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German Federal Council Approves Pending Protocol to Tax Treaty with Denmark

10 May 2021

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Treaty Development

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Germany-Denmark

On 7 May 2021, the German Federal Council (upper house of parliament - Bundesrat) approved the law for the ratification of the pending protocol to the 1995 income and capital tax treaty with Denmark. The protocol, signed 1 October 2020, is the first to amend the treaty and includes the following main changes: The title and preamble are replaced in line with OECD BEPS Standards; Article 7 (Business Profits) is replaced with updated provisions in line with OECD standards; Article 14 (Independent Personal Services) is deleted, and references to the performance of "independent personal services" in Articles 10 (Dividends), 11...