Interpretation of Art. 26(3) of FranceSpain tax treaty (MAP) exchange of letters published

The French tax administration published Guideline 14 A-8-05 of 8 August 2005, which reproduces the exchange of letters dated 22 December 2003 and 1 March 2005 between the French and Spanish competent authorities on the interpretation of Art. 26(3) of the France-Spain tax treaty of 10 October 1995 (mutual agreement procedure, corresponding to Art. 25(3) of the OECD Model).

Pursuant to Spanish legislation, advance pricing agreements (APAs) may …