The amending protocol to the 1996 income and capital tax treaty between Estonia and Germany entered into force on 29 June 2021. The protocol, signed 15 December 2020, is the first to amend the treaty and includes the following main changes: The title and preamble are replaced in line with OECD BEPS standards; Article 9 (Associated Enterprises) is updated with the addition of provisions for corresponding adjustments; Paragraph 2(a) of Article 10 (Dividends) is replaced to provide an additional condition for the 5% withholding tax rate for at least 25% ownership (holding) to require that at least 25% of the...