The Dutch government has announced that the protocol to the 2012 income tax treaty with Germany will enter into force on 31 December 2016. The protocol, signed 11 January 2016, is the first to amend the treaty. It includes primarily clarifying adjustments to Articles 3 (General Definitions), 5 (Permanent Establishment), 8 (Shipping and Air Transport), 13 (Capital Gains), and 14 (Income from Employment), as well as to the protocol originally signed with the treaty.
The protocol will apply fro…