The New Australia-Germany Income and Capital Tax Treaty (2015): A Tax Treaty for the Era of the OECD/G20 BEPS Initiative?

Abstract

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.