Bulgaria Bulgarian tax agreements and international agreements Other changes generally concern the taxation of funds, in particular the German investment structures used by Luxembourg private equity funds. We would like to draw your attention to the fact that the competent authorities of the contracting states notify each other of any changes to their respective tax laws with regard to the introduction of new taxes, substantial changes to existing taxes and the abolition of taxes covered by this Convention. The aim of the new Germany-Luxembourg Double Taxation Convention (DTT) is to replace the agreement signed in 1958, which corresponds to the structure and content of the OECD`s model tax treaty. Under the new Germany-Luxembourg Double Taxation Agreement, dividends are taxed as follows: 2. As long as paragraph 3 does not apply, all income or capital intended for taxation in the State of residence is excluded from the taxable base which, according to previous articles, may be taxed in the other state. However, income and capital taxes that may be taxed by the State of residence are levied at the rate applicable to the total income or total capital of the taxpayer. With respect to dividends, rates 1 and 2 apply only to dividends paid by a company in another state to a company whose minimum percentage of voting rights is held by the first company. The tax base of the State of residence also excludes the units that hold the dividends from which they are excluded from the taxable base in accordance with the third paragraph or which would be excluded in the event of distribution. This provision should not be construed as requiring a State Party to grant residents of the other State party personal allowances, tax breaks and reductions because of marital status or family obligations granted to its own residents. Germany and Luxembourg concluded their first double taxation agreement in 1959 since the convention was amended in 2011.