The protocol establishes a holding period for dividends, limitation of benefits provisions for payments to permanent establishments (PEs) and a new requirement for activities that are not deemed to create a permanent establishment. The Contracting States still have to ratify the protocol.Mexico and Germany signed the “Protocol Amending the Agreement Between the Federal Republic of Germany and the United Mexican States for the Avoidance of Double Taxation and Tax Evasion with respect to Taxes on Income and Capital” (the Protocol).The purpose of the Protocol is to implement measures to prevent the base erosion and profit shifting derived from the Multilateral...