Germany published the Withholding Tax Relief Modernization Law in the Official Gazette on 8 June 2021, which includes measures to simplify and streamline relief procedures, the digitization and centralization of procedures, and the improvement of anti-treaty abuse (treaty shopping) rules. With respect to treaty abuse in particular, a revised rule is introduced to comply with EU law and adopt certain aspects of the ATAD GAAR. The revised rule provides that a foreign company, partnership, or o…