The Spanish tax haven "black list" explicitly included the Luxembourg companies referred to under the exclusion clause of Para. 1 of the 1986 protocol to the Spain and Luxembourg income and capital tax treaty of 3 June 1986 (i.e. in general, holding companies and other assimilated companies regulated in the Luxembourg Law of 1929).
On 3 May 2000, the Spanish and Luxembourg tax administrations concluded a mutual agreement procedure that a Luxembourg SICAV is not…