During a tax audit procedure, the Spanish tax authorities (STA) challenged the application of the United States (US)-Spain Tax Treaty exemption on capital gains derived from the transfer of shares in a Spanish subsidiary.The challenge was based on the application of the General Anti-Abuse Rule (GAAR), on the grounds that the overall transaction, consisting in a series of consecutive intra-group share transfers, was artificial and an improper form to achieve the intended result.The GAAR Advisory Committee (required as part of the challenge) considered that the overall transaction (i.e., considering the series of subsequent transfers of shares) was unnatural and improper...