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Protocol to Tax Treaty between Denmark and Germany has Entered into Force

18 January 2022

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Treaty Development

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Denmark-Germany

The amending protocol to the 1995 income and capital tax treaty between Denmark and Germany entered into force on 23 December 2021. 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 (Interest), 12 (Royalties, 13 (Capital Gains), and 21 (Other Income) are removed...