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German Ministry of Finance Holds Newer OECD Model Commentary May be Applied to Older Treaties

|Approved Changes|Germany
Germany

On 19 April 2023, the German Ministry of Finance published a Circular on the importance of the OECD model commentary for the interpretation of double taxation agreements (DTAs). The Circular explains the Ministry's position that the current (newer) commentary to the OECD Model Convention may be applied in the interpretation of DTAs between OECD Member States that are based on the Model Convention, including older DTAs, unless otherwise provided by a letter from the Ministry of Finance or oth…

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