Spain has published Royal Decree 399/2021 of 8 June 2021, which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. Amendments are made to the MAP Regulation to provide for the full implementation of Council Directive (EU) 2017/1852 of 10 October 2017 on the effective resolution of tax disputes, which was already partially implemented by Royal Decree-Law 3/2020 of 4 February 2020. Amendments are also made to introduce certain measures resulting from Action 14 of the OECD BEPS project and to resolve various issues and provide greater legal certainty. It is noted that the royal...