The amending protocol to the 2011 income and capital tax treaty between Germany and Ireland entered into force on 30 December 2021. The protocol, signed 19 January 2021, 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 i…