The German Ministry of Finance has announced the signing on 18 November 2019 of an amending protocol to the 2016 income tax treaty with Finland. The protocol includes the following changes:
- The title and preamble are replaced in line with OECD BEPS Standards;
- Article 25 (Application of the Convention in Special Cases) is replaced with a new Article 25 (Prevention of Treaty Abuse), which includes the provision that a benefit under the treaty will not be granted in respect of an item of incom…