On 7 July 2017, Spain published in the Official Gazette the amending protocol to the income and capital tax treaty with Mexico as ratified. The protocol, signed 17 December 2015, is the first to amend the treaty and will enter into force on 27 September 2017. The protocol provides for the following changes to the treaty, including certain BEPS-related changes:

• The preamble is replaced to incl…