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Nexia Ebner Stolz

Tax Advice

German Anti-Treaty-Shopping Rules

The provisions of section 50d(3) of the German Income Tax Act (EStG) on preventing the abuse of treaty benefits (anti-treaty-shopping rules) are going to be revised. To achieve this, the draft Withholding Tax Relief Modernisation Act (AbzStEntlModG) adopted by the German government on 20 January 2021 contains a proposal that responds to the requirements of EU law.

Howe­ver, trans­po­sing the cor­res­pon­ding EU legis­la­tion would also lead to a sig­ni­fi­cant tigh­te­ning of the rules.

Find out more in our bro­chure.

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