Executive summaryOn 20 January 2021, the German Government agreed on a draft law proposing a revision and modernization of withholding tax (WHT) procedures with respect to income from capital investment and royalties in Germany. The Government draft is based on the first working draft issued by the Ministry of Finance (MoF) and published for consultation on 20 November 2020 but includes several changes, additions and deletions. Specifically, the draft law still includes the proposed changes to the German anti-treaty shopping rules and the framework for the administration of WHT and relief thereof. In addition, several changes regarding Transfer Pricing (TP), already...