Considering the notable complexity of the current model and the experience gained from the high volume of litigation resulting from its practical application, the FUNDACIÓN IMPUESTOS Y COMPETITIVIDAD (Tax and Competitiveness Foundation) believes that both Spanish and European Union (“EU”) tax regulations – and their practical application– must be reviewed, innovated and improved, to enhance the competitiveness of the Spanish and the other EU economies, based on research into, and study and dissemination of, international taxation, in active collaboration with the public economic, financial and tax authorities and supervisory bodies of both Spain and the EU, encouraging Spain’s public and private sectors to become more open to foreign relations.