On 8 October 2021, officials from Germany and Mexico signed an amending protocol to the 2008 income and capital tax treaty between the two countries. The protocol is the first to amend the treaty and includes the following changes:
- The preamble is replaced in line with OECD BEPS standards;
- Article 5 (Permanent Establishment) is updated in relation to activities of a preparatory or auxiliary character that do not result in a PE;
- Article 10 (Dividends) is amended to introduce a minimum holding…