The new Australia-Germany Income and Capital Tax Treaty (2015): A tax treaty for the era of the OECD/G20 BEPS initiative?

Though the substance of the OECD recommendations will require very careful analysis, it’s clear that in a number of areas... the BEPS package contains proposals which would much better align tax systems with the dynamics and realities of modern business.[1] The new Australia-Germany Income and Capital Tax Treaty (2015)responds to the OECD recommendations in the Final Reports of the Base Erosion and Profit Shifting (BEPS)initiative. It is one of the first tax treaties concluded following the OECD/G20 BEPS initiative and the first to incorporate the final OECD recommendations.