The amending protocol to the 2008 income and capital tax treaty between Germany and Mexico entered into force on 6 August 2023. The protocol, signed 8 October 2021, 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 holdi…