MLI outlook: Germany's Act of 1 June 2026 amending its MLI Act (BGBl. 2026 II Nr. 108, published 5 June 2026) adds the Convention with Portugal to Germany's list of Covered Tax Agreements. The Convention will be modified only after Germany notifies the OECD Depositary of the extended list and of the completion of its internal procedures for this treaty (Germany applies Article 35(7) of the MLI). Once matched, at least the BEPS minimum standard is expected to apply: a new preamble (MLI Art. 6), a principal purpose test (MLI Art. 7) and mutual agreement procedure changes (MLI Art. 16). No effective date had been notified as at 15 September 2026 (OECD list of signatories and parties); check the OECD MLI matching database.
Convention between the Portuguese Republic and the Federal Republic of Germany for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital
Convenção entre a República Portuguesa e a República Federal da Alemanha para Evitar a Dupla Tributação em Matéria de Impostos sobre o Rendimento e sobre o Capital.
The Portuguese Republic and the Federal Republic of Germany, desiring to promote their bilateral economic relations by avoiding double taxation with respect to taxes on income and capital, have agreed as follows:
A República Portuguesa e a República Federal da Alemanha, desejando fomentar as suas relações económicas bilaterais pela eliminação da dupla tributação em matéria de impostos sobre o rendimento e sobre o capital, acordaram nas disposições seguintes:
We apply tax treaties to dividends, interest, royalties, salaries and gains, prepare the relief-at-source form and refund claims, and check structures against the treaty’s anti-abuse rules. A written answer and a fixed quote within one working day.
The English column is an authentic text of the Convention, reproduced from the Diário da República publication (Law No. 12/82), checked against the print in Bundestag paper 9/897. The Convention was done in Portuguese, German and English, each text being authentic; the English text prevails if the Portuguese and German texts are interpreted differently. The Portuguese text is reproduced from the official publication. Editorial notes are ours and are not part of the Convention.