The colour-coded world map shows the countries with which Germany entered into double taxation agreements on income and capital taxes on 1 January 2019, as well as legal assistance and mutual assistance agreements (including the exchange of information). It also shows the countries with which Germany is negotiating such agreements for the first time. There is also an agreement between the German Taipei Institute and the Taipei Representative Office in Berlin. Since the Federal Republic of Germany has never recognized Taiwan as a sovereign state, this agreement is not an international treaty. However, the structure and content of the agreement is based on the OECD model convention. Hong Kong and Macao are specific administrative regions of the People`s Republic of China; Chinese general tax law does not apply to it. This means that the double taxation conventions between the Federal Republic of Germany and the People`s Republic of China do not apply to Hong Kong and Macau. The card does not contain an agreement on inheritance and donation fees or an agreement on the vehicle tax. Nor does it contain specific agreements on taxes on the income and capital of airlines and shipping companies. The map also does not contain negotiations on amending or extending existing agreements.
One of the main changes to the double taxation agreement between Germany and Switzerland relates to the taxation of dividends paid. The new agreement provides for a new threshold for free dividend distribution, which is now 10% compared to the previous 20%. The new agreement stipulates that an economic beneficiary must now hold at least 10% of the capital within the Swiss or German company that distributes the dividends. Effective beneficiaries must hold 10% for at least one full calendar year to qualify for the tax exemption. If the beneficiary does not have a 10% stake for the minimum period of 12 months, the tax on dividends is 15% in Germany and Switzerland. However, the economic beneficiary can claim a tax refund after reaching the 12-month period. In addition, German investment funds will apply a 15% withholding tax on dividend payments.