The German law providing for the ratification of the amending protocol to the 2016 income tax treaty between Finland and Germany entered into force on 3 November 2020. The protocol, signed 18 November 2019, 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 wi…