Germany Updates Basis Model for Tax Treaty Negotiations

The German Ministry of Finance has announced an update of the model treaty used as the basis of Germany's tax treaty negotiations. As compared to the basis model published in 2013, the 2026 update takes into account the amendments to the 2017 OECD Model Tax Convention, which are mainly based on the results of the G20/OECD Base Erosion and Profit Shifting (BEPS) project, including additional protective measures against unfair tax competition and aggressive tax arrangements. In addition, the b…