed agreements under the MLI will start to be compliant after Spain’s ratification of the MLI. Spain is encouraged to ratify the MLI as soon as possible. Spain indicated that the MLI was approved by its Parliament. Spain further indicated that it expected to deposit its instrument of ratification of the MLI in early 2021.


← 1. For 87 of its agreements listed under the MLI, Spain is implementing the preamble statement (Article 6 of the MLI). For 86 of its agreements listed under the MLI, Spain is implementing the PPT (Article 7 of the MLI). Spain made a reservation pursuant to Article 6(4) and Article 7(15)(b) of the MLI and three of Spain’s agreements are within the scope of this reservation (the agreements with Andorra, Mexico and Romania).

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