The amending protocol to the 2012 tax treaty between Germany and Luxembourg entered into force on 29 December 2023. The protocol, signed 6 July 2023, is the first to amend the treaty. Some of the main changes include the following:
- The preamble is replaced in line with BEPS standards;
- Article 1 (Persons Covered) is amended with the addition of a new paragraph 2, providing that for the purposes of the treaty, income derived by or through an entity or arrangement that is treated as wholly or p…