On 19 January 2021, officials from Germany and Ireland signed an amending protocol to the 2011 income and capital tax treaty between the two countries. The is the second to amend the treaty and includes the following changes:
- The preamble is replaced in line with OECD BEPS standards;
- Article 5 (Permanent Establishment) is amended with the addition of paragraph 4.1, which provides that, subject to certain conditions, paragraph 4 (general exceptions for activities not resulting in a permanent …