Germany and the UK Signed an amending protocol to the 2021 tax treaty between the two countries on 12 January 2021. The protocol 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 not resulting in a permanent establishmen…