Germany has 96 tax agreements in force, as reported in its response to the Peer Review questionnaire. Two of those agreements, the agreements with Australia and Japan, comply with the minimum standard.
Germany signed the MLI in 2017, listing 35 tax agreements.1
Germany is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.
Germany indicated in its response to the Peer Review questionnaire that most of its agreements contain a provision based on paragraph 1 of Article 28 of the German Treaty Negotiation Basis which enables Contracting States to apply domestic anti-abuse provisions such as Section 50d of the German Income Tax Act (Anti Conduit Rule) or Section 42 of the German Fiscal Code (GAAR).
Germany further indicated that bilateral negotiations would be used for its agreements with Argentina, Belgium, Bulgaria, Canada, Costa Rica, Cyprus, Denmark, Ecuador*, Egypt, Estonia, Finland, Greece, Iceland, India, Indonesia, Iran*, Israel, Ireland, Kyrgyzstan*, Latvia, Norway, Poland, Portugal, Singapore, South Africa, Sri Lanka, Sweden, Switzerland, Tajikistan*, Trinidad and Tobago, Ukraine and the United Kingdom.