The SPz 12-3 is a fairly mid vehicle for 6.7, and now it was uptiered to 7.0 for absolutely no reason.
Germany does not have a 7.0 lineup, the SPz 12-3 is literally the only vehicle at its tier. Discounting premiums, Germany doesnt have a good 7.3 lineup either, with the only TT vehicles there being the Luchs A2 and Wiesel 1A4. And in 7.7+ the SZp 12-3 is, quite honestly, dogpoo, while uptiering 6.7 vehicles would put those at a severe disadvantage.
As a vehicle, the SPz 12-3 is lackluster too, being very slow, very unarmored, and very large for what it is, especially compared to its counterparts in China, Japan and Italy.
It has 1(2) significant difference(s) compared to the aforementioned WZ141-1, Type 60 SPRG (C) and R3 T106 FA, namely that it trades a second 106mm RR for a 20mm Rh202 AC (and is SIGNIFICANTLY slower).
Those points are especially evident when comparing it to the WZ141-1, which has a 12.7mm MG along with its second 105mm RR, a bit over 1.5 times the top speed and over 2 times the power-to-weight ratio.
As for the 20mm AC, its utility is in not needing to spend a 106mm round on lighter vehicles, but the other 3 aforementioned vehicles have a second 106mm for that exact scenario (with the WZ141-1 having a 12.7mm). That 20mm, however, is fairly useful against aircraft. It is, however, not nearly as good against planes as IFV autocannons, due to having slower traverse rates, not nearly as much elevation and only roughly 200 degrees of horizontal traverse limits.
The turret that the 20mm is put on, however, is actively detrimental to the operation of the 106mm, due to not allowing it to get its 15 degrees of depression, one of SPz 12-3’s substantial advantages over the WZ141-1 and the R3 T106 FA, over the front. That turret is also sticking out enough to be targeted over cover when you get your gun on target, allowing the enemy to cripple the SPz 12-3 right away (option to remove the turret pls).
Anyway thanks for coming to my TED talk. If you have anything to add, please do.