The amending protocol to the 2012 income tax treaty between Germany and the Netherlands entered into force on 31 July 2022. The protocol, signed 24 March 2021, is the second to amend the treaty and includes the following main changes:
- 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 period with respect to the 5% withholding tax rate, pro…