MLI from the Perspective of German Tax Administration

5.2.1. Preamble

Forming part of the action 6 minimum standard(25) modifications to the preamble are mandatory for all covered tax agreements that do not have the equivalent. In addition to that, Germany supports the new preamble because it is German treaty policy to have a clear statement that treaties are meant to avoid double taxation and at the same time avoid non-taxation. A preamble is not a substantive provision that can be applied right away. Thus, the effect of these words should not be overestimated, but according to the Vienna Convention on the Law of Treaties(26)…