The duration of the project will be of 3 years and it shall consist of the following phases:

Phase 1. In a first step, the international anti-abuse rules recognized by Spain and the United States in their own domestic law will be discussed, given that it is in internal regulations where the barriers of protection established by each country are reflected with a view to prevent both foreign investors and national entities that invest abroad, and could lead to abusive tax evasion practices by taking advantage of possible situations of international tax arbitrage or lack of sufficient control, resulting in a loss of tax revenue and directly affecting the budgets of the country.

Phase 2. The clauses established in the double taxation agreement signed between Spain and the US and the recently approved protocol in accordance with the measures recognized by the OECD to eradicate tax avoidance and evasion between the signatory States will be analyzed. The overlap of fiscal sovereignty of individual countries may lead to the double taxation of the same person, the same income or the same property, which is identified as a barrier to international transactions.

Phase 3. The aim of the last part of the project is the analysis of the implementation in practice of the new Protocol that has benefited the Spanish companies investing in the United States, in relation to the current situation. This study moves to the last phase of the project in order to have a time frame to assess in practice the effects of the new changes incorporated in the recent Protocol.