On 12 December 2019, the German Official Gazette published a law implementing EU directive on tax dispute resolution providing a uniform mechanism to address tax treaty disputes among EU member states that meets the BEPS Action 14 minimum standard.
The law contains provisions for the effective settlement of disputes regarding the interpretation and application of bilateral tax treaties and the Union Arbitration Convention, in particular disputes that lead to double taxation. The law entered into force on 13 December 2019 and applies to disputes that were filed as of 1 July 2019 in connection with income or capital earned in tax years beginning on or after 1 January 2018. The provisions may also apply to previous disputes and tax years, if this has been agreed by the Member States concerned.
