Germany: Status of income tax treaties

Germany currently has income tax treaties with 96 countries.

Germany currently has income tax treaties with 96 countries.

The German Federal Ministry of Finance (BMF) on 18 January 2023 provided information on the current status of Germany’s income tax treaties.

  • Germany currently has income tax treaties with 96 countries.
  • Treaties and protocols with Mauritius and the Netherlands apply for the first time from 1 January 2023.
  • Protocols were newly signed in 2022 with Bulgaria, Latvia and Lithuania, which still need to be transposed into national law.
  • Negotiations for (amended) treaties or protocols were initiated with Albania, Brazil, Luxembourg, Malaysia, Montenegro and the Netherlands.

Pursuant to the BMF guidance, several of the treaties will apply retroactively after they have taken effect. In suitable cases, tax assessments must be made provisionally if it is uncertain when the signed treaty will come into effect, which will be to the benefit of the taxable entity.

Read a January 2023 report [PDF 385 KB] prepared by the KPMG member firm in Germany 


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