The amending protocol to the 1996 income and capital tax treaty between Estonia and Germany was signed on 15 December 2020. The protocol is the first to amend the treaty 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 to require that at least 25% of the paying company's capital is held for a...