The amending protocol to the 2010 income and capital tax treaty between Germany and the UK entered into force on 17 December 2021. The protocol, signed 12 January 2021, is the second to amend the treaty and includes the following main changes:
- The title and preamble are replaced in line with OECD BEPS standards;
- Article 5 (Permanent Establishment) is amended with the addition of paragraph 4A, which provides that, subject to certain conditions, paragraph 4 (general exceptions for activities n…