6.3.10.3 Concurrence with current national law

Since tax treaties restrict the application of national laws, no changes at a domestic level seem necessary for the somewhat more realistic changes to tax treaties described here. For example, as no full group approach is introduced in the somewhat more realistic variant, there will be no conflicts with current national rules for group taxation regimes. However, ideally the rules on a treaty level correspond to the rules at the national level in order to rule out mismatches or interpretation conflicts. This would also reduce compliance costs for taxpayers. For example, it is logically less burdensome not to levy withholding taxes on intra-group dividends under domestic law, than to levy and subsequently refund these taxes via an administrative process.