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

Spain signed the MLI in 2017, listing 86 tax agreements.1

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.2

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 signed a bilateral complying instrument with respect to its agreements with China, Japan and Romania.

Spain indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used for its agreements with the Netherlands, Norway, Sweden and Ukraine.

No jurisdiction has raised any concerns about their agreements with Spain.


← 1. In total, Spain listed 89 agreements under the MLI, three of which (the agreements with Azerbaijan*, Belarus* and Cabo Verde) are not yet in force. The agreement with Mexico, which is already compliant, was also listed under the MLI. The agreement with Romania is subject to a bilateral complying instrument and listed under the MLI.

← 2. 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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