Tax dispute resolution has incorporated arbitration-like elements as an increasingly relevant mechanism for resolving disputes between taxpayers and tax authorities, particularly in cross-border tax matters involving multinational enterprises (MNEs). In Spain, such mechanisms operate primarily within the framework of European Union law and are implemented through domestic legal instruments, alongside a structured economic-administrative review system incorporating quasi-arbitral features. This article provides a comprehensive analysis of the legal and institutional framework governing alternative tax dispute resolution in Spain, with particular emphasis on the interaction between EU-based procedures and domestic administrative review mechanisms. It examines the nature of the Spanish model, its procedural architecture, and its position within broader developments in tax governance. The study further identifies key practical and doctrinal challenges. Finally, it situates the Spanish system within a comparative context, including Poland and broader European and OECD-influenced developments, highlighting its relevance for taxpayers and its role in the evolving architecture of both transnational and domestic tax dispute resolution.
Arbitration: The International Journal of Arbitration, Mediation and Dispute Management