Bilateral tax treaties are a cornerstone of the international tax landscape and play a vital role in the global economy, attempting to reconcile the complex and ever-changing domestic tax laws of the contracting states. The main purpose of tax treaties is to foster cross-border investment and business activities albeit the more recent focus of the OECD was on the tackling of perceived tax treaty abuses.
The economies of Luxembourg and the Federal Republic of Germany are particularly intertwined. Luxembourg is a financial centre, a major fund location and the location of choice for establishing holding companies. As such, the Federal Republic of Germany is one of the main investment jurisdictions and a key investor jurisdiction of Luxembourg companies and investment funds.