The new and first comprehensive tax treaty between Germany and Taiwan has been formally concluded on December 28^th, 2011. This tax treaty generally follows the OECD Model Convention 2005 except for two clauses – procedural rules for taxation at source and application of the agreement in special cases – which are not the standard articles in the OECD Model Convention but frequently included in German tax treaties. In addition, the tax treaty with Taiwan contains a most favored nation clause, which provides the possibility of applying a lower withholding tax rate on gross dividends paid to a company if in a later agreement between a member state of the OECD and Taiwan a tax rate of less than 10 % has been agreed upon.